In a joint letter, several German industry associations have appealed to Federal Environment Minister Carsten Schneider (SPD) to support a postponement of the date of application of the new EU Packaging Regulation (PPWR). The current deadline of 12 August 2026 would lead to considerable implementation problems. The letter is available to packaging journal.
In the letter, the signatory associations - including well-known representatives from the packaging industry, retail and the waste management sector - warn of „serious practical problems“ if the new EU regulation comes into force on 12 August 2026 as planned. Instead, they argue for a postponement to 1 January 2027 in order to create time for legally secure national implementations and transitional regulations.
Legal uncertainty and planning problems feared
Specifically, the senders criticise the fact that the start date is in the middle of the financial year, resulting in two different legal regimes within one calendar year. New definitions such as „manufacturer“ or „producer“ would call into question the previous distribution of roles in extended producer responsibility (EPR) - with potentially far-reaching effects on licensing obligations, financing structures and responsibilities.
It is also unclear until the end of 2026 how the new EU law will be implemented nationally. The corresponding German implementation law will not be available until mid-2026 at the earliest, and key questions of interpretation at EU level remain unanswered. As a result, dual systems, manufacturers and municipalities will not be able to conclude contracts, plan volumes or calculate services.
Risk to municipal services and system stability
The authors are particularly concerned about the stability of the system. The parallel implementation of old and new regulations leads to duplicate contracts, increased bureaucracy and financial risks. Without clear responsibilities, the financing of municipal tasks such as waste advice or container cleaning would be jeopardised. In the worst case scenario, the entire EPR system could be destabilised.
Associations demand postponement until 1 January 2027
The associations therefore believe that a Europe-wide coordinated postponement to 1 January 2027 is the only practicable way forward. This is the only way to achieve the goal of an orderly, legally compliant and economically viable implementation. A postponement would also fulfil the EU-wide requirement to reduce bureaucracy and ensure planning security.
Germany could play an active role here, the report continues - also because comparable challenges exist in other EU member states.
Demand with a signalling effect
With this letter, the signatory associations are sending a clear signal to the Federal Ministry for the Environment and the EU Commission. In view of the tight deadlines and unresolved implementation issues, decisive political action is called for. It remains to be seen whether and to what extent the Federal Government will respond to the demand.
The letter in full
Dear Mr Federal Minister,
We are making an urgent appeal to you today: please work at European level to postpone the date of application of the EU Packaging Regulation (2025/40, PPWR) from 12 August 2026 to 1 January 2027. The current date of application leads to serious practical problems, which we explain in the following overview:
- Two legal regimes within one financial year:
From 12 August 2026, new EU definitions (including „producer“, „producer“) will apply, with significant effects on the distribution of obligations in the extended producer responsibility (EPR) system. The obligation for companies to licence packaging is shifting, which may lead to previously obligated parties suspending or reducing their payments because it is unclear who will be responsible in future.
- Lack of legal clarity at EU and national level:
The national Packaging Act will remain partially applicable until the end of 2026. At the same time, the German implementation law is not expected to be available until mid-2026. Key questions of interpretation at EU level - for example on quota fractions or packaging categories - have also not yet been answered.
- Blocked planning and contract security:
Without clarity on definitions and obligations, neither EPR systems nor manufacturers can plan reliably. Annual contracts, volume forecasts and pricing are impossible. Municipalities, on the other hand, do not know whether and through which dual system services such as waste counselling or container cleaning will continue to be financed.
- Bureaucracy and financial risks with systemic relevance:
The changeover during the year requires duplicate contracts, data reports and billing procedures - an enormous amount of additional work without any ecological benefit. At the same time, there is a risk of financing gaps in system services, including the loss of municipal tasks or the destabilisation of EPR structures.
The solution: a practicable, Europe-wide deferral: Postponing the date of application of the new rules to 1 January 2027 would give all parties involved the necessary time to implement the new regulations in a legally secure and orderly manner.
National implementation laws could be prepared, open questions clarified at EU level and economically viable transitional arrangements created.
A postponement would also be in line with the EU's aim of reducing unnecessary bureaucracy and ensuring predictability - instead of creating new, avoidable hurdles. EPR systems in other member states also face the same challenges - Germany would not be alone with such an initiative, but could take on a coordinating role.
We therefore urge you to make a strong case to the EU Commission and your colleagues in the Member States for this pragmatic and system-stabilising adjustment.
