The German Packaging and Environment Alliance (AVU) warns of what it sees as an impending misdirection in the draft bill for the German Packaging Law Implementation Act (VerpackDG). The Federal Environment Ministry's proposal to implement the EU Packaging Regulation (PPWR) could cause additional bureaucratic costs and legal uncertainties for companies and leave opportunities to promote sustainable packaging unutilised.
At the core criticised the AVU that the design In addition to transposing the PPWR into German law, there are plans to establish an organisation to provide financial support for measures to promote reusable systems. According to the AVU, the annual costs of around 90 million euros are to be borne by the packaging manufacturers.
Planned organisation for reusable transport as a point of contention
According to AVU, such an organisation is not provided for in the PPWR, which has already attracted widespread criticism. AVU Chairman Carl Dominik Klepper says: „Such an organisation is not provided for in the PPWR and runs counter to the leanest possible implementation and thus also to the agreements in the coalition agreement. It leads to high additional costs that ultimately fall back on consumers. This is completely disproportionate to the expected added value for the circular economy and fails to recognise that there are already a large number of initiatives for the sustainable handling of packaging.“
Call for stronger incentives for recyclable packaging and the use of recyclates
The AVU also sees a need for improvement in the design of incentives for more sustainable packaging. From the association's point of view the design take the opportunity to „finally create effective incentives“ for highly recyclable packaging and packaging with a recycled content. Klepper is quoted as saying: „The German regulations should be further developed as soon as possible, the plans are on the table. Waiting years for the implementation of EU requirements, as envisaged in the draft law, is half-hearted and slows down manufacturers of sustainable packaging solutions.“
In this context, the AVU is calling for targeted financial incentives for packaging that is proven to be very easy to recycle as part of the new VerpackDG. According to the association, this should also help to overcome the current crisis in the recycling industry by making recycled material more attractive than virgin material from a cost perspective.
Change in definition of „manufacturer“: AVU argues in favour of postponement to 2027
Criticism The AVU also criticises the planned change to the definition of „producer“ of packaging in mid-2026. In the association's view, such a change „in the middle of the year“ would mean additional bureaucracy for the dual systems. Klepper explains: „What sounds like a formality has far-reaching consequences: The new EU definition means that for 40 per cent of consumer packaging, other manufacturers than before must be made financially responsible for the disposal of their packaging. This mammoth task could jeopardise the overall system of packaging disposal in Germany.“ The AVU recommends that the change in definition should not take place until 2027 and that this should be secured by a transitional provision in the VerpackDG.
According to the press release the VerpackDG be adopted in the parliamentary procedure at the beginning of 2026 and come into force in August 2026.
Source: AVU
