On 11 February 2026, the Federal Cabinet adopted the draft for a new Packaging Law Implementation Act. The Alliance Packaging and Environment (AVU) rates key changes to the draft bill positively, but criticises the lack of economic incentives to strengthen the plastic recyclate markets.
With the new Packaging Law Implementation Act the EU packaging regulation PPWR is to be embedded in German law and replace the previous Packaging Act. The AVU recognises important adjustments in the cabinet's decision, but still sees structural challenges, particularly for the plastics recycling market.
More personal responsibility instead of additional institutions
The AVU is positive about the fact that the originally planned new organisation for reduction and prevention tasks is not being pursued further.
„An additional institution is not required under European law. Reusable packaging promotion and packaging reduction can be implemented without bureaucratic superstructure and disproportionate costs. The cabinet's decision gives companies significantly more responsibility here. The industry must now show that it fulfils this responsibility.“
Carl Dominik Klepper, Chairman of the AVU
Doubts about the achievability of higher recycling rates
With regard to the planned higher recycling quotas for plastics, aluminium and ferrous metals, the AVU supports the goal of a stronger circular economy in principle. At the same time, the association expresses doubts about the practical feasibility under the current market conditions. According to the AVU, collection volumes are declining for many materials, while the quality of the material flows is deteriorating. In addition, plastics recyclers are suffering from weak demand, as new materials are often offered at lower prices.
„Higher recycling targets cannot solve the current crisis in plastics recycling. As long as easily recyclable packaging or packaging with recycled plastic content does not receive a systematic financial advantage, the economic basis of plastics recycling will remain fragile,“ emphasises Klepper.
The AVU is critical of the fact that the draft law does not provide for any further development of the ecological design of the participation fees. According to the association, a financial incentive for packaging that is demonstrably easy to recycle or contains recyclate could have provided short-term incentives. Instead, the Federal Ministry for the Environment refers to European requirements that are not due to take effect until 2030.
The draft law will now be notified to the EU Commission. This will be followed by consultations in the Bundestag and Bundesrat. The new law must enter into force by 12 August 2026 at the latest.
Source: AVU
