The European Commission has not maintained its objections, raised through the TRIS procedure, to the German draft of the Packaging Act Implementation Law (VerpackDG). Consequently, the previously extended standstill period, which had delayed the legislative process, lapses. For the Federal Ministry for the Environment, this means that the VerpackDG could now come into effect as planned on 12 August 2026.
The development emerges from a new notification in the European notification procedure. In May, the Commission issued a reasoned opinion on the German draft law. This extended the standstill period to 17 August 2026. In terms of content, the concerns related, among other things, to individual definitions and regulations in connection with the implementation of the European Packaging Regulation PPWR.
Extended grace period lapse
With the notification now published, the reasoned opinion is no longer effective. This means that the extended standstill period no longer applies. From the document itself However, it is not apparent that the Commission expressly approved the law or gave a formal „green light“. Instead, it is noted that the previously raised objections are no longer being pursued.
For the federal government, however, this is an important step. The VerpackDG serves to adapt German packaging law to the requirements of the EU Packaging Regulation, which will apply directly in all member states from 12 August 2026.
Success for the German argument
With the abolition of the extended standstill period, the risk of a temporal gap between the PPWR coming into effect and the necessary adjustments to national law. Companies along the packaging value chain will therefore likely gain more planning security for the implementation of the new European regulations.
The withdrawal of the objections is also a success for the federal government. In its statement, it had defended in detail the regulations criticised by the Commission and justified their compatibility with the PPWR. According to the information, the Commission's objections concerned, in particular, definitions of terms in the draft law and requirements for the manufacturer register. Germany argued that the criticised regulations either constituted independent national definitions or concerned areas that were not fully harmonised by the PPWR.
Berlin accordingly pointed to, among other things, the necessity of national definitions for the implementation of packaging law, as well as the continued central role of the packaging register as long as the registration platform provided for at the EU level is not yet available. The fact that the Commission is not pursuing its reasoned opinion speaks for the fact that this argumentation was convincing in the further proceedings.
Whether the Packaging Act will actually come into force as planned on 12 August 2026 now depends on the remaining national legislative steps.
