From 12 August 2026, new Extended Producer Responsibility (EPR) requirements will apply under the PPWR: for own-brand packaging, as well as imported third-party branded packaging without a domestic intermediary, the responsibility will lie with retailers. Retail companies will in future be responsible for financing the recycling of this packaging. There is no transitional period: the EPR obligation must be fulfilled before the packaged goods are sold.
With the introduction of the PPWR, Extended Producer Responsibility is being reallocated. Trading companies are affected in two key cases: firstly, responsibility for own-brand packaging lies with companies that develop or have products manufactured under their own name or brand. It is not possible to transfer this obligation to suppliers or contract fillers. Secondly, companies that import packaged products into Germany from abroad without a domestic intermediary must take on system participation for these imports. The decisive factor here is the first placement on the market in the country where the packaging becomes waste.
Risks to system stability
The new regulation carries risks for the stability of the packaging recycling system. If previously obligated parties deregister their volumes and retailers do not participate their packaging volumes in the system in a timely and complete manner, a funding gap will arise. This gap could jeopardise the competitively organised system of packaging disposal. Furthermore, appropriate sorting and recovery capacities must be contracted by the system operators at an early stage to avoid significant shortfalls in recycling rates.
Need for action for companies
To ensure the stability of packaging recycling, the Central Agency Packaging Register (ZSVR), together with a panel of experts, has developed the „Trade Action Plan“. Under the motto "Acting Responsibly: Implementing PPWR. System participation for own brands and imports, without gaps, starting now", the necessary steps are outlined:
- Enquiries to suppliers regarding packaging information: Companies need details on the weights and material fractions of their own-brand and imported packaging to provide accurate quantity forecasts from August.
- Timely adjustment of system participation: Trading companies should conclude new contracts or extend existing contracts with their system operators for the additional quantities well before the deadline.
- Update of registration data in the LUCID packaging register: All brand names for which system participation will have to be assumed in future should be added to the registration.
- Notification of adjusted plan and forecast quantities in the LUCID packaging register: The details must correspond to the notifications with the system operators.
- Ensuring traceable documentation: All relevant packaging and quantity data should be recorded to provide a basis for the year-end quantity report and a possible subsequent declaration of completeness.
Only if all these steps are fully implemented by 12th August can trading companies fulfil their future responsibilities and avoid a sales ban. This is the basis for stable financing of packaging recycling. Companies are now called upon to act quickly to meet the new requirements.
Source: Central Agency Packaging Register (ZSVR)
