It became official on Friday morning, 17th July 2026: The Packaging Act Implementation Act (VerpackDG) is in the Federal Law Gazette. With this, the countdown has irrevocably begun – the law comes into force on 12th August, simultaneously with the entry into force of the EU Packaging and Packaging Waste Regulation (PPWR). The Packaging Act of 2017 is thus history. What the announcement means, which obligations remain, what is changing, and which transitional periods the industry now needs to be aware of.
The proclamation makes the law irreversible
Federal Law Gazette 2026 Part I, No. 207, issued in Bonn on 17 July 2026 – behind this dry citation lies the most important packaging law decision in almost a decade. The „Act to Adapt Packaging Law and Other Legal Areas to Regulation (EU) 2025/40" of 13 July 2026, signed by Federal President Steinmeier, Federal Chancellor Merz, and Federal Minister for the Environment Carsten Schneider, has overcome the final formal hurdle of the legislative process with its announcement.
This makes it clear: there is no going back. Speculation about deferrals, last-minute improvements, or the watering down of individual obligations has been settled. Article 8 (7) of the German Act on the Adaptation of Law lays down a binding date of 12 August 2026 for the entry into force of the core part – the Packaging Law Implementation Act (VerpackDG). This is exactly the day on which the EU Packaging Regulation 2025/40, better known as PPWR, also takes effect EU-wide. Correspondingly, Article 7 stipulates that the Packaging Act of 5 July 2017 will cease to have effect at the end of 11 August 2026. For companies, this means a sharp break without a transition period in the true sense – anyone placing packaging on the German market on 12 August will be doing so under a completely new legal framework.
Implementing law instead of full regulation: The new architecture
Anyone expecting a one-to-one continuation of the Packaging Act in the Packaging Act Implementation Act will quickly notice the fundamentally different structure. The Packaging Act Implementation Act is – as the name suggests – an implementation law. The substantive requirements for packaging itself, from recyclability and recycled content to labelling and reduction of small quantities, will henceforth be directly in the PPWR and will apply directly as an EU regulation, without any national implementation act. According to Section 1, the Packaging Act Implementation Act will only regulate what the regulation leaves to the Member States or expressly mandates: primarily the organisation of extended producer responsibility, the registration and reporting system, dual systems, the deposit system, and sanctions.
In practice, this means that compliance officers will have to read on two fronts in the future. The question „May I market this packaging like this?“ is answered by the PPWR; the question „What registration, participation, and reporting obligations apply to me in Germany?“ is answered by the VerpackDG – often with direct references within the regulation.
What remains: Registration, System Participation, Central Agency
Despite all the reorganisation, the legislator is essentially relying on established structures. The registration obligation remains: under Section 6 of the Packaging Act (VerpackDG), manufacturers must register via the electronic system of the Central Agency for Packaging Register (Zentrale Stelle Verpackungsregister) before making packaging available – the authority function under Article 44 of the PPWR clearly lies with the ZSVR. The Central Agency for Packaging Register Foundation itself will continue to exist in its current legal form under Section 48.
The obligation to participate in a system also survives the system change: § 7 continues to oblige manufacturers of packaging subject to system participation to participate in one or more dual systems before placing them on the market. Data reporting to the ZSVR (§ 9) and the annual declaration of completeness, which must be submitted by 15 May according to § 10, are also familiar – with the known quantity thresholds of 80 tonnes for glass, 50 tonnes for paper, cardboard and carton, and 30 tonnes for other types of material. The de minimis limits for data reporting have been readjusted, however: manufacturers with less than ten tonnes of packaging subject to system participation in the previous year will now only report annually instead of on an ongoing basis (§ 9(2)). Also new to the rules are „other producer responsibility organisations“ through which manufacturers of packaging not subject to system participation can fulfil their obligations.
Beware, definitional pitfall: producer is not the same as manufacturer
Perhaps the biggest stumbling block of the new legislation is of a terminological nature. Article 3 of the PPWR defines „producer“ as someone who manufactures packaging or packaged products, or has them developed or manufactured under their own name or brand – conformity obligations are incumbent upon them. In contrast, the „manufacturer“ as defined by the Packaging Act (VerpackG) is the addressee of extended producer responsibility, i.e., registration, system participation, and reporting. Both roles may, but do not necessarily have to, be held by the same entity. Anyone who still interprets the terms with the logic of the old Packaging Act risks assigning obligations to the wrong party within the company or supply chain. Therefore, a clear assignment of roles for each product line must be at the very top of the agenda for the coming weeks.
The transition periods: These dates the industry needs to know
The most practically important paragraph for late summer is § 68. It ensures that the 12th August deadline does not become a cold start. Those already registered under § 9 VerpackG are automatically deemed registered under § 6 VerpackDG; any necessary changes to the registration details must be made by 12th November 2026. Manufacturers falling under the registration requirement for the first time must register by 12th September 2026 – a remarkably short deadline of just one month after entry into force. Existing system participations continue, but for a maximum of until 31st December 2026; therefore, at the turn of the year at the latest, participation ratios must be on a new basis. Organisations performing the tasks of another Producer Responsibility Organisation may continue to do so on a transitional basis without authorisation, but for a maximum of until 31st October 2027.
Fines up to €200,000
The fact that the legislator is serious is shown by the catalogue of sanctions. § 66 lists several dozen administrative offences in two paragraphs – from failure to register and lack of system participation to violations of directly applicable PPWR articles, for example regarding deposit refunds or reporting obligations. The most serious violations, including failure to participate in a system and operating a system without authorisation, can be punished with fines of up to €200,000; a range of up to €100,000 applies to numerous other offences. This is supplemented by sales bans: distributors are not allowed to supply packaging from unregistered manufacturers, and fulfilment service providers must also check the proper registration of their clients – the ZSVR provides an automated data comparison for this purpose.
And after that? The law already thinks ahead
It is noteworthy that the adaptation law already announces future legislative changes. Article 4 amends the recently established Packaging Act (VerpackDG) itself – in stages on 1 January 2027, 12 February 2028, and 1 January 2030, partly depending on delegated acts from the Commission. For example, national special rules will be abolished as soon as the corresponding PPWR requirements come into effect. Furthermore, the Single-Use Plastics Fund Act will be amended on 1 January 2027. The message behind this is that German packaging law will gradually recede further behind the EU regulation in the coming years. It is not the end of the transition for the industry on 12 August – but its binding beginning.
The exact wording of the law can be found here in the Federal Law Gazette
