VerpackDG: The German PPWR Implementation Act at a Glance
Published in the Federal Law Gazette on 17 July 2026, entering into force essentially on 12 August 2026: The Packaging Law Implementation Act (VerpackDG) replaces the Packaging Act and aligns German packaging law with the PPWR. What the act regulates, what continues to apply from the VerpackG – and when which fines apply.
What is the VerpackDG?
The VerpackDG is Article 1 of the „Act to Adapt Packaging Law and Other Legal Areas to Regulation (EU) 2025/40“ of 13 July 2026, promulgated on 17 July 2026 Federal Law Gazette 2026 I No. 207. It comes into force – with staggered exceptions – on 12 August 2026, at the same time as the PPWR becomes applicable. Since the PPWR is a regulation and therefore directly applicable, the VerpackDG governs what remains to be regulated at national level: responsibilities, the producer register, the authorisation of dual systems, deposits, enforcement and sanctions.
Relationship with the PPWR
The obligations themselves – restrictions on substances, conformity assessment, documentation, declarations, and the responsibilities of the various parties – are set out in the PPWR and derive from it Articles 5–21, 38 and 39 of the PPWR. The VerpackDG supplements definitions, procedures and enforcement Sections 1–3 of the Packaging Act. Anyone wishing to understand German packaging law must therefore always consult both levels – the regulation for the „what“ and the Act for the „how“ in Germany.
What remains in force: registers, systems, decisions
- LUCID registrations: Anyone who was registered under the previous Section 27 of the Packaging Act (VerpackG) is also considered registered under the new law; participation in training must be proven by 31 December 2027, otherwise the registration shall be deemed cancelled from 1 January 2028. Section 68(16) of the Packaging Act.
- Dual systems: Systems approved as at 11 August 2026 shall be deemed authorised, provided they demonstrate compliance with additional requirements by 1 January 2027 Section 68(11) of the German Packaging Act (VerpackG).
- Classification decisions by the ZSVR: Decisions made before 12 August 2026 remain valid; they may be amended if the new legislation provides for a different classification Section 68(15) of the Packaging Act.
The language rule for the declaration of conformity
The PPWR leaves the language issue to the Member States Article 39(2) PPWR. Germany has answered them in a practical manner: The EU declaration of conformity can, at the manufacturer's choice, in German or English be issued Section 62 of the Packaging Act. For companies with an international presence, this means that an English version is sufficient for the German market.
Fines: two stages, two deadlines
The Packaging Act (VerpackDG) distinguishes between two groups of administrative offences: breaches of national obligations under the Act itself Section 66(1) of the German Packaging Act (VerpackG) have been subject to fines since 12 August 2026. Infringements of PPWR obligations – such as failure to carry out a conformity assessment, missing documentation or retention violations Section 66(2)(3) and (4) of the Packaging Act (VerpackDG) – are only available from 12 February 2027 to apply Section 68(17) of the German Packaging Act (VerpackDG). Details of the affected disclosure obligation: PPWR Declaration of Conformity.
Outlook: pre-programmed changes
The omnibus act already contains consequential amendments that have been passed with staggered entry into force dates – including 1 January 2027 and 12 February 2028. Articles 4 and 5 of the Act, Federal Law Gazette 2026 I No. 207. Packaging law is therefore constantly evolving; individual adjustment steps also depend on the enactment of European legal acts (!). We continuously categorise which changes affect whom in the packaging journal.
Frequently Asked Questions
Does the VerpackDG replace the Packaging Act?
Yes – the Packaging Act (VerpackDG) is replacing the previous Packaging Act; numerous transitional provisions ensure continuity, for example for LUCID registrations and system approvals (Section 68 VerpackDG).
Does my LUCID registration remain valid?
Yes, existing registrations remain valid. However, participation in training must be proven by 31 December 2027, otherwise the registration will be deemed revoked from 1 January 2028 (§ 68 para. 16 VerpackDG).
When do fines threaten under the Packaging Act?
For breaches of national obligations from 12 August 2026 (Section 66 (1) VerpackDG); for breaches of PPWR obligations only from 12 February 2027 (Section 66 (2), Section 68 (17) VerpackDG).
Two levels of law, one radar
PPWR Radar keeps track of both PPWR and VerpackDG: every requirement is linked to its source at both levels, and every change is matched against your profile – with a notification if it affects you.
Start free impact assessment5 questions, no registration – initial assessment of what the PPWR means for your packaging.
This article provides an explanation and overview; it does not constitute legal advice and is no substitute for an assessment of the individual case. Sources: Regulation (EU) 2025/40 (PPWR, OJ L of 22 January 2025), Packaging Law Implementation Act (VerpackDG, Federal Law Gazette 2026 I No. 207). Legal status: 12 August 2026.