The Packaging Act Implementation Act (VerpackDG) is all but passed, shortly before the deadline of 12 August 2026: it is intended to take effect at the same time as the EU Packaging Regulation (PPWR) comes into force, with only the German Bundesrat's approval still pending before the summer recess. However, this does not provide real planning certainty, as lawyer Dr. Markus W. Pauly highlights at Future Resources in Cologne.

Two construction sites remain open: firstly, there is a dispute over the central terms of the PPWR – above all the producer and manufacturer definitions. Secondly, it is unclear how the approval of Producer Responsibility Organisations (PROs) by the Central Agency will be specifically structured. Anyone who wants to be fully compliant by the deadline simply cannot do so due to a lack of detailed specifications.

However, Pauly is not giving the all-clear. Although fine regulations will only apply later and the enforcement of packaging law in Germany has always been cautious – no world will end on 13 August. However, the implementation effort is enormous. His advice: start with all your might now, instead of relying on transition periods.