{"id":115410,"date":"2026-05-13T13:49:15","date_gmt":"2026-05-13T11:49:15","guid":{"rendered":"https:\/\/packaging-journal.de\/?p=115410"},"modified":"2026-05-12T17:00:53","modified_gmt":"2026-05-12T15:00:53","slug":"overly-packaged-bureaucracy","status":"publish","type":"post","link":"https:\/\/packaging-journal.de\/en\/verpackdg-mehr-buerokratie-als-noetig\/","title":{"rendered":"Packaging Act: More bureaucracy than necessary"},"content":{"rendered":"
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The new Packaging Act Implementation Act (VerpackDG) transposes the PPWR into German law \u2013 and brings significantly more bureaucracy for the industry than is required by European law. Packaging law expert Dr. Markus Pauly sees the law as a prime example of gold-plating and warns of distorted competition with other EU member states.<\/strong><\/p>\n

In February, the Federal Cabinet passed the draft Packaging Act Implementation Act (VerpackDG). The Act establishes the national legal framework for the implementation of the EU Packaging and Packaging Waste Regulation (PPWR) and will completely replace the existing Packaging Act from 12 August 2026. This step is generally undisputed: \u201eThe fact is that the VerpackDG is a necessary prerequisite for enforcing the PPWR, which comes into force on 12 August 2026, in Germany,\u201c clarifies Dr. Markus Pauly from the Cologne law firm Pauly Rechtsanw\u00e4lte. Pauly is considered one of the most renowned specialists for packaging law in Germany. However, when looking at the specific details of the Act, the expert's agreement quickly ends.<\/p>\n

\"\"The Packaging Act, as amended by the cabinet's decision, is a prime example of over-regulation, the opposite of bureaucracy reduction and \u201agold plating\u2018.<\/p>\n

Dr. Markus Pauly of the Cologne law firm Pauly Rechtsanw\u00e4lte<\/p><\/blockquote>\n

The Central Agency Packaging Register (ZSVR) will become a \u201esuper authority\u201c, with new licensing procedures for Producer Responsibility Organisations (PROs) and new definitions being introduced. His conclusion: \u201eIn any case, the regulations go beyond the minimum requirements of the PPWR for national implementing acts.\u201c<\/p>

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One of the most far-reaching innovations concerns the registration requirements. In future, all extended producer responsibility organisations and individual producers that do not use collective systems will require formal registration, which will be processed through the ZSVR. The legislator is relying on a high degree of automation for this. Pauly considers the extension to producers of packaging not subject to collective participation to be not absolutely necessary under European law: \u201eA leaner solution would have been conceivable here, one that does not interfere so much with the functioning market for packaging disposal at B2B collection points.\u201c Producers of transport, reusable, industrial and commercial packaging would also be affected in future \u2013 an area that has so far been largely left out.<\/p>\n

Redesign of the ZSVR financing<\/h2>\n

Linked to this is the redesign of the ZSVR (Central Register for Packaging) financing. Previously, the dual systems and operators of industry solutions primarily bore the costs of the register. In the future, individual manufacturers and producers of non-system-participating packaging will also be directly involved in financing \u2013 a significant expansion of the circle of those liable for costs.<\/p>