Whether packaging is actually recycled is determined only in practice – by the mix of materials, sorting technology, and market demand. While new laws are now forcing the market to rethink its approach, current data shows where Germany stands today:
According to current data from the Federal Environment Agency, the overall recycling rate for all packaging is 69.4%. This is the actual amount recycled in Germany:
- Ferrous metals & paper: 86.8% / 86.6%
- Glass: 80.6% (Despite being infinitely recyclable, this is not a top figure due to mis-sorting)
- Aluminum: 68.0%
- Plastics: 52.2% on average. However, pure household plastics from the yellow bag already exceed the 70% mark in material recycling.
- Wood: 30.2%
The EU comparison for plastic packaging
With a rate of 52.2%, Germany is above the European average. According to current data from Eurostat, the comparison for plastic recycling in Europe looks like this:
• Belgium: 59.5% (European leader)
• Germany: 52.2%
• EU average: 42.1%
• France: 25.7%
Looking ahead: No more advertising myths
Anyone who uses vague slogans in their advertising is treading on thin legal ice. Legal requirements for packaging and environmental advertising are being tightened:
- The EmpCo Directive is taking effect: Starting September 27, 2026, strict rules against greenwashing will apply across Europe. Generic advertising phrases such as “environmentally friendly” or “green” are strictly prohibited without comprehensive proof. It is also illegal to misrepresent products as “climate-neutral” through CO₂ offsetting alone.
- PPWR – Design for Recycling Starting in 2030: Starting in 2030, all packaging must meet strict “Design for Recycling” criteria. Non-separable composite materials will be phased out of the market. Packaging with less than 70 percent recyclability will be banned.
- “At Scale” Principle Starting in 2035: Starting in 2035, theoretical recyclability in the laboratory will no longer be sufficient. Companies must provide binding proof that their packaging is collected, sorted, and actually recycled on a large scale (“at scale”) in practice. Without a functioning infrastructure or market for the recycled material, packaging is officially considered non-recyclable.
In the future, mere recyclability on paper will no longer be sufficient from a legal standpoint. While the EmpCo Directive strictly prohibits unsubstantiated greenwashing claims as of September 27, 2026, the PPWR will require actual proof of recycling “at scale” starting in 2035. For companies, developing circular packaging will thus shift from a voluntary sustainability strategy to a legal and economic necessity.
Contact us for comprehensive compliance consulting on electrical equipment, batteries, packaging, and PV panels – and subscribe to our newsletter to stay up to date on laws and trends.
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