Compliance has long been mandatory – it determines market access. While many are still grappling with Germany’s Packaging Act (VerpackG), the new EU Packaging Regulation (PPWR) is already in the starting blocks.
Review: Packaging Act
Since 2019, Germany’s Packaging Act has governed manufacturers’ responsibility for sales, return, and shipping packaging. The basic principle is that whoever first places packaging on the market commercially is responsible for its collection and recycling.
Overview of Responsibilities
- Registration: Registration in the LUCID registry of the Central Agency for Packaging Registers (ZSVR).
- System participation: Entering into a licensing agreement with a dual system (for recycling).
- Data reporting: Regular reporting of packaging volumes.
Outlook for the Packaging Act & PPWR (starting in mid-2026)
The PPWR (EU Regulation) and the VerpackDG (Packaging Implementation Act) will work together starting in August 2026: The PPWR sets the substantive rules for all of Europe (e.g., recycling rates, design, minimum recycled content requirements, and uniform labeling), while the German implementing law, the VerpackDG, is expected to regulate implementation in Germany—such as responsibilities, inspections by the ZSVR, and fines.
The key new features of PPWR in detail:
- EU-wide consistency: The PPWR applies directly in all EU member states, which is intended to simplify cross-border compliance in the long term
- Design for recycling & recycling grades: By 2030, all packaging must be recyclable or reusable and meet specific design-for-recycling requirements. To this end, a system of recyclability grades will be introduced:
Performance levels A, B, and C are planned, with minimum recyclability rates of 70–95%; packaging below these levels is no longer considered “recyclable.”
Starting in 2030, packaging with less than 70% recyclability may no longer be placed on the market (belowClass C).
Starting in 2038, Class C will also be phased out, so that only highly recyclable packaging (A and B) will be permitted.
Minimization, empty space, and “deceptive packaging”
The PPWR stipulates that packaging must be reduced to the minimum necessary size; unnecessary double walls, false bottoms, or oversized outer cartons will no longer be permitted. Starting January 1, 2030, a maximum void space ratio of 50% will apply to group, transport, and e-commerce packaging, with filling materials such as air cushions, foam, or chips counting as void space.
Bans on certain single-use packaging
The regulation includes phased bans on certain types of single-use packaging, particularly plastic packaging. These include, among other things, certain types of single-use food and beverage bags and certain miniature hotel and cosmetic packaging.
Labeling, Digitization & Consumer Information
In the future, packaging must bear standardized labels that clearly indicate how it should be sorted and disposed of. In addition, a digital information system (e.g., QR codes, digital product passports) will be established to provide access to detailed recycling and content information.
EU Declaration of Conformity
In the future, packaging may only be placed on the market if a written declaration of conformity is provided. This legally confirms that the packaging meets the requirements of the regulation. These include recyclability (Art. 6), compliance with substance restrictions (e.g., PFAS/lead), and the minimization of packaging weight.
Contact us for comprehensive advice on your compliance issues relating to electrical and electronic equipment, packaging, batteries, and PV panels.
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