VerpackDG and PPWR: What Companies Need to Know Now
On 12 August 2026, packaging law changed fundamentally. The previous Packaging Act (VerpackG) was replaced by the European Packaging and Packaging Waste Regulation (PPWR) and the Packaging Law Implementation Act (VerpackDG). The new rules establish a harmonised legal framework for packaging and packaging waste across Europe and broaden the focus from waste disposal to the entire life cycle of packaging. The Central Agency Packaging Register (ZSVR) provides a detailed explanation of this replacement.
For many companies, key obligations initially remain in place. At the same time, the PPWR and VerpackDG introduce new terminology, responsibilities and requirements that may have significant long-term effects on packaging design, compliance processes and supply chains.
What remains unchanged for companies?
Companies that were already required to meet obligations under the Packaging Act will recognise many of them.
The continuing core obligations include:
- Registration with the LUCID Packaging Register
- System participation for packaging subject to system participation
- Data and volume reporting
- Declarations of completeness for companies subject to this obligation
The basic structure of extended producer responsibility therefore remains in place. Companies must continue to ensure the financing of the collection, sorting and recovery of their packaging.
The biggest change: new roles in packaging law
For the first time, the PPWR distinguishes between two different roles throughout Europe:
Manufacturer
The manufacturer is responsible for the conformity of the packaging. It must be able to demonstrate that the packaging meets the requirements of the PPWR. In future, this will include, in particular, the technical documentation and the EU declaration of conformity.
Producer
The producer bears extended producer responsibility in the EU Member State in which the packaging becomes waste. Its obligations include, in particular, registration, system participation and data reports.
In many cases, the manufacturer and producer are the same entity. In international supply chains or import arrangements, however, the roles may be held by different entities. Companies should therefore assess which role they will have for their packaging in future.
Packaging itself is receiving greater attention
The previous Packaging Act focused primarily on registration, licensing and waste disposal.
The PPWR goes significantly further. In future, the following topics, among others, will be a focus:
- Packaging recyclability
- Use of recyclates
- Packaging prevention
- Reuse
- Technical documentation
- Conformity requirements
Packaging is therefore increasingly viewed as a product in its own right that must meet specific European requirements. Companies should address their packaging portfolio at an early stage.
New requirements for international supply chains
There are also changes for companies that are not established in Germany.
Anyone who supplies packaging or packaged products directly to end users in Germany and has no establishment in Germany must in future appoint an authorised representative. That representative assumes responsibility for fulfilling the extended producer responsibility obligations in Germany. The producer must still personally register with the LUCID Packaging Register.
Act now rather than react later
Even if many obligations appear familiar at first glance, companies should not underestimate the transition.
The following questions are becoming particularly important:
- What role will my company have in future?
- Am I a manufacturer, a producer or both?
- What requirements will apply to my packaging in future?
- What evidence will need to be available in future?
- Where are there risks relating to recyclability and PPWR compliance?
The earlier companies answer these questions, the easier it will be to avoid later adjustments.
Understanding VerpackDG and the PPWR correctly
The PPWR and VerpackDG mark the beginning of a new phase of European packaging law. Mandatory registration and licensing remain in place. At the same time, topics such as recyclability, packaging design and technical evidence requirements are receiving greater attention.
Companies should use the time available to analyse their packaging structures and identify potential impacts at an early stage.
Learn More About PPWR and the Packaging Act
In our Knowledge Center, you’ll find background information, real-world examples, FAQs, and recommendations for action regarding the new packaging law.
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Ensure your packaging meets PPWR requirements
The recyclability of packaging plays a central role in the PPWR regulation. This requires recyclable packaging with an increasing proportion of recyclate from 2030. Companies should therefore optimise their packaging design now in order to meet legal requirements and strengthen the circular economy.
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