Germany enacts landmark packaging reform, tightens recycling quotas and EPR rules

GERMANY – Germany has formally transposed the EU’s Packaging and Packaging Waste Regulation (PPWR) into national law, unveiling sweeping reforms that raise recycling quotas, tighten extended producer responsibility (EPR) obligations and overhaul licensing structures.

The new Packaging Law Implementation Act (VerpackDG) will replace the existing Packaging Act (VerpackG), which has governed the market since January 2019.

The reform is designed to align Germany’s packaging framework with EU-wide circular economy targets and accelerate progress toward higher-quality material recovery.

Under the updated law, recycling targets will rise significantly from 2028. Aluminium and ferrous metals must each achieve a 95% recycling rate.

Plastics will face a 75% recycling quota, with at least 70% of that total required to be achieved through mechanical recycling, a provision aimed at limiting incineration and promoting closed-loop material use.

Industry stakeholders say the mechanical recycling sub-target could reshape investment flows, driving additional capacity in sorting, washing and reprocessing infrastructure.

In parallel, dual systems and EPR organizations will be required to allocate a minimum share of their budgets to waste prevention initiatives.

These may include seed funding for reusable packaging schemes, refill infrastructure and consumer awareness campaigns.

Expanded licensing and funding reforms

Mandatory licensing requirements will be broadened to include all organizations assuming EPR obligations for multiple manufacturers. Independent producers must continue to apply for individual licenses.

To streamline compliance, an automated licensing process will be introduced under the oversight of the Central Agency Packaging Register (ZSVR).

In a significant shift, manufacturers and licensing applicants, rather than dual systems alone, will now co-fund the ZSVR’s operations.

The reform reflects growing legal and market pressure to strengthen climate-aligned packaging policy.

In 2024, the International Court of Justice ruled that countries failing to adequately address greenhouse gas emissions and fossil fuel dependency could face legal consequences under international law.

Meanwhile, analyst firm Gartner predicts that by 2028, 75% of organizations will replace voluntary packaging commitments with compliance-driven legislative targets.

For packaging producers and brand owners operating in Germany, Europe’s largest economy, the new VerpackDG signals a decisive shift from ambition to enforcement, with measurable recycling thresholds and stricter financial accountability set to redefine market expectations.

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