How Regulation (EU) 2025/40 (PPWR) applies in Germany: the national extended producer responsibility (EPR) scheme, small-producer thresholds, eco-modulation, and deposit return system status. PPWR is directly applicable in Germany from August 12, 2026.
Multiple PROs via LUCID registry (Landbell, Interzero/Interseroh, ALBA/Zentek, Grüner Punkt/DSD, Reclay). Competitive market, brands should request multiple quotes annually.
≤80,000 packaging units AND ≤200 kg/year. Both thresholds must be met for exemption.
The VerpackG design-incentive duty (fees favoring recyclable formats) carries into the new Verpackungsdurchführungsgesetz (VerpackDG), signed July 13, 2026, promulgated in BGBl I 2026 Nr. 207 on July 17, 2026 and in force August 12, 2026 under Art. 8(7) of the umbrella act [LOCKED, gazette record read at recht.bund.de and the consolidated text at gesetze-im-internet.de, September 1, 2026]. The duty itself is VerpackDG Sec. 26: systems must set participation fees so as to reward materials that recycle at the highest possible rate and the use of recyclate and renewable raw material, and must report each June 1 on how they did it. Sec. 26a leaves the binding detail to a Rechtsverordnung that has not been made, and bridges recyclability assessment to the German national standard until the PPWR Art. 6(4) delegated acts apply, so there is no German rate schedule to price against yet. PPWR recyclability and material-composition criteria are not yet folded into the national eco-modulation or completeness-audit obligation; harmonized grade-based modulation follows the PPWR Art. 6(4) design-for-recycling act (ACT-02) and the Art. 6(5) implementing acts, binding 18 months after the later of the two, so around mid-2031 [SIGNALED].
Declaration of Completeness (Vollständigkeitserklärung) required above certain tonnages. File with ZSVR (verpackungsregister.org).