VerpackDG
The obligation comes from Europe. The cost sits in German law.
The PPWR tells you that you will need reuse. The Verpackungsrecht-Durchführungsgesetz decides what single-use costs you in Germany in the meantime — and contains a provision that can remove that cost entirely. This page is the operator’s read of it, not legal advice.
VerpackDG
Two laws, two clocks
They answer different questions and they are easy to confuse in a meeting. Getting the dates the wrong way round is the fastest way to lose a room.
- Must I move to reuse?PPWR Art. 29 · Targets from 1 January 2030
- If I make reusable packaging available for the first time, must a reuse system exist for it?PPWR Art. 26 · Applies now
- What does single-use cost me?VerpackDG §§ 7–10 · Running, per tonne reported
- How does that cost go away?VerpackDG § 11 Nr. 1 · Available now
- What if I do nothing?VerpackDG § 66 · German duties now; PPWR breaches from 12 Feb 2027
The Verpackungsrecht-Durchführungsgesetz (VerpackDG) is Art. 1 of the Gesetz zur Anpassung des Verpackungsrechts und anderer Rechtsbereiche an die Verordnung (EU) 2025/40 vom 13. Juli 2026, BGBl. 2026 I Nr. 207. It has applied since 12 August 2026 and repealed the VerpackG with effect from 11 August 2026.
What counts as system-participation packaging now
Two definitions decide whether the fee reaches you at all. Both are worth reading before anyone quotes you a saving.
§ 3 Abs. 6
Transport packaging is in scope
Systembeteiligungspflichtige Verpackungen now expressly include Transportverpackungen that, measured across the whole market for packaging of the same type, typically arise as waste mostly in private households or at comparable collection points.
§ 3 Abs. 7
Canteens and hospitals are comparable collection points
The test in Satz 1 is whether, by the kind of packaging waste that typically arises there, the site is comparable to a private household. Satz 2 then names — expressly “insbesondere”, so the list is open — the Gastgewerbe within the meaning of Art. 3(1)(35) PPWR, wie Gaststätten, Restaurants, Kantinen, Imbisse, Cafés, Hotels and Ferienanlagen, plus Raststätten, Verwaltungen, Kasernen, Krankenhäuser, Bildungseinrichtungen, karitative Einrichtungen, the premises of Freiberufler and typical sites in culture and leisure. Satz 3 adds farms and craft businesses, but only where the waste can be collected in household-type containers, capped at one 1,100-litre bin per collection group.
§ 11 Nr. 1 — one route out of the fee
Read it closely, because the trigger is not the one people assume. It is not “you collect your own crates”. Three things have to be true at once:
- The packaging is reusable — and this is the hard part, not a formality. Art. 11(1) PPWR sets nine cumulative requirements, one of which imports the recyclability requirements of Art. 6. A minimum number of rotations follows in a delegated act due by 12 February 2027 (Art. 11(2)).
- There is actual take-back and actual reuse — not an intention to reuse, and not a container that could in principle be reused.
- Both are enabled by an existing reuse system. The producer does not have to run it. But a loop being stood up for the first time does not obviously qualify.
Where it applies, §§ 7 to 10 fall away: system participation, the data reports and the Vollständigkeitserklärung. That is a line item, not a compliance talking point.
What § 11 does not do
It does not exempt you from the packaging law
Only §§ 7–10 are disapplied. Registration under § 6 remains, and so does take-back and recovery under § 39 — which expressly lists both transport packaging that is not system-participation packaging and reusable packaging under Art. 11 PPWR. Every obligation under the PPWR itself remains. The § 59 prevention duties bind systems, sonstige Organisationen, Branchenlösung operators and producers meeting their EPR individually, so whether they reach you depends on the route you take.
It stands or falls on the facts
§ 11 needs no application and grants no approval — it simply does not apply where its conditions are not met. So if take-back and reuse are not actually happening, §§ 7 to 10 were never disapplied for that period, whatever was assumed at the time. Breaching the system-participation duty is an Ordnungswidrigkeit of up to € 200,000 (§ 66 Abs. 1 Nr. 3 in conjunction with Abs. 3), and that is enforceable today — § 68 Abs. 17 defers only § 66 Abs. 2, the fines for PPWR breaches. This is why the measurement matters more than the lorries.
It does not tell you what you would save
That depends on your reported tonnage and the rates in your own licence agreement. We do not publish a figure here because we do not have one with a source behind it. Bring the tonnage and we will do the arithmetic with you.
The dates that actually move a decision
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12 Aug 2026
The VerpackDG applies
The VerpackG is repealed with effect from 11 August 2026 (Art. 7).
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12 Sept 2026
Newly obliged producers register
§ 68 Abs. 2. Producers already registered under the VerpackG stay registered, but changes have to be made by 12 November 2026.
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31 Dec 2026
Existing system participations end
§ 68 Abs. 1: they continue “längstens jedoch bis zum Ablauf des 31. Dezember 2026”, vorbehaltlich abweichender privatrechtlicher Vereinbarungen — a private agreement may provide otherwise, in either direction. Contracts for 2027 are negotiated before this date — which is why this is a 2026 conversation, not a 2027 one.
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12 Feb 2027
Fines for PPWR breaches begin to apply
§ 68 Abs. 17 defers § 66 Abs. 2 only. Fines for German duties under § 66 Abs. 1 — registration, system participation, data reports, take-back — apply now. There is no general grace period.
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1 Jan 2030
The PPWR reuse targets bite
Art. 29(1): at least 40% of specified transport packaging reusable within a reuse system. Art. 29(2) and (3) go further for movements between an operator’s own sites — and those of linked or partner enterprises — and for deliveries to another economic operator in the same Member State. Read Art. 29(4) before assuming any of it reaches you: paragraphs 1 to 3 do not apply to packaging for dangerous goods, to packaging custom-designed for large-scale machinery, equipment and commodities, to flexible formats in direct contact with food and feed, or to cardboard boxes.
Bring the tonnage.
The first useful conversation is not about the regulation. It is about what you currently report, what you pay to license it, and whether an existing reuse system could carry it. Thirty minutes, free, and it commits you to nothing.