After the European Commission had issued a detailed statement on the draft VerpackDG in May, it was now, surprisingly, withdrawn. The statement triggered a standstill period in the TRIS notification procedure; however, as it has been withdrawn, the extension is now void. The Commission had previously expressed concerns that certain provisions of the German draft law might deviate from the requirements of the EU Packaging and Packaging Waste Regulation (PPWR). This concern was mainly directed at definitions relating to ‘material recycling’, ‘distributors’ and ‘plastic packaging’. Furthermore, the Commission had identified potential conflicts regarding registration and reporting obligations under Extended Producer Responsibility.
However, the German government had clearly repelled Brussels’ objections, as parts of the criticism were based on translation issues and misunderstandings regarding the structure of German packaging law. From the German government’s perspective, the definitions in question were fully compatible with the European requirements. No fundamental conflicts with the future requirements of the PPWR were identified in relation to the producer register. The withdrawal of the detailed opinion now creates the conditions for the legislative process to continue.
It remains unchanged that the EU Packaging Regulation (PPWR) will apply directly in all Member States from 12 August 2026. Companies must therefore prepare for the new European requirements regardless of the progress of the national legislative process. With the interim extension of the standstill period until 17 August, it had already become apparent that the German Packaging Law Implementation Act (VerpackDG) could not come into force at the same time as the PPWR, as originally planned. The industry therefore feared substantial legal ambiguities and enforcement issues during a potential transitional phase. With the withdrawal of the detailed statement, this risk has now been reduced significantly. As the extended standstill period no longer applies, there is in principle a renewed possibility that the VerpackDG can be adopted in good time. Whether this timetable can actually be met, however, depends on the further course of the legislative process.
Companies should therefore continue to closely monitor regulatory developments and consistently press ahead with their preparations for the requirements of the PPWR that are immediately applicable. The PPWR Online Workshop by trade-e-bility supports you with concise and practical guidance right up to the PPWR deadline on 12 August 2026.
If you have any questions regarding the PPWR, please contact 040/750687-300 or sales@trade-e-bility.de – our trade-e-bility consulting team will be happy to make you a suitable offer.
