What every small and medium-sized business placing packaged goods on the German market needs to know — and do — before August 2026
The Three-Layer Framework
Layer 1 — What is your packaging made of? (PPWR)
The PPWR requires every manufacturer, importer, or distributor placing packaging on the EU market to be able to confirm that their packaging complies with a set of material requirements. This is formalised in a Declaration of Conformity (DoC) — a document certifying that a specific packaging type meets the relevant sustainability requirements of Regulation (EU) 2025/40.
The DoC covers two distinct dimensions that are easy to conflate but need to be tracked separately:
Material composition — what the packaging is physically made of: plastic type (PET, HDPE, PP, etc.), paper grade, coatings, adhesives, inks, and any functional barriers. This determines whether your packaging meets the PPWR's substance restrictions and can achieve the required recyclability grade.
Key substance thresholds that apply from 12 August 2026:
- PFAS in food-contact packaging: no more than 25 ppb for any single PFAS, or 250 ppb combined
- Heavy metals (lead, cadmium, mercury, hexavalent chromium): combined maximum of 100 mg/kg
Recycled content — what share of the material, by weight, is post-consumer recycled. This is separate from composition and is often the data point SMEs find hardest to obtain from their packaging suppliers. It becomes legally mandated for plastic packaging from 2030, with targets that vary by packaging type — for example, approximately 30% for many standard plastic formats, rising to up to 65% for certain beverage bottles by 2040.
The practical challenge: Most SMEs do not manufacture their own packaging. They buy it from a supplier, often overseas. The obligation to hold a DoC means you need your packaging supplier to provide verifiable, documented data on both material composition and recycled content — per packaging type, per SKU. If your supplier cannot provide this, you either need to switch suppliers or, if you brand-own the packaging, issue the DoC yourself.
This data collection process takes time to build. Starting it now — well before the 2026 application date — is the single most important compliance step an SME can take.
Layer 2 — How much are you placing on the market, and what are you paying for it? (VerpackDG / LUCID)
Once you know what your packaging is made of (Layer 1), you have the foundation for the second obligation: reporting your packaging volumes by material type and paying the corresponding recycling fees. This is governed by national law — in Germany, the VerpackDG — and administered through the LUCID Packaging Register operated by the Central Agency Packaging Register (ZSVR).