VerpackDG Requirements: Accurately Assign Roles and Deadlines for the PPWR

In the future, obligations under the Packaging Implementation Act (VerpackDG) can no longer be managed solely based on license volumes and material types. As of August 12, 2026, the EU Packaging Regulation (PPWR) and the Packaging Act Implementation Act (VerpackDG) will apply jointly. The key factor now is the role a company plays with regard to each individual piece of packaging and the documentation requirements that result from it.

For purchasing, packaging development, and compliance, this means that the roles of producer and manufacturer must be clarified on a product-by-product basis, technical documentation must be systematically obtained, and national reporting and approval requirements must be prepared in a timely manner. This article outlines roles, obligations, and deadlines, and explains the steps companies should take now.

As of September 2026. The legal basis consists of Regulation (EU) 2025/40 on packaging and packaging waste, as well as the Packaging Act (VerpackDG), which is Article 1 of the Act Adapting Packaging Law to Regulation (EU) 2025/40, published in the Federal Law Gazette 2026 I No. 207 on July 17, 2026.

What Has Changed as a Result of the Packaging Act

The VerpackDG replaces the previous Packaging Act and supplements the directly applicable PPWR with national responsibilities, procedures, and enforcement provisions. The Bundestag passed the law on June 11, 2026, and the Bundesrat approved it on July 10, 2026. The PPWR and the Packaging Act (VerpackDG) have been in effect together since August 12, 2026.

Established obligations such as registration, participation in the system, and data reporting remain in place. At the same time, the focus is expanding from waste disposal to packaging as a product: In the future, companies must also provide verifiable evidence that the design, use of materials, and compliance meet European requirements. Our article“The PPWR Regulation Explained”provides an overview of the requirements of the EU regulation.

• Two roles instead of a single responsible party: The PPWR distinguishes between the producer, who is responsible for ensuring the packaging’s compliance, and the manufacturer, who fulfills the extended producer responsibility in the respective member state.
• Compliance per package: Technical documentation and a PPWR Declaration of Conformity must be available for each individual package. An aggregated quantity report by material type is not sufficient for this purpose.
• Authorization for Certain Manufacturers: Manufacturers of packaging not subject to mandatory participation in the system must obtain authorization from the Central Packaging Register pursuant to Section 19 of the Packaging Act (VerpackDG).
• Authorized Representative in the Absence of a Branch Office: Manufacturers without a branch office in Germany must, pursuant to Section 5(2) of the Packaging Act (VerpackDG), designate an authorized representative before making their products available for the first time.

Packaging Act Obligations: What Are the Deadlines?

The obligations follow two time frames: The PPWR and VerpackDG have been in effect since August 12, 2026, while certain approval procedures will not become mandatory until later. The Central Agency for Packaging Registration plans to implement the necessary electronic procedures in late summer and fall 2027. Companies should therefore view the transition period not as a delay, but as a preparation phase.

The transition periods postpone the process, not the necessary data work. Anyone who doesn’t begin clarifying roles until fall 2027 will have to compile packaging data and supplier documentation under significant time pressure. This is why an early project start is crucial, especially for large product portfolios: The deadline is in 2027, but a robust data foundation should already be in place by 2026.

Producer or manufacturer: What role does your company play?

The PPWR distributes responsibility among several economic operators. Producers and manufacturers may be the same company, but they do not have to be. The producer is responsible for the design, characteristics, and conformity of the entire packaging. The manufacturer fulfills the extended producer responsibility in the respective Member State, in particular registration, participation in the system, and data reporting.

Therefore, the following is crucial for procurement: A role assigned by law cannot be transferred to the supplier solely through a contractual clause. Suppliers can provide data, technical documentation, and supporting evidence. However, whether your company is a producer or a manufacturer is determined by the statutory classification rules, such as those based on brand use or domestic priority. The role must therefore be verified for each individual package.

What the Purchasing Department Needs to Do Now

Implementation begins with a complete packaging inventory, not with the application for authorization. Only at the product level can one reliably determine who is responsible for what, what information is missing, and what supporting documentation must be maintained. The following five steps lay the foundation for registration, data reporting, and authorization.

• Create a packaging inventory: For each product, record all packaging components, including material, mass, function, and packaging level. This data also serves as the basis for reports required under Section 9 of the Packaging Act (VerpackDG).
• Determine the roles for each package: Assign the roles of producer, manufacturer, importer, and, if applicable, an authorized representative to each package. In addition to the result, document the criteria and sources used to reach the decision.
• Verify Authorized Representative: Companies without a branch office in Germany generally require an authorized representative for extended producer responsibility. According to Section 5 of the Packaging Act (VerpackDG), only one authorized representative may be designated per manufacturer.
• Standardize supplier requirements: Incorporate technical documentation, declarations of conformity, and relevant material data into specifications, requests for proposals, and contracts. This ensures that supporting documentation is generated during the procurement process itself, rather than only upon request.
• Schedule registration and approval: Review the existing information in the Packaging Registry and plan for the necessary approvals under Section 19 of the Packaging Act (VerpackDG) well in advance of December 31, 2027.

The greatest effort lies not in the application itself, but in the packaging master data. If the material, mass, packaging function, role, and verification status are maintained in a structured manner, data reports, declarations of conformity, and approval documents can be derived from the same data source. A robust packaging master data set thus becomes the central proof of compliance.

What Remains Unclear Regarding the Interpretation

Not every practical scenario can currently be clearly deduced from the law and official guidance. Cases in which a trademark owner, contract manufacturer, importer, and distributor are all involved with the same packaging are particularly relevant. Until a settled interpretation is established, companies should transparently document their decision-making criteria and assumptions.

• The roles of producer and manufacturer in contract manufacturing: These roles are legally defined; however, their specific allocation depends on design specifications, brand identity, and market positioning.
• Distinction Regarding Transport Packaging: In each individual case, it must be determined which packaging is subject to participation in a recycling system and for which only other registration, take-back, or data reporting requirements apply.
• Details of the Registration Process: The electronic procedures are expected to be available in 2027. The specific documents that must be submitted and the applicable fees have not yet been finalized.

Until these questions are definitively resolved, transparent documentation is more important than rushing to a conclusion. A well-maintained legal register can bring together the classification, the sources used, unconfirmed assumptions, and subsequent changes in an audit-proof manner. In an audit, it’s not just the result that counts, but also the robust process leading up to it.

Frequently Asked Questions About VerpackDG and PPWR

The following answers summarize the most important practical questions for purchasing, packaging development, and compliance, based on the status as of September 2026.

Provide a structured demonstration of PPWR compliance using CONSUST

The clarification of roles and responsibilities for each package can be mapped as an end-to-end process. CONSUST’s PPWR software guides users from package registration through role assignment to the declaration of conformity. A rule-based decision tree supports the assignment process, while the Compliance Cockpit provides transparency regarding open data, supporting documentation, and actions required.

CONSUST’s PPWR software includes built-in templates for technical documentation and declarations of conformity, and missing supplier information can be obtained via structured questionnaires and directly assigned to the respective packaging. Our“PPWR Guide: Implementing Compliance in 7 Steps”outlines the process from initial assessment to market approval. We’d be happy to demonstrate how your packaging structure and responsibilities can be systematically mapped out.

This article presents a professional assessment based on the cited sources as of the date indicated and is not a substitute for a legal review in individual cases.