EU packaging rules (PPWR) apply since 12 August 2026 · day 91Check if it applies to you →
PPWR · since 12 Aug 2026 · Check if it applies to you →
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Do recyclable packaging and recycled content lower my dual-system fees?

They should. § 26 VerpackDG requires dual systems to set fees that reward recyclable materials, recycled content and renewable raw materials.

Since 12 August 2026, § 5 VerpackDG, implementing Article 45(3) of Regulation (EU) 2025/40, requires a producer with no establishment in Germany to appoint an authorised representative before it first makes packaging available in Germany. Read § 5

By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below

Quick answer

They should. § 26(1) VerpackDG: dual systems must create incentives, through how they set participation fees, for packaging made of materials and material combinations that can be recycled to the highest possible share given actual sorting and recycling practice, and for the use of recycled material and renewable raw materials. § 26(2): each system reports by 1 June to ZSVR and the Federal Environment Agency how it did this. § 26(3): until EU rules under Article 6(4) PPWR apply, ZSVR publishes a minimum standard for assessing recyclability each year by 1 September. See how to lower your licence fees. VerpackDG § 26

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