Germany's new packaging law (VerpackDG): what it means for stretch film and straps on export pallets

On 12 August 2026, Germany's Packaging Act stopped applying.

A new law took its place on the same day that the EU Packaging and Packaging Waste Regulation (PPWR) began to apply. Its name is long, so everyone uses the short form: VerpackDG.

For anyone who sends pallets to Germany, the lines that matter are about transport packaging. That is the stretch film, the straps and the pallets that never reach a shop shelf.

Checked against official sources on 28 October 2026.

My short answer: pallet wrap and straps that end up in German factories and warehouses are, in most cases, transport packaging outside the household "system" scheme. Whoever first supplies them in Germany must register, take them back free of charge, get them reused or recycled and keep a yearly record. The new part is an approval. From 1 January 2028, that company needs approval from the German packaging register, the ZSVR, or must hand its duties to an approved take-back organisation. For most Indian exporters, the obligated company is the German importer.

If you sell directly to an end user in Germany, it can be you.

I am a packaging maker in Jaipur, not a German lawyer. We export to more than 20 countries, so I read laws like this one with our own pallets in mind. The section numbers here come from the law as passed by the Bundestag on 11 June 2026, printed as Bundesrat paper 377/26. The Bundestag's own report records the vote.

What is VerpackDG?

It applies to packaging within the scope of the PPWR (§ 1). Where the EU Regulation leaves room, it adds German detail: registration, the household collection systems, take-back, fees and fines. Most of it came into force on 12 August 2026, under its final article. Trade sources report that the Bundesrat approved it on 10 July 2026 and that it was published in the Federal Law Gazette on 17 July 2026.

It also raises the plastic recycling quota for the household systems. The figure is 75% from 1 January 2028 and 80% from 1 January 2030 (§ 42(2)).

Those quotas bind the systems, not you.

They do show where Berlin is heading.

Is pallet wrap "system" packaging?

Germany splits packaging into two worlds.

The first world is packaging that must join a household "dual system". § 3(6) defines it. It includes transport packaging only where that packaging mostly ends up as waste in private homes "oder bei vergleichbaren Anfallstellen", or in comparable places.

§ 3(7) lists those places. They include hotels, restaurants, canteens, offices, hospitals, schools, barracks, cinemas and stadiums. Farms and craft workshops also count, if they manage with household-size bins of up to 1,100 litres per material group.

Stretch film on a pallet delivered to a factory or a warehouse does not end up in any of those places.

So in most cases it sits in the second world, and § 39 applies.

Where your pallets end up decides this, not the film. If your goods go to small craft workshops that put the wrap in household bins, ask your German buyer how it has classified the packaging.

The duties for transport packaging

These duties fall on the producer, as the PPWR defines it. They also fall on every distributor after it in the supply chain.

There are six of them.

1. Register with the ZSVR before first supplying packaging in Germany. The registration covers the packaging under § 39 too (§ 6(1) and (2)).
2. Take back used, empty transport packaging of the same type, shape and size, free of charge. This happens at the place of handover or close to it, and the packaging is kept apart from other waste (§ 39(1)). Businesses may agree a different place and cost split among themselves.
3. Send what comes back preferably to reuse or recycling (§ 39(3) with § 42(5)).
4. Keep a yearly record, by 15 May, of the packaging supplied and taken back in the previous calendar year. It is broken down by material and weight, and the State authority can ask to see it (§ 39(3)).
5. Keep enough money and staff to do all this, with your own checks (§ 39(4)).
6. Pay a share of the ZSVR's costs under a funding agreement (§ 51(1)). This does not apply if all your packaging is handed to an approved take-back organisation.

The law calls such an organisation a "sonstige Organisation für Herstellerverantwortung". It is a producer responsibility organisation for packaging outside the household systems (§ 39(6)). You may hand it your take-back and recycling duties. You must then tell the ZSVR.

The 2027 deadline: approval by 31 December 2027

This is the part I would put in the diary first.

It is also the easiest one to miss.

§ 19 says producers of packaging outside the system scheme must be approved by the ZSVR before they first supply it. This is how Germany applies Article 47 of the PPWR, which asks for approval of producers that meet their duties on their own. The conditions in § 19(2) are these.

1. The producer meets the § 39 take-back and recycling duties.
2. It has the money and staff to do so.
3. It runs its own checks on its finances.
4. It lodges an insolvency-proof security with the ZSVR.
5. It makes sure the packaging is sorted and recycled to a high standard after use.
6. It signs a funding agreement with the ZSVR and pays the charge.

The ZSVR must decide within four weeks of a complete application. If it does not, the approval counts as granted (§ 19(2) and (6)). Four weeks is quick. A producer that hands all its packaging to an approved take-back organisation needs no approval of its own (§ 19(1)).

The transition is in § 68. Producers may keep supplying such packaging without approval until 31 December 2027 (§ 68(9)). The take-back organisations may work without their own approval until 31 October 2027 (§ 68(12)).

After that, § 13(2) bars a producer from supplying this packaging without one route or the other. § 13(3) also bars distributors from passing on packaging from a producer that has neither.

So if your German buyer relies on a take-back organisation, it should check one thing by 31 October 2027. Is the organisation itself approved?

Who is the producer of the wrap on your export pallet?

VerpackDG uses the PPWR definition of producer, in Article 3(1)(15) of Regulation (EU) 2025/40. For transport packaging, three cases cover most exporters.

1. A company based in Germany that first makes the transport packaging available there (point (a)). For imported goods, this is usually your German importer or distributor.
2. A company based in Germany that unpacks packaged goods without being the end user (point (e)). The Commission's guidance notice C/2026/3084 says logistics companies that unpack or repack imported goods are not end users. They are the producer of the transport packaging.
3. A company based outside the EU that makes transport packaging available for the first time in Germany, directly to end users (point (c)). If you sell from India straight to a German factory that uses your goods, this can be you.

I would check this lane by lane, not company by company. The same exporter can be the producer on one lane and have no German duty on another.

In the third case, you need a representative in Germany. The law calls it an authorised representative for extended producer responsibility. You appoint it by a written mandate, in German, before your first delivery (§ 5(2) and (4), with PPWR Article 45(3)). You register with the ZSVR yourself and name the representative. The representative then carries out your other duties in its own name (§ 5(3) and (5)).

An EU proposal to relax the representative duty is under negotiation. The positions reported so far do not relieve companies outside the EU. Nothing has changed in law.

Keep one more role apart. Under the PPWR, the "manufacturer" draws up the EU declaration of conformity for the packaging itself. The Commission's FAQ (August 2026) treats the maker of unbranded stretch film as its manufacturer. That is not the German producer. A declaration from your film supplier helps your buyer, but it does not replace the buyer's registration.

What about fees and eco-modulation?

§ 26a asks for ordinances on how the household systems must set their fees, so that recyclable packaging and recycled plastic pay less. Trade sources report that the government aims to start this in 2027. I have not found an ordinance issued as of 28 October 2026.

For B2B pallet wrap outside the systems, the costs come from elsewhere. These are the ones I would ask a German buyer about. There is the ZSVR charge under § 51, the cost of take-back and recycling, and the fee of any take-back organisation your buyer joins. I have not seen published figures for these. I will not guess them.

What to do before 31 December 2027

1. For each German customer, write down who the producer of your transport packaging is: the importer, a logistics company that unpacks, or you. I would start here, because every other step depends on the answer.
2. If it is you, appoint a representative in writing, in German, and register with the ZSVR before your next delivery. Do not wait for 2027.
3. Give every German buyer a packaging sheet with each shipment. Show film weight per pallet, strap material and weight, pallet type and corner boards. Their 15 May record is by material and weight, and they need your numbers for it.
4. Agree in the contract who takes back the film and straps, and who pays. § 39(1) allows that between businesses. Shipping used film back to India makes little sense, so a local route in Germany is the practical answer.
5. Ask your buyer whether it will seek its own § 19 approval or join a take-back organisation. If it joins one, ask whether that organisation will be approved by 31 October 2027.
6. Cut the weight. Every kilo of film you do not use is a kilo nobody has to take back, record or pay for. Our guides to film per pallet and pre-stretch and to PP, PET and steel strapping help with that.

For the wider EU rules on reusing wrap and straps from 2030, see our guide to the EU reuse targets.

Has a German buyer asked you for a packaging data sheet? If you are not sure what to put in it, write to us through our contact page. We will help you with the weights and materials.

This article is general information, not legal advice. VerpackDG is new and the ZSVR is still issuing guidance on it, so please confirm your position with your German importer and a German adviser on packaging law.