In a joint letter, several German industry associations appeal for a postponement of the date of application of the new EU packaging regulation (PPWR). The current deadline of August 12, 2026 is leading to considerable implementation problems.  

In the letter, the signatory associations – including well-known representatives from the packaging industry, retail and the waste management sector – warn of “serious practical problems” if the new EU regulation comes into force on August 12, 2026 as planned. Instead, they argue for a postponement to January 1, 2027 in order to create time for legally secure national implementations and transitional regulations.

Legal uncertainty and planning problems feared

Specifically, the senders criticize the fact that the start date is in the middle of the financial year, resulting in two different legal regimes within one calendar year. New definitions such as “manufacturer” or “producer” would call into question the previous distribution of roles in extended producer responsibility (EPR) – with potentially far-reaching effects on licensing obligations, financing structures and responsibilities.

It is also unclear until the end of 2026 how the new EU law will be implemented nationally. The corresponding German implementation law will not be available until mid-2026 at the earliest, and key questions of interpretation at EU level remain unanswered. As a result, dual systems, manufacturers and municipalities will not be able to conclude contracts, plan volumes or calculate services.

Risk to municipal services and system stability

The authors are particularly concerned about the stability of the system. The parallel implementation of old and new regulations leads to duplicate contracts, increased bureaucracy and financial risks. Without clear responsibilities, the financing of municipal tasks such as waste advice or container cleaning is at risk. In the worst case scenario, the entire EPR system could be destabilized.

Associations demand postponement until January 1, 2027

The associations therefore believe that a Europe-wide coordinated postponement to January 1, 2027 is the only practicable way forward. This is the only way to achieve the goal of an orderly, legally compliant and economically viable implementation. A postponement would also meet the EU-wide requirement to reduce bureaucracy and ensure planning security.

Germany could play an active role here, it continues – also because comparable challenges exist in other EU member states.

Demand with a signal effect

With this letter, the signatory associations are sending a clear signal to the Federal Environment Ministry and the EU Commission. In view of the tight deadlines and unresolved implementation issues, decisive political action is called for. It remains to be seen whether and to what extent the German government will respond to the demand.