In Berlin, the Federal Cabinet approved the draft Packaging Law Implementation Act (VerpackDG), which is intended to implement the PPWR at the national level. In Brussels, a draft Commission guidance document on the PPWR was leaked, and the delegated act regarding Articles 29.2 and 29.3 (reusability for strapping bands and stretch film) was adopted. In addition, the EU-wide consultation on the evaluation of the Single-Use Plastics Directive (SUPD) was launched, and member states voted in favor of the mass balance approach.
Germany: Cabinet Approves Packaging Implementation Act
On February 11, 2026, the Federal Cabinet adopted the draft Packaging Law Implementation Act (VerpackDG). This is intended to implement the EU Packaging Regulation (PPWR) at the national level and completely replace the previous Packaging Act. The Federal Ministry for the Environment, Climate Action, Nature Conservation, and Nuclear Safety provided information in a press release.
Following the Cabinet’s decision, notification under EU law will take place. Subsequently, the Bundestag must pass the law, and the Bundesrat will be consulted.
PPWR – Draft of the EU Guidance Document on the PPWR Leaked
In mid-January, a draft of an EU Commission guidance document on the interpretation of the PPWR was leaked. Interestingly, the document supports a very straightforward interpretation of the PPWR. More on this in our next newsletter.
PPWR – Delegated Act on Reuse Targets (Articles 29.2 and 29.3)
On February 25, 2026, the Commission adopted the Delegated Act removing strapping bands and load-securing films from the 100% target set out in Articles 29(2) and 29(3) (Link).
Strapping bands and load-securing films are also exempted from the remaining 40 percent quota for domestic transport and transport by affiliated companies.
Regardless of this specific exemption, the general target of the PPWR—that a total of 40 percent of transport packaging must be reused by 2030 (Article 29(1))—remains in effect.
SUPD – Commission Launches EU-Wide Consultation
The European Commission conducted a public consultation to evaluate the Single-Use Plastics Directive (SUPD).
- The survey was open until March 17, 2026.
- The evaluation is scheduled to be completed by July 2027.
Why this is important
The results of the consultation could lead to further tightening of regulations in the medium term (scope, requirements for reuse/alternatives, producer obligations). Further developments therefore remain relevant for stakeholders along the packaging value chain.
SUPD – Member States Vote for Mass Balancing Approach
On February 6, 2026, a majority of member states voted in favor of the “fuel-use exempt” mass balance approach under the Single-Use Plastics Directive (SUPD).
- The draft decision clarifies the mass balance requirements and the inclusion of chemical recycling and establishes rules for mass balance without a fuel exemption to achieve the 25 percent target for PET bottles. To date, there have been no reports of significant changes from the leaked draft circulated in early January.
- The final text has not yet been published. Minor changes are expected to affect how imported recycled materials can be counted toward recycling targets.
- The provisions in the leaked draft stipulated that recycled PET (rPET) produced outside the EU market could only be counted toward the 25% recycling rate for PET beverage bottles after November 21, 2027, when imports from OECD countries will be permitted.
- According to sources, the text now adopted clarifies that, until that date, all steps in the recycling chain must take place within the EU.
The European Commission will adopt the implementing measures without significant delay, and the implementing act will enter into force 20 days after its publication in the Official Journal of the EU.
