May 7, 2026
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Federal Council calls for low‑bureaucracy implementation of EU Packaging Regulation
At the end of March, Germany’s Federal Council (Bundesrat) adopted its opinion on the draft legislation adapting German packaging law to the EU Packaging and Packaging Waste Regulation (PPWR). The upper house broadly supports an implementation that is as low in bureaucracy as possible and closely aligned with the European requirements. National rules should not go beyond the provisions of the PPWR and should avoid placing additional burdens on small and medium‑sized enterprises in particular.
At the same time, the Bundesrat stresses that existing structures within German packaging law should largely be retained wherever this is permissible under EU law. Additional national provisions, such as new approval requirements for certain types of packaging or extended reporting obligations for producers and compliance schemes, should be reviewed and simplified where appropriate. In particular, the Bundesrat criticises proposed reporting obligations on waste prevention: under the draft legislation, around 60,000 stakeholders would be required to document related measures and submit them to authorities upon request, which the Länder regard as involving a considerable administrative burden. As an alternative, the Bundesrat suggests an approach based on the Austrian model, whereby a portion of the fees collected is channelled into waste‑prevention projects. It also calls for a critical review of specific financing and organisational arrangements – for example those linked to the Central Packaging Register – in light of their bureaucratic impact.
In terms of substance, the Bundesrat places a strong emphasis on the environmental design of the system. It calls for strengthening the incentive effect of participation fees and for introducing minimum requirements for their differentiation based on recyclability and recycled content. The aim is to create stronger incentives for recyclable‑friendly packaging design and the use of secondary raw materials. In addition, the Länder advocate further economic incentives to support the circular economy, including measures to boost demand for recyclates, such as through public procurement or the introduction of additional EU‑wide minimum recycled content targets.
On the issue of reusable packaging, the Bundesrat makes clear that related measures should not be pursued as an end in themselves. Instead, greater attention should be paid to the overall environmental impact of packaging across its entire life cycle.
Against this background, the Federal Government is urged to assess whether specific national requirements – including additional approval or reporting obligations – are genuinely required under EU law or could be simplified.
