Textile EPR regime and Packaging Act
Textile EPR draft expected before year-end following policy proposal
On 27 March, the Federal Environment Ministry (BMUKN) released a policy framework paper (“Eckpunktepapier”) setting out the Ministry’s proposed approach for implementing an EPR-based textiles waste management regime in Germany and invited stakeholder comments by 24 April. The paper is not draft legislation and its provisions remain proposals.
The policy paper proposes a regime covering clothing, clothing accessories, household textiles and footwear, mirroring the product scope of Directive 2025/1892.
The framework defines a producer as any undertaking that first offers textiles on the German market (manufacturer, importer or distributor), while obligating foreign entities to appoint an Authorised Representative (AR) and requiring online marketplaces and fulfilment service providers to verify producer registration.
It also requires producers to register and participate in an authorised PRO and envisages multiple competing PROs, which would:
- require approval and meet requirements relating to nationwide coverage and financial capacity/financial guarantees
- be held responsible for nationwide collection and reimburse collectors for collection activities, with collecting parties able to choose the PRO in which they participate
- be required to achieve a 70% collection target (calculated against the weight placed on the market in the previous year), a 95% recovery target for collected waste textiles and an 85% target for preparation for reuse and recycling combined
Germany does not currently operate a statutory textile EPR-based waste management regime and collection is carried out through municipal, charitable and commercial collection systems without a dedicated producer-financed EPR framework.
The forthcoming draft Textiles Act is expected in summer 2026. Germany must transpose the textile EPR requirements of Directive (EU) 2025/1892 by 17 June 2027 and establish its textile EPR regime by 17 April 2028.
Packaging Act: New authorisation regime for non-household packaging
On 17 July, Germany published the Packaging Law Implementation Act (VerpackDG), which replaced the Packaging Act (VerpackG) with effect from 12 August, and adapts national packaging legislation to the EU’s PPWR.
The existing system for packaging typically arising from households (termed “packaging subject to system participation” or “systembeteiligungs-pflichtige Verpackungen”) and comparable sources largely continues.
However, the Act makes several significant changes:
Non-household packaging
From 1 January 2028, producers of packaging not subject to system participation – including many types of transport and commercial packaging – must either transfer their EPR obligations to an authorised other PRO (“sonstige Organisation für Herstellerverantwortung” or sOfH) or obtain ZSVR authorisation for individual compliance. sOfHs are also authorised by the ZSVR and are subject to collection, financial control and financial guarantee requirements.
PROs
Existing PROs managing “packaging subject to system participation” (i.e. household packaging) remain authorised by the competent state authorities, but must meet additional operational and financial requirements, including adequate sorting and recycling capacity and a financial guarantee. Higher recycling targets apply from 2028.
Industry solutions
The existing alternative allowing producers to organise takeback from specified commercial/institutional sources (termed “industry solutions” or “Branchenlösungen”) is retained but is now subject to ZSVR authorisation. Solutions may operate without authorisation only until 31 October 2027.
Packaging prevention
PROs, sOfHs, industry solutions and individual compliers must implement and annually document packaging waste prevention measures, including measures supporting reuse and refill.
Foreign producers
Companies without a German establishment that sell directly to German end users must appoint an Authorised Representative (AR).
LUCID
Existing registrations remain valid, but producers must update their registration details by 12 November 2026. Producers newly subject to registration must register by 12 September 2026.
