Search
Contact
16.11.2018 | KPMG Law Insights

The new packaging law will soon apply

The new packaging law will soon apply

On January 1, 2019, the Packaging Ordinance will be replaced by the Packaging Act.

This results in significant changes in the area of registration and notification requirements. For example, the Packaging Act includes the obligation to register with the “Stiftung Zentrale Stelle Verpackungsregister”. This must be done by the end of the year, otherwise the companies concerned will no longer be allowed to place packaged goods on the market from January 1, 2019.

The Packaging Act affects all manufacturers and distributors who place sales packaging and outer packaging filled with goods, which typically accumulates as waste after use by private end consumers, on the market for the first time on a commercial basis or import it into Germany on a commercial basis. Such manufacturers or distributors must participate in one or more disposal systems with the aforementioned packaging (so-called system participation obligation).

In addition, the companies concerned must immediately report the type of material and the mass of packaging that they place on the market and that is subject to the system participation obligation.

Furthermore, the companies concerned must submit an annual declaration of completeness on the packaging placed on the market in the previous calendar year. Such letters of representation must be reviewed and certified by an auditor licensed to do so. Such an inspector may be a registered expert, an inspector appointed in accordance with. § 27 para. 2 Packaging Act to be a registered auditor, tax advisor or certified public accountant.

A manufacturer who has not registered his packaging may not place it on the market until the registration has been made up. If the manufacturers of packaging are not registered or not properly registered, their distributors are also not allowed to offer the goods in question for sale.

With little time left before the January 1, 2019 deadline, action is now required for all non-registered companies that commercially place disposable packaging on the market or import it into Germany.

Our specialists at KPMG Law Rechtsanwalts- und KPMG Wirtschaftsprüfungs-gesellschaft will support you not only in reviewing and confirming your annual declaration of completeness, but also in all legal issues relating to the Packaging Act.

Constantine from Busekist

Thomas Uhlig

Explore #more

13.08.2026 | KPMG Law Insights

Federal Ministry of Finance Presents Draft Bill on Mandatory Use of Electronic Cash Registers and Combating Tax Evasion

In July 2026, the Federal Ministry of Finance (BMF) and the Federal Ministry of Justice (BMJV) presented an action plan to combat tax and financial

11.08.2026 | In the media

Guest article in *Versicherungsmonitor* on the topic of cyber claims regulation

Cyberattacks—particularly ransomware campaigns—pose challenges for insurers when it comes to claims settlement. When entire IT infrastructures at insured companies come to a standstill and the…

11.08.2026 | KPMG Law Insights

Transparency Requirements Under Article 50 of the AI Act: Companies Should Address These Questions Now

The transparency requirements of the EU AI Act have been in effect since August 2, 2026. These obligations apply to chatbots, AI assistants, avatars, synthetic…

10.08.2026 | In the media

Op-Ed on the Procurement Acceleration Act and Sustainable Public Procurement

On April 23, 2026, the Bundestag passed the Act on Accelerating the Award of Public Contracts. After the Act was published in the Federal Law…

05.08.2026 | Deal Notifications

KPMG Law and KPMG Advise NMP Germany on the Acquisition of Klöckner Desma Elastomertechnik GmbH

KPMG Law Rechtsanwaltsgesellschaft mbH (KPMG Law) and KPMG AG Wirtschaftsprüfungsgesellschaft (KPMG) advised NMP Germany GmbH on the legal, tax, and financial aspects of the transaction…

04.08.2026 | In the media

Portrait of Mathias Oberndörfer in the *Börsen-Zeitung*

Mathias Oberndörfer has been with KPMG for more than 20 years—reason enough for an in-depth profile in the *Börsen-Zeitung*. The Börsen-Zeitung traces his career path…

03.08.2026 | Unkategorisiert

KPMG Law und KPMG beraten NMP Germany beim Erwerb der Klöckner Desma Elastomertechnik GmbH

Die KPMG Law Rechtsanwaltsgesellschaft mbH (KPMG Law) und die KPMG AG Wirtschaftsprüfungsgesellschaft (KPMG) haben die NMP Germany GmbH beim Erwerb der Klöckner Desma Elastomertechnik Gruppe…

03.08.2026 | In the media

Statement by KPMG Law experts on the EU Packaging Regulation in the business magazine *impulse*

Starting January 1, 2030, packaging must consist of at least 70 percent recyclable materials. Starting August 1, 2030, so-called “deceptive packaging” will also be banned.…

30.07.2026 | KPMG Law Insights

CRD VI and Third-Country Banks: Preserving Cross-Border Access to the EU Market

From 11 January 2027, third-country banks will need to reassess whether they may continue to provide banking services into the EU on a cross-border basis.…

28.07.2026 | In the media

Op-ed in the FAZ on the topic “Who is liable when algorithms make decisions?”

Artificial intelligence has made its way into the boardroom. Whether it’s investment decisions, risk analysis, or workforce planning—the results of artificial intelligence are increasingly being…

Contact

Dr. Konstantin von Busekist

Partner
Head of Global Compliance Practice
KPMG Law EMA Leader

Tersteegenstraße 19-23
40474 Düsseldorf

Tel.: +49 211 4155597123
kvonbusekist@kpmg-law.com

Dr. Thomas Uhlig

Partner
Head of General Business and Commercial Law

Galeriestraße 2
01067 Dresden

Tel.: +49 351 21294460
tuhlig@kpmg-law.com

© 2026 KPMG Law Rechtsanwaltsgesellschaft mbH, associated with KPMG AG Wirtschaftsprüfungsgesellschaft, a public limited company under German law and a member of the global KPMG organisation of independent member firms affiliated with KPMG International Limited, a Private English Company Limited by Guarantee. All rights reserved. For more details on the structure of KPMG’s global organisation, please visit https://home.kpmg/governance.

KPMG International does not provide services to clients. No member firm is authorised to bind or contract KPMG International or any other member firm to any third party, just as KPMG International is not authorised to bind or contract any other member firm.

Scroll