02 December 2025 – The circular economy in Germany is currently experiencing a level of momentum the industry has not seen in years. Stricter legal requirements, ambitious recycling targets and rising expectations from policymakers, retailers and consumers are driving the need to rethink packaging – from material selection and design to proper participation in the Dual System.
Looking ahead, one thing is clear: Only packaging that is recyclable and correctly participates in the Dual System will be able to compete in the market. The new EU requirements under the Packaging and Packaging Waste Regulation (PPWR), as well as the new minimum standard issued by the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister - ZSVR), significantly increase the pressure on companies to act. At the same time, this transformation creates major opportunities: Sustainable packaging solutions are becoming an increasingly important competitive advantage and strengthen resource efficiency.
Current developments in the German market underline this relevance: Overall packaging volumes have recently declined slightly, while recycling rates continue to rise. Germany is sending a clear signal toward resource conservation. However, one prerequisite remains unchanged: clean system participation and transparent recording and reporting of packaging volumes.
To be well prepared both legally and organisationally for the coming years, companies should review and refine their processes now. Three key areas are particularly important:
Registration and System Participation
The first essential step is ensuring that all packaging placed on the market is registered correctly in the LUCID Packaging Register. Companies must verify whether all packaging typically ending up as waste with private end consumers has been captured and assigned to a Dual System. Equally important is reviewing system participation contracts: Are all relevant packaging volumes included? Are all required documents complete? Do internal processes align with the ZSVR requirements? Incorrect or incomplete registrations can lead to warnings, sanctions and reduced market transparency. Regular data updates, clear internal responsibilities and continuous documentation are therefore essential to ensure long-term legal compliance.
Forecast Reporting and Volume Management
Accurate determination and reporting of annual packaging volumes form the basis of any system participation. Companies should plan their expected volumes realistically, based on current sales forecasts, product developments and seasonal variations. A structured volume management system helps ensure timely submission of forecast volumes, early identification of deviations and correct submission of additional reports when needed. Clean volume recording ensures transparency and simplifies internal cost planning. Companies that optimise their processes in this area reduce sources of error, minimise administrative effort and avoid potential financial or legal consequences.
Important Note: Your forecast volume report for the 2026 licensing year must be submitted no later than 31 December 2025 – both to the Dual System and identically in the LUCID portal of the Central Agency Packaging Register (ZSVR).
Recyclability and Sustainable Packaging Design
Requirements for recyclable packaging will increase significantly with the PPWR and the new ZSVR minimum standard. Companies should therefore systematically review material selection, separability of components and the potential use of recyclates. Packaging with low material diversity, no disruptive coatings and clear separation features is more easily identified and processed by sorting and recycling systems. Design also plays an important role: reduced colour use, clear labelling and established standard materials significantly increase recyclability. Early adjustments allow companies to meet upcoming regulatory requirements and avoid possible sanctions for non-compliance.
What Companies Should Prioritise Now
- Critically assess recyclability and packaging design: separability, material composition and recyclate usage targets are key criteria for meeting future regulatory requirements and preventing sanctions for non-compliance.
- Position sustainability as a strategic future topic: The circular economy is far more than compliance. By using more sustainable packaging, companies can conserve resources, reduce costs and strengthen their brand image.
How the Dual System EKO-PUNKT Supports Companies
As an experienced system operator with a strong focus on circular economy and recycling, EKO-PUNKT supports companies in keeping valuable materials in circulation. In addition to packaging licensing in Germany and internationally, as well as recyclability analysis and evaluation, we provide solutions for recyclate supply and the return of high-quality secondary raw materials into new production processes. Together, we create the foundation for functional packaging recycling and a truly circular economy.
Contact us now for a consultation
Are you a small or medium-sized business looking for a simple way to fulfill your packaging compliance?
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Author
EKO-PUNKT GmbH & Co. KG
Vanessa Herzog
Waltherstr. 49-51
51069 Köln
T +49 221 964897-62
M +49 160 6184350
vanessa.herzog@eko-punkt.de
Source: EKO-PUNKT
Image credit: KI-generiert mit DALL·E über ChatGPT (OpenAI)
