Recently, plans for a new consumption tax on plastic packaging were announced. The tax is to be incorporated into the already ongoing Budget Accompanying Act through an amendment and generate additional revenue for the federal budget starting mid-2027.
The anticipated key points of the law
An official draft of the Plastics Packaging Tax Act was not yet available to the business community as of 09.10.2026. However, according to reports, it includes the following key points:
- The main focus will be on certain plastic films and plastic packaging materials, as well as specific packaging made from paper/cardboard, textiles, steel, and aluminium, provided their plastic content amounts to at least 50 grams per kilogram, equivalent to 5 percent.
- The tax rate will be €550 per 1,000 kilograms of plastic, equivalent to €0.55 per kilogram of plastic.
- The tax will apply not only to domestic production but also to imports from abroad.
- Relief measures are planned for recyclates, although these are not expected to take immediate effect.
- The regulation also provides significant control rights for customs authorities.
- No distinction will be made between large companies and small or medium-sized enterprises.
The associations commented verbatim on 09.10.2026 as follows:
From the perspective of the signatory associations, a plastic packaging tax is neither a fiscally, economically, or environmentally sound measure. It imposes additional burdens on consumers and businesses, creates new bureaucracy, and sets wrong incentives for recycling packaging.
1. The tax increases bureaucracy for businesses. Businesses already bear significant financial responsibility for their packaging through extended producer responsibility and the Single-Use Plastics Funds. At the same time, implementing the European Packaging Regulation PPWR requires substantial investments, including in recyclable packaging and recycled content usage. A plastic packaging tax would impose additional financial burdens on the same packaging without yielding benefits for the circular economy. The draft legislation estimates the additional annual compliance cost for businesses at approximately 44 million euros, plus a one-time conversion cost of around 8.8 million euros. These figures are grossly underestimated, as businesses will first need to calculate, document, and file tax returns for the plastic quantities in all packaging. For recycled content, traceability throughout the supply chain is additionally required. However, this is also governed by the PPWR and is expected to be promoted through eco-modulation of licensing fees. There is a risk of parallel regulatory and proof systems.
2. The tax creates additional competitive and locational disadvantages. In the European Single Market, a tax levied solely in Germany leads to disparate burdens on domestic and cross-border value chains. Additionally, much higher control intensities arise compared to abroad. A national fiscal special route imposes extra burdens on the domestic production and filling of packaging and sets back Germany as a location.
3. The tax increases the cost of everyday goods. The draft legislation explicitly assumes that the additional tax burden will be passed on to consumers. Affected are products where plastic packaging plays an important role for protection, hygiene, or durability. Especially in the food sector, the possibilities for using recyclates are still very limited due to high legal requirements for materials in contact with food, making tax refunds unrealistic. The plastic packaging tax would thus primarily be an additional cost burden on private households.
4. The tax entails significant additional expenses for the public administration. The draft legislation foresees 819 additional full-time positions at customs, the Federal Information Technology Center, and the Federal Ministry of Finance. From 2029, the ongoing expenses are expected to be around 104 million euros annually. Converting the stated time requirements using realistic assumptions for the necessary control intensity yields a significantly higher workload, likely requiring over 1,300 new positions. Against the backdrop of a government share already exceeding 50% of GDP, such a personnel expansion clearly contradicts the federal government’s political goals of reducing bureaucracy and making public administration more efficient.
5. The tax fails to set investment incentives for more sustainable packaging or additional recycling capacities. For the circular use of packaging materials and climate protection, it is more effective to actively promote sustainable packaging solutions financially. Currently, the federal government is developing a revision of eco-modulation of licensing fees under the Packaging Regulation Implementation Act with a material-neutral approach focusing on recyclability and potentially recycled content in packaging. This project must not be overshadowed by the tax.
Manufacturers and users of plastic packaging in Germany have been advancing better recyclability of packaging for years. For instance, the recycling rate for plastic packaging collected via the yellow bag or yellow bin increased from 42 percent (2018) to 70.8 percent (2024). More and more recycled plastics are replacing fossil-based raw materials. At the same time, packaging consumption in Germany has been declining since 2021, including the amount of plastic packaging—a trend expected to continue.
The signatory associations urge the Federal Government and the German Bundestag to refrain from introducing a plastic packaging tax. In any case, an orderly and transparent legislative process, involving all responsible ministries and adequate parliamentary consultation, must be ensured. This includes an impact assessment with independent review by the National Regulatory Control Council, providing a comprehensive analysis of the industrial policy and ecological effects.
These 33 associations signed the statement
Allianz Verpackung und Umwelt e.V.; Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V.; Bundesverband der Deutschen Industrie e.V.; Bundesverband der Deutschen Süßwarenindustrie e.V.; Bundesverband der Systemgastronomie e.V.; Bundesverband der Tabakwirtschaft und neuartiger Erzeugnisse e.V.; Bundesvereinigung der Deutschen Ernährungsindustrie e.V.; BDZ Deutsche Zoll- und Finanzgewerkschaft; bvse-Bundesverband Sekundärrohstoffe und Entsorgung e.V.; Deutscher Hotellerie- und Gastronomieverband e.V.; Deutsche Industrie- und Handelskammer; Der Getränkekarton-Fachverband Kartonverpackungen für flüssige Nahrungsmittel e. V. ; Fachverband Faltschachtel-Industrie e.V.; Fachvereinigung Hartpapierwaren und Rundgefäße e.V.; Gemeinschaft Papiersackindustrie e.V. ; Die Papierindustrie e. V.; Großhandelsverband Foodservice e.V.; Handelsverband Deutschland e.V.; Industrieverband Körperpflege- und Waschmittel e. V.; Industrieverband Garten e.V.; Industrieverband Papier- und Folienverpackung e.V. ; IK Industrievereinigung Kunststoffverpackungen e.V.; Lebensmittelverband Deutschland e. V.; Markenverband e.V.; Milchindustrie-Verband e.V.; PlasticsEurope Deutschland e. V.; PRO-S-PACK Arbeitsgemeinschaft für Serviceverpackungen e.V.; Verband der Automobilindustrie e.V.; Verband der chemischen Industrie e.V. – VCI; Verband Vollpappe-Kartonagen e.V.; VDMA e. V.; Wirtschaftsverband Papierverarbeitung e. V.; ZVEI e.V. – Verband der Elektro- und Digitalindustrie
- Relevant in topic:
- Sustainability and Corporate Responsibility
- Key areas:
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- Circular Economy
It has been translated with the assistance of AI.
No guarantee is made as to the accuracy or completeness of the translation.
Released 09.10.2026
Modified 13.10.2026
Contact
Christoph Petri
Director Environmental and Raw Materials Policy