Twelve areas of action are outlined, an implementation horizon of the end of 2027 is sought, and a total funding volume of over 560 million euros is indicated. For product manufacturers, the planned measures relating to extended producer responsibility, recycled content quotas, and the Digital Product Passport are of particular interest. The following article provides a structured overview.
A. Background: What is the Action Programme?
The NKWS has formed the strategic framework of German circular economy policy since the end of 2024. It sets out the guiding principle of substantially reducing the consumption of primary raw materials and describes objectives and measures for a resource-efficient, circular economy. The Action Programme now presented is the next step: it implements the mandate from the coalition agreement to “present key points for measures that can be realised in the short term to close material cycles”, and identifies, from the broad catalogue of measures within the NKWS, those projects that the Federal Government intends to address by the end of 2027. The Action Programme itself does not yet give rise to binding legal obligations – it marks the political will and the starting point for subsequent legislative procedures and practical projects. Independently of this, some proposals form part of ongoing procedures at European level with specific deadlines.
At the European level, the Action Programme is closely embedded in the EU Commission’s Clean Industrial Deal, the Critical Raw Materials Act (CRMA), and the Circular Economy Act (CEA) announced for the end of 2026. The EU raw materials strategy points in the same direction: circular economy is no longer understood as a purely environmental policy objective, but as an instrument for strengthening industrial resilience and raw material independence.
The Action Programme comprises a total of twelve areas of action, ranging from the establishment of an implementation platform, investment promotion, and public procurement through to international cooperation. Overall, the document gives one important indication: all measures within the Action Programme remain subject to a financing proviso and to the proviso regarding the Federal Government’s competence under financial constitutional law.
B. Product-Relevant Measures at a Glance
This article focuses on those areas that may affect product manufacturers.
I. Extended Producer Responsibility (Measure 8)
Measure 8 of the Action Programme bears the heading “Improving and Extending Product Responsibility” and is arguably the most significant section for product manufacturers. It is divided into three regulatory projects:
1. Adaptation of national packaging law
The EU Packaging Regulation (Regulation (EU) 2025/40, PPWR) entered into force on 11 February 2025; initial provisions apply from 12 August 2026. The Action Programme intends to adapt national packaging law to the PPWR by this date. The Bundestag has now adopted the corresponding Packaging Law Implementation Act (VerpackDG) on 11 June 2026, which must still pass through the Bundesrat. The relevant committee has recommended that the Act be deferred, but that a further amendment be initiated soon, in order to, amongst other things, better regulate the allocation of financing responsibility between public waste disposal authorities and dual systems.
For manufacturers of packaging within the meaning of the PPWR, new cost-bearing obligations within the framework of extended producer responsibility are becoming apparent in particular, as well as future participation in so-called other producer responsibility organisations, including for packaging that has not previously been subject to a system participation obligation. Of central importance for the financial dimension is also the still-outstanding Delegated Act on the eco-modulation of participation fees under the PPWR, on the basis of which Section 26 VerpackDG (formerly Section 21 VerpackG) is to be adapted. Negotiations on this matter are expected to continue until 2030. The Action Programme announces that it will examine the possibilities of creating an effective national provision before this Delegated Act is adopted.
2. Extended producer responsibility for textiles
The amended EU Waste Framework Directive, which entered into force on 16 October 2025, obliges Member States to introduce extended producer responsibility for textiles, accessories, and footwear – with a transposition deadline of 17 June 2027. The Action Programme intends to comply with this requirement and to integrate the existing collection structures in Germany with the new producer responsibility system.
Manufacturers and importers of covered textile products will in all likelihood be subject to registration and take-back obligations in future. The Action Programme expressly emphasises that obligations are also to be enforced against suppliers from third countries – a signal to manufacturers who place their products directly with end consumers in Germany via distance selling. We also refer at this point to further information in the blog post on the planned producer responsibility in the textile sector of 13 April 2026.
3. End-of-Life Vehicles Regulation
In February 2026, a political trilogue agreement was reached on the EU Regulation on the circular design of vehicles and on the treatment of end-of-life vehicles. The Regulation is to include minimum shares of recycled plastics; corresponding requirements for steel and critical raw materials are also envisaged in the longer term. Following the formal entry into force of the EU Regulation, the Action Programme plans to adapt national law. Vehicle manufacturers and their suppliers should already be taking this development into account in product development.
II. Digital Product Passport (Measure 4)
The Action Programme intends to support the introduction of Digital Product Passports (DPP) on the basis of the relevant EU regulations. To this end, a dedicated competence team for Digital Product Passports is to be established within the framework of a coordination office. The Action Programme identifies the following guiding principles: low-bureaucracy implementation, protection of sensitive company data, and particular consideration of SMEs.
For product manufacturers, the DPP is already a planning matter today: it will become mandatory at EU level on a sector-by-sector basis – beginning with batteries – and requires the systematic recording and provision of product and material data along the entire value chain. The specific dates depend on the adoption of the respective EU tertiary legal acts.
III. Plastic Recycled Content Quotas (Measure 9)
Article 7 of the EU VerpackVO provides for mandatory recycled content quotas for plastic packaging, applying from 2030. The Action Programme announces that it will advocate, in the negotiations on the relevant implementing act, for a so-called “banking period” in the years 2028 and 2029: plastic recyclates already used during this transitional period should be able to be credited towards the quotas applying from 2030. Whether this banking period materialises depends on the outcome of the EU negotiations.
This already creates planning relevance for packaging manufacturers: those who adopt the use of plastic recyclates at an early stage could benefit from such crediting. This presupposes that the necessary procurement and certification structures are established in good time.
IV. Market Surveillance and Online Platforms (Measure 10)
Even under current law, obligations exist for online traders to verify that products offered on their platform comply with product law requirements – for example in the area of the ElektroG. The Action Programme builds on this and pursues the aim of extending and strengthening these requirements at EU level. Specifically, the Federal Government is to advocate for clear, enforceable rules that prohibit online platforms from offering products from manufacturers who do not comply with applicable product responsibility regulations. This is to be anchored within the framework of the EU Commission’s Circular Economy Act (CEA) planned for the end of 2026.
Since the CEA has not yet been published, no concrete new obligations for manufacturers can be derived from this project at present. The political direction is, however, clear: compliance with product responsibility obligations is likely to become an increasingly relevant prerequisite for access to online sales channels in future. Manufacturers should keep a close eye on this development.
V. Lithium Batteries and Fire Protection Measures (Measure 6)
The Action Programme provides for the establishment of a Round Table on “Reducing the Fire Risk from Lithium Batteries”. The background to this is that fires at waste disposal and treatment facilities – according to industry sources frequently caused by damaged lithium batteries – are placing an increasing burden on the waste disposal infrastructure. The Action Programme makes clear that the recently concluded amendment to the ElektroG cannot resolve the problem on its own.
Within the framework of the Round Table, various approaches to solutions are to be developed, including standardised plant-related safety measures to improve the insurability of waste disposal facilities, as well as measures for broader consumer information. In addition, a manufacturer-financed fire protection fund – called for by the waste management industry – is also being discussed as one of several possible options; the Action Programme expressly refrains from making a determination in this regard. Manufacturers of products containing lithium batteries (in particular electrical appliances, e-bikes, e-cigarettes) should nonetheless follow this process closely, as the outcomes of the Round Table could in the medium term lead to regulatory or financial requirements.
Conclusion
The Federal Government’s Action Programme for the NKWS is a political direction-setting document: it identifies the legislative projects that the Federal Government intends to pursue during this legislative period and sets the pace – binding legal obligations do not arise immediately. For product manufacturers, it is nonetheless relevant, as it describes the regulatory horizon of expectations and shows which topics will come onto the agenda in the coming years.
Manufacturers should pay particular attention to:
- preparation for the new packaging law (VerpackDG about to be passed; EU application date August 2026),
- monitoring of the national textile EPR legislative procedure (EU transposition deadline June 2027),
- early engagement with the Digital Product Passport (introduced on a sector-by-sector basis at EU level),
- strategic planning for the use of recyclates in plastic packaging (quota obligation from 2030, possible banking period from 2028),
- and developments relating to online platforms and product responsibility in the context of the planned Circular Economy Act.
In addition, there is the need for continuous monitoring of the subordinate EU legal acts – in particular the Delegated Acts under the VerpackVO – as their delayed entry into force regularly gives rise to shifts and planning uncertainty.
Do you have any questions about this news, or would you like to discuss it with the author? Please contact: Paul Jäde and Michael Öttinger
