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My dual system contract runs out at the end of 2026 – do I have to sign a new one?

Verified on 2026-09-01 · Packaging law (PPWR)

In short

Under the German transitional rules, system participation contracts concluded before 12 Aug 2026 remain valid until 31 Dec 2026 at the latest. From 1 Jan 2027, contracts and volume reports must reflect the new allocation of responsibility – in many cases that means: conclude a new contract or have yours actively confirmed. Industry statements on this currently contradict each other; get written confirmation from your system on what applies to your contract.

What to do now, concretely

  1. Dig out your dual system's contract documents (conclusion date, term, volume schedule).
  2. Ask the system in writing whether your contract remains valid beyond 31 Dec 2026 or must be concluded anew.
  3. Document the answer and set a reminder for November 2026 – that still leaves time to switch if the terms get worse.
  4. Compare prices while you are at it: switching systems is easiest at the turn of the year.

Important: do not terminate or let the contract lapse before the follow-on contract is in place – selling without system participation is a distribution-ban and fine risk. When in doubt, the industry advice applies: keep your own licensing running without interruption.

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Sources: fynax: PPWR und VerpackDG – Altverträge längstens bis 31.12.2026 (accessed 2026-09-01) · KPMG Law: VerpackDG-Übergangsregeln (accessed 2026-09-01)

Legal information, not legal advice. The linked official sources prevail; data marked “draft” has not been finally verified.

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