Last updated: 1 January 2026
What has happened?
In 2016, the German Federal Ministry of Environment and the German retail industry agreed on voluntary measures to reduce the use of plastic carrier bags. However, upon evaluating the success of these voluntary measures, the government decided that they had not proven to be successful. Consequently, the German legislature amended the Packaging Act (in German: Verpackungsgesetz) and introduced a general legal ban on plastic carrier bags. This ban entered into force on 1 January 2022.
What does this mean?
The most relevant aspects of the legal ban on plastic carrier bags are the following:
- The amended Packaging Act does not prohibit the sale or use of plastic carrier bags per se. However, since 1 January 2022, final distributors have been prohibited from placing on the market plastic carrier bags, with or without handles, with a wall thickness of less than 50 micrometers, that are intended to be filled with goods at the point of sale.
- This prohibition also includes “bioplastic” bags, i.e., recycled or ecologically produced plastic bags. In the Federal Ministry of Environment’s opinion, bioplastics are as harmful to the environment as conventional plastic carrier bags.
- In contrast, placing plastic carrier bags on the market as a separate product is not prohibited, especially as these carrier bags are not intended to be filled at the point of sale.
- Furthermore, very lightweight plastic carrier bags with a wall thickness of less than 15 micrometers (in German: Hemdchentüten) are exempted from the ban. In the Federal Ministry of Environment’s view, there are few environmentally friendly alternatives to these bags, which are necessary for hygiene reasons or are intended as sales packaging or initial packaging for food.
- If final distributors offer plastic carrier bags with a wall thickness of less than 50 micrometers in violation of the Packaging Act, they have committed an administrative offense punishable with a fine of up to EUR 100 thousand.
Where to seek further help
Baker McKenzie has extensive experience in advising clients on the ever-evolving German packaging law. To discuss how your business can best position itself in respect of these issues, please contact a member of our team today.
