From To-Go Cups to Fireworks: The Obligation to Report Single-Use Plastic Products
The Single-Use Plastic Fund Act (EWKFondsG) and the EU Single-Use Plastic Directive (2019) introduce significant new obligations for manufacturers of single-use plastic products that serve the German market. Starting in 2026/2027, the scope will expand to include other products such as fireworks. The EWKFondsG differs from the Packaging Act, as it includes not only packaging but also products like wet wipes, balloons, and tobacco products (with filters).
The Single-Use Plastic Fund Act (EWKFondsG) obliges manufacturers of products such as to-go cups, wet wipes, and tobacco filters to report and pay fees starting in 2024. From 2026/2027, these obligations will also apply to additional products like fireworks. Registration and reporting are carried out through the DIVID platform of the Federal Environment Agency.
What Manufacturers Need to Know:
The law applies to all manufacturers who place single-use plastic products on the German market for the first time. The responsibility lies with the supplier of the filled product, not the packaging manufacturer.
Affected products include:
- To-go cups and food packaging
- Wet wipes and lightweight carrier bags
- Balloons and tobacco products (based on filter weight)
Companies must contribute to the costs of waste management, public space cleaning, and awareness campaigns to reduce plastic consumption and littering. Manufacturers are required to pay a fee, determined by the type and quantity of single-use plastic products placed on the market.
Challenges for Foreign Companies
For companies without a business presence in Germany, the EWKFondsG presents specific challenges. In addition to the registration obligation, companies must report quantities of products placed on the market to ensure that contributions to the Environmental Fund are accurately calculated. Furthermore, notices of assessment from the Federal Environment Agency must be carefully reviewed, and payments must be made on time.
This process requires a detailed understanding of German regulations and can be particularly complex and time-consuming for companies outside Germany. Without local representation, compliance with the regulations can involve additional legal and administrative effort.
Single-Use Plastic Fund and DIVID Platform
The Single-Use Plastic Fund, managed by the Federal Environment Agency, finances environmental protection measures. Manufacturers must register and submit annual quantity reports.
Starting in 2024, the obligation to pay fees applies to all affected manufacturers, regardless of registration status. The management of fees is handled through the digital DIVID platform.
Reporting Obligation
Companies must report their quantities of single-use plastic products annually by March 15 of the following year. From the 2023 reporting period, these reports are subject to fees, and littering charges are applied to cover the costs of land cleanups.
Our experts can assist you with compliance. Contact us for a free consultation.
