Single-Use Plastics Fund Act (EWKFondsG) in Germany: What Foreign Manufacturers Need to Know

25. September 2024

4 minutes

Deutsche Recycling editorial team

Single-Use Plastics Fund Act (EWKFondsG) in Germany: What Foreign Manufacturers Need to Know

The Single-Use Plastics Fund Act (EWKFondsG) brings significant changes for manufacturers of single-use plastic products supplying the German market.

Starting 1 January 2025, manufacturers without a local presence in Germany will need to appoint an authorised representative. This article provides an overview of what the law entails, the obligations associated with it, and the challenges that foreign companies must overcome.

For Quick Readers

The Single-Use Plastics Fund Act (EWKFondsG) requires manufacturers of specific single-use plastic products (as listed in Annex 1 of the EWKFondsG) to appoint an authorised representative in Germany from 1 January 2025. If a company is not based in Germany, this representative will take responsibility for fulfilling the manufacturer’s obligations under the law, including submitting verified volume reports assessed by an expert in advance.

Why the EWKFondsG is Important for Foreign Manufacturers:

The EWKFondsG is part of Germany’s efforts to reduce environmental pollution caused by single-use plastics. It aims to hold manufacturers accountable and require them to contribute to the costs of waste disposal and environmental cleanup. For foreign companies exporting single-use plastic products to Germany, it is essential to understand and implement the regulations outlined in this law.
The law covers all products listed in Annex 1, including various commonly used single-use plastic packaging and items. Manufacturers must ensure they either have a local office in Germany or appoint an authorised representative to comply with the legal requirements.

Who is Required to Register?

The DIVID platform registration requirement applies to all companies supplying single-use plastic products to Germany. The timeline for registration depends on when the company begins its operations:
  • Before 01/01/2024: Registration must be completed by 31/12/2024.
  • From 01/01/2024 onwards: Immediate registration is required.
  • Before 01/01/2026 (for fireworks): Registration must be completed by 31/12/2026.
These regulations apply equally to manufacturers, importers, and distributors placing products on the German market.

The Challenges for Foreign Companies:

For companies without a local office in Germany, complying with the EWKFondsG presents significant challenges. In addition to the registration requirement, volume reports on the quantities of products placed on the market must be submitted to ensure that the environmental fees are correctly calculated. Companies must also review the fee notices from the Federal Environment Agency and make timely payments to the environmental fund.
This process requires a detailed understanding of German regulations and can be particularly complex and time-consuming for companies unfamiliar with local legal requirements. Without a local representative, managing compliance can create additional legal and administrative burdens.

Our Full-Service Solution!

Deutsche Recycling offers foreign companies a comprehensive solution to all the requirements of the EWKFondsG. We act as your authorised representative, ensuring that all legal obligations are met.
Our service includes:

  • Consultation: We provide expert advice on all aspects of authorisation and the EWKFondsG.
  • Process Support: We guide you through the entire process, from registration to fee payments.
  • Obligation Fulfillment: As your representative, we take responsibility for all legal duties.
  • Legal Compliance Review: We review fee notices from the Federal Environment Agency to ensure everything runs smoothly.
  • Payment Management: We handle the payment process on your behalf.
The Single-Use Plastics Fund Act (EWKFondsG) imposes significant obligations on foreign manufacturers exporting to the German market. Our full-service solution helps you manage these challenges efficiently and in compliance with the law. Contact us today to learn how we can help you meet the EWKFondsG requirements and secure your presence in the German market.

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