info@ecopv-eu.com
+49 6196 5835357
info@ecopv-eu.com
+49 6196 5835357
All questions regarding DIVID registration, the Single-Use Plastics Fund, the EWKFondsG, and the levy obligation for certain single-use plastic products. This detailed guide answers your questions about the legally compliant implementation of the special levy on single-use plastics manufactured or imported into Germany.
Basics & Legal Framework
The Single-Use Plastic Fund Act (EWKFondsG) requires manufacturers and importers of certain single-use plastic products (e.g., takeout packaging, beverage cups, or tobacco filters) to pay an annual special levy. The funds collected go into the state Single-Use Plastic Fund to compensate municipalities for cleaning public spaces.
The law transposes the EU Single-Use Plastics Directive into German law. Based on the polluter-pays principle, the costs for the disposal and removal of discarded plastic waste in parks and on streets are shifted from the general public to the distributors. The fund is managed digitally by the Federal Environment Agency (UBA), which distributes the funds to cities and municipalities according to a statutory points system. As of January 1, 2026, fireworks containing plastic components are also subject to this levy.
The fund shifts the financial burden of cleaning up plastic waste in public spaces from taxpayers directly to the responsible market participants. It also creates a strong economic incentive to switch to tax-free reusable systems.
Until now, local governments have covered the cleanup costs for carelessly discarded single-use cups or cigarette butts on their own. The fees are now collected by the UBA, relieving the strain on municipal budgets for emptying public trash cans and for local awareness campaigns. Since the fee is calculated per kilogram of plastic, companies that opt for plastic-free packaging or reusable packaging save money.
The EWKFondsG is based on Article 8 of the EU Single-Use Plastics Directive (EU) 2019/904 on Extended Producer Responsibility (EPR). The law is supplemented by the Single-Use Plastics Ban Regulation and the Single-Use Plastics Labeling Regulation.
The European directive follows a three-step strategy: Single-use plastic items that are particularly harmful to the environment (such as plastic cutlery or cotton swabs with plastic stems) are banned. Permitted single-use items must bear visual warnings regarding proper disposal, and for the remaining mass-produced products, the financial contribution requirement under the EWKFondsG applies. Since these laws complement one another, a product – such as a plastic beverage cup – may be subject to both a labeling requirement and a levy requirement at the same time.
The EWKFondsG has been in effect since January 1, 2024. All affected companies must register on the UBA’s DIVID platform and report the quantities from the previous calendar year by May 15 of each year.
During ongoing operations, billing occurs on a fixed schedule: After the volume report is submitted in May, the UBA calculates the individual tax assessment later in the year. Important for 2026: For quantities placed on the market of 100 kilograms or more per product category, the data must be certified by an independent auditor or expert. A special deadline applies to manufacturers of fireworks: They must register on the DIVID portal by December 31, 2026, at the latest, for the levy obligation effective starting in 2026.
Affected Products
Appendix 1 of the law lists nine specific product groups: food containers, bags/plastic wrap, beverage containers (up to 3 liters), beverage cups, lightweight plastic shopping bags, wet wipes, balloons, tobacco products with filters, and, as of January 1, 2026, fireworks.
The law covers mass-produced items that extremely frequently litter public spaces. Tobacco filters incur the highest fees due to their astronomical quantities. Important: There is a maximum weight limit of 500 grams for bags, plastic wrap, and food containers. Larger packages (e.g., 1-kg bulk packages) are exempt from the special levy. Products made entirely of paper without any plastic coating are also completely exempt from the levy.
Food containers are defined as boxes or trays, with or without lids, that hold ready-to-eat takeout food. The food must be intended to be consumed immediately on-site or as a takeout meal directly from the container.
The food must be ready to eat without cooking, heating, or further preparation. Classic examples include coated fast-food boxes, salad bowls, or sushi packaging. Frozen meals that must first be microwaved are not included. Important: The 500-gram threshold applies here as well – if the contents weigh more than 500 grams, the EWKFondsG requirement does not apply. According to the law, beverage containers, drink cups, and plates are expressly excluded from this category. In borderline cases, we will submit an official classification request on your behalf to the Federal Environment Agency (UBA).
No. The levy applies exclusively to pre-moistened wipes for personal and household care that are intended for private end consumers. Wet wipes intended solely for commercial or medical use are completely exempt from the levy.
Wipes for professional nursing care, disinfectant wipes in hospitals, or industrial cleaning wipes used in trades are not subject to the EWKFondsG. The decisive factors are marketing and intended use. If a manufacturer sells an identical wipe both in supermarkets and in the B2B hospital sector, only the portion sold to private customers is subject to the levy.
Yes, this specific expansion to include fireworks has been in effect since January 1, 2026 – however, no other products will be added beyond that.
All manufacturers and importers of fireworks (categories F1 through F4) with integrated plastic components are now subject to the law. Plastic casings, stands, or fuse covers generate enormous amounts of waste after New Year’s Eve. For this reason, pyrotechnics suppliers are required to register on the Federal Environment Agency’s DIVID portal by December 31, 2026.
Please note the deadlines: Although the registration requirement has been in effect since January 2026, the actual reporting obligation applies only to sales volumes starting January 1, 2027. Consequently, the very first mandatory volume report must be submitted electronically by May 15, 2028. According to the UBA testing guidelines, the total weight of the fireworks article serves as the basis for calculation, not just the weight of the plastic component alone. No additional product groups are planned.
Who Is a Manufacturer & Who Is Affected
A manufacturer is any natural or legal person who, for the first time, commercially makes a single-use plastic product subject to the levy available on the German market. This role may fall to the producer of the finished product, the filler, the seller, or the importer.
Anyone who imports finished single-use items from abroad is considered a manufacturer. Unlike under the Packaging Act Implementation Act (VerpackDG), the EWKFondsG generally does not focus on who fills the packaging, but rather on who first makes the packaging in question available on the German market. Because these supply chain dynamics are complex, we analyze your distribution channels and classify your products in a legally compliant manner based on the official UBA guidelines.
Yes, under certain conditions. Anyone who imports single-use plastic products from abroad themselves or is the first to place them on the market in Germany for commercial purposes bears full manufacturer responsibility and is subject to the levy.
Anyone who purchases unfilled to-go packaging domestically is generally exempt – provided that the upstream supplier has already fulfilled these obligations. Cafés, butcher shops, and bakeries are often considered final distributors. If you purchase unregistered cups or to-go containers (e.g., through personal import), you yourself become legally liable as the manufacturer required to pay the fee.
If, on the other hand, you purchase the packaging from a German wholesaler registered on the DIVID portal who is listed as the first distributor for these products, the obligation to pay the fee lies with the upstream supplier.
Yes. Online retailers who import single-use plastic products subject to the levy directly from abroad (e.g., China) and sell them in Germany are considered first-time distributors and must register with DIVID themselves.
As a pure reseller of domestic goods, you are exempt from the special levy. However, you are subject to a distribution ban if the manufacturers of your products are not properly registered in the DIVID registry. Since e-commerce marketplaces will conduct these checks fully automatically in 2026, missing registrations will result in immediate listing suspensions.
Yes. Manufacturers and distance sellers without a branch office in Germany are required to appoint an authorized representative based in Germany before commencing their sales activities.
The authorized representative fulfills all obligations under waste management law in their own name and is fully liable to the Federal Environment Agency for data reports and payments. Foreign direct sellers who ship to German customers via online platforms without an authorized representative are operating illegally. As a full-service provider established in Germany, we assume this legally mandated role as authorized representative for foreign manufacturers of solar products, electronics, and consumer goods in a legally compliant manner through our systems.
Registration via DIVID
Registration is conducted entirely online via the DIVID portal of the Federal Environment Agency (UBA). Manufacturers and importers must enter their company information, tax ID numbers, all brand names used, and the exact product types as specified in Annex 1.
The DIVID platform serves as the central government interface. In addition to initial registration, it is used to process annual data reports and the settlement of the single-use plastic levy. The UBA also uses this portal to manage the distribution of fund resources to municipalities. Since registration is a legal requirement for lawful distribution, it must be completed before the first sale takes place.
We handle the entire technical and content-related setup of your account on the DIVID portal.
Manufacturers and importers who introduce new products subject to the levy onto the German market must complete registration on the DIVID portal before the first commercial release of the product. There is no retroactive grace period for new entrants – the requirement applies starting with the first product.
The law does not provide for any grace periods or exemption thresholds for late entrants. Anyone offering single-use plastic products subject to the levy without an active registration is in violation of the EWKFondsG.
For the newly added fireworks, a strict registration deadline also applies: Registration must be completed by December 31, 2026, at the latest, provided you were already active on the market prior to 2026. The subsequent regular levy obligation begins on January 1, 2027, and the first official volume report for the 2027 reference year must be submitted by May 15, 2028.
Reporting & Payment
Registered manufacturers must report, by May 15 of each year, the exact mass in kilograms of all single-use plastic products made available for the first time in Germany during the preceding calendar year.
Reporting is done exclusively online via the DIVID portal and must be broken down strictly according to the individual product types listed in Appendix 1. Even if no products subject to the fee were distributed in a given year, a so-called “zero report” is required by law. Failure to report or late reporting is considered an administrative offense.
Yes, in principle. The annual volume report must typically be reviewed by a registered expert, certified public accountant, tax advisor, or certified auditor and verified on the DIVID portal.
The law provides for a threshold of 100 kilograms in this regard: If you placed less than 100 kilograms of plastic mass on the market per product category in the previous calendar year, this costly audit requirement does not apply to you at all – however, the reporting and registration requirements remain unaffected.
If you miss the statutory deadline of May 15, the Federal Environment Agency (UBA) will make an official estimate of the type and quantity of single-use plastic products you have placed on the market. This estimate then serves as the legally binding basis for your tax assessment notice.
Since the UBA bases its assessment on general industry and sales data, such an official estimate is usually higher in practice than the actual quantities, resulting in an unnecessarily high levy burden.
Furthermore, failure to report or late reporting constitutes an administrative offense under the EWKFondsG, which can be punished with fines of up to 100,000 euros. A persistent violation of reporting and registration requirements also jeopardizes your sales license: Marketplace operators are legally required to verify compliance, so violations may result in sales bans and the suspension of your listings on e-commerce platforms.
The fee is calculated per kilogram of pure plastic weight. The exact rates are specified in the EWKFondsV and vary drastically depending on the product type: they range from 0.17 cents to 8.95 euros per kilogram.
The enormous price differences reflect the estimated cleanup costs in public spaces:
After the volume report is submitted in May, the Federal Environment Agency issues the official fee assessment later in the year. The amount due must be paid by bank transfer within one month of receiving the assessment.
This payment deadline must be strictly adhered to, as the UBA takes an extremely strict stance on late payments. Just three business days after the one-month deadline expires, statutory late payment penalties of 1% of the outstanding amount per month become automatically due. The agency grants payment in installments or a deferral only in extreme, verifiable cases of financial hardship.
Penalties
The EWKFondsG establishes fines for companies that fail to meet their registration, reporting, or payment obligations. In addition to regulatory sanctions, failure to register may result in practical disadvantages such as exclusion from distribution platforms and a regulatory volume estimate that is unfavorable to the manufacturer.
The specific amount of the fine depends on the nature and severity of the violation as well as the circumstances of the individual case; both a complete failure to register and a late or incorrect volume report can be penalized as separate administrative offenses. Since the UBA maintains a publicly accessible manufacturer registry, unregistered suppliers can be identified relatively easily, which increases the risk of detection compared to less transparent regulatory frameworks. In practice, a lack of or incomplete registration often leads to economic disadvantages even before formal fine proceedings begin – for example, when distribution partners or marketplaces refuse to work with unregistered manufacturers. Anyone who discovers a breach of this obligation on their own should proactively report it to the UBA as soon as possible to limit the risk and scope of potential sanctions.
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