Under the Single-Use Plastics Fund Act (EWKFondsG) in Germany, producers and distributors of single-use plastic products are required to register in DIVID. This includes a wide range of businesses involved in the production, import, or distribution of such products.

Who needs to register for Single-Use Plastics?

Manufacturers: Companies that produce single-use plastic products within Germany must register. This includes businesses that create plastic packaging, bottles, food containers, straws, and other similar items.
Importers: Companies that import single-use plastic products into Germany from outside the country are also required to register. This includes both plastic products that are intended for sale to consumers and those sold to other businesses.
Distributors and Retailers: If businesses are selling single-use plastics in Germany (even if they do not produce or import them), they may need to register as well, depending on their role in the supply chain.

Registration Requirements:

Identification of Products: Businesses must report the types and amounts of single-use plastic products they are placing on the market.
Payment of Fees: Producers and importers will contribute financially to the system based on the volume of plastic they sell. These fees help fund the collection, recycling, and disposal of plastic waste.
Compliance with Waste Management: Registered companies are required to follow the rules regarding the proper disposal, collection, and recycling of the plastic products they place on the market.

What are Single-Use Plastic (SUP) Products?

Single-Use Plastic (SUP) Products are plastic items that are designed to be used once and then discarded. These products are typically not intended for reuse, and they contribute significantly to plastic pollution because they are often not recycled or properly disposed of. Those include,

Plastic Bottles: Water, soda, and other beverage bottles that are used once and thrown away.

Plastic Bags: Shopping bags made of plastic, often used for packaging goods in stores.

Plastic Cutlery: Forks, knives, spoons, and straws used for eating or drinking, especially in takeout or fast food.

Plastic Plates and Cups: Disposable plastic items used for serving food and drinks at parties or events.

Food Packaging: Plastic containers, wraps, and trays used for packaging food items, such as plastic food wraps or take-out containers.

Plastic Straws: Commonly used for drinking beverages but often discarded after a single use.

Plastic Lids and Caps: Lids for coffee cups, take-out containers, and beverage bottles.

Coffee Pods: Single-serve plastic pods used for coffee machines, such as those for Keurig or Nespresso.

Plastic Stir Sticks: Often used in coffee shops for stirring drinks.

Plastic Cigarette Butts: Filters that are part of disposable cigarettes.

Why compliance with EPR matters?

The Extended Producer Responsibility (EPR) regulation is a vital step towards promoting sustainable waste management and reducing plastic pollution. Compliance with EPR is not optional — it is mandatory for businesses that produce, import, or distribute single-use plastic (SUP) products in Germany. Failing to comply with these regulations can have significant consequences for your business, including the deactivation of non-compliant listings on platforms like Amazon.de and other German marketplaces, which can severely disrupt your operations and revenue streams.

Immediate Actions Required:

For Producers Based in Germany:

Secure Registration Numbers: Ensure you obtain a registration number for each of your brands across various categories of single-use plastics.
How to Register: Register with the German Environment Agency (Umweltbundesamt) through a service provider like FZCO Accountants. You’ll need to create an Elster account for this process.

For Producers Based Outside Germany:

Designate an Authorized Representative (AR): If you are not based in Germany, you are required to designate an authorised representative (AR) within Germany to manage your EPR obligations. The AR will handle all compliance requirements on your behalf, ensuring that your products remain listed on German marketplaces.

For Drop Shippers and Resellers:

Get Registration Numbers from Your Suppliers: As a drop shipper or reseller, you must ensure that your upstream suppliers have registered their single-use plastic products. Confirm the registration status of your products with your suppliers to ensure compliance.

How to stay compliant with EPR?

Register for the Single-Use Plastics Registration: Whether you’re a producer, importer, or reseller, you need to submit your registration by the required deadlines.

Work with Service Providers: If needed, enlist the help of service providers like FZCO Accountants to assist with the registration process, especially if you’re unsure about the requirements.

Regularly Check Compliance: Stay up to date with any regulatory changes or updates from the German Environment Agency and the European Union to ensure continuous compliance.

Key Deadlines:

Existing Sellers: You must register and secure your registration number by 31 December 2024.
New Sellers: Register as soon as possible to ensure your products are compliant.
Effective Date: From 2025, all producers of single-use plastic products must have a registration number.

The registration process ensures that those responsible for the creation and distribution of single-use plastics are held accountable for managing their environmental impact. The goal is to encourage waste reduction, improve recycling rates, and reduce plastic pollution.

Germany EPR for Single-Use Plastics