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On Wednesday 1 January 2025, the German Extended Producer Responsibility (EPR) regulation will come into effect, significantly impacting the sale of single-use plastic products on German marketplaces, including Amazon.de. What do you need to do to comply so you can continue (or start) trading in Germany?
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ToggleWhat does the EPR regulation do?
This regulation mandates that producers, importers, and distributors of single-use plastic items engage in systematic collection, sorting, and recycling efforts to maintain their listings. It works in tandem with Germany’s Single-Use Plastics (SUP) Levy to promote a more sustainable approach to plastic use and disposal.
The Single-Use Plastics Levy: how does it relate to the German EPR regulation?
These are interconnected measures aimed at reducing plastic waste. The law on the Single-Use Plastics Fund, passed in May 2023, requires producers, importers and sellers to bear the costs for the collection of their single-use plastic products from 2024.
Here’s a simple explanation:
- EPR Regulation: Your business must register its single-use plastic products, report the quantities sold, and ensure proper waste management practices. Read our overview of the EPR regulations.
- Single-Use Plastics (SUP) Levy: Introduced in 2024, this is a financial charge that businesses must pay when they first place single-use plastic products on the market. The levy helps fund the costs associated with managing and recycling these plastics. The first payments are due in 2025.
Together, these measures ensure that businesses are accountable for the environmental impact of their products, and support sustainable waste management and recycling efforts.
Why does compliance with EPR matter?
The EPR regulation is a crucial step towards sustainable waste management and reducing plastic pollution. Compliance isn’t optional; it’s mandatory.
If you don’t comply with these regulations, you risk the deactivation of non-compliant listings on Amazon.de and other German marketplaces. This could severely impact your business operations and revenue streams.
Immediate actions required:
- If you’re a producer based in Germany: Secure registration numbers for all your brands across various categories of single-use plastics. This can be done by registering with the German Environment Agency through a service provider like AVASK. You’ll need to create an Elster account for your registration.
- If you’re a producer based outside Germany: You’ll need to designate an authorised representative (AR) to manage your single-use plastics obligations on your behalf. This representative will handle all compliance requirements, ensuring your products remain listed.
- If you’re a drop shipper and/or resellers: Get the registration numbers from your upstream suppliers. Make sure that all your products are compliant by verifying the registration status with your suppliers.
- Register for the Single-Use Plastics registration number by 31 December 2024 if you’re an existing seller. If you’re a new seller, register now. All producers of SUP products must have a registration number from 2025.
You’ll need to submit your registration yourself, but we can help guide you with that.
How to stay compliant with EPR
Starting in 2025, you’ll need to:
- annually report the types and volumes of single-use plastic products sold in Germany
- pay the associated eco fees
This is essential to demonstrate compliance when marketplaces’ portals for single-use plastic products go live at the end of 2024.
What’s your reporting obligation?
From 2025, producers are required to report the SUP products they made available, or sold on the market, for the first time in the previous calendar year to the Federal Environment
Agency electronically via the DIVID platform by 15 May each year. You’ll have to do this yourself, but we can guide you through the process.
What happens if you don’t comply?
Listings that don’t comply with the EPR mandates will be deactivated post-deadline. This could lead to:
- significant disruptions in your business operations
- loss of sales
- potential penalties
If you’re compliant now, you’ll safeguard your business, support your trade in the German market and your EU expansion goals, and contribute to a more sustainable future.
Why you need to act now
The deadline is fast approaching, and the process of securing registration numbers and ensuring compliance can be time-consuming. We strongly advise registering promptly with a provider like AVASK – and AVASK’s new service will be available soon to help you navigate these requirements efficiently.
FAQs about the upcoming single-use plastics deadline
What happens if we miss the deadline?
Missing the deadline for compliance with the German EPR regulation for single-use plastics can result in significant penalties:
- Fines: Non-compliance can lead to fines of up to €100,000. This applies whether the lack of registration is intentional or unintentional.
- Sales ban: Products that are not registered in accordance with the EPR regulations may be subject to a sales ban. This means that non-compliant products cannot be sold on the German market.
- Seizure of goods: Authorities have the power to seize all non-compliant goods on the market. This can lead to substantial financial losses and disruption of business operations.
- Additional penalties: There may be further administrative and civil penalties for non-compliance, including incorrect declaration of the amount of single-use plastics.
That means it’s crucial to register as soon as you can to ensure compliance with the EPR regulations by the 1 January 2025 deadline.
What products are covered under the German Single-Use Plastics levy?
The key categories are:
- food containers, i.e. containers, such as boxes with or without lids, for food which:
a) is intended to be consumed directly, either on site or as a take-away meal,
b) are generally consumed out of the packaging and
c) can be consumed without further preparation such as cooking, boiling or heating.
Food packaging in this sense does not include beverage containers, beverage cups, plates, bags
and film packaging, such as wrappers, containing food.
2. bags and film packaging made of flexible material, such as wrappers, with food content that
a) is intended to be eaten directly from the bag or film packaging, and
b) does not require any further preparation;
3. beverage containers with a filling volume of up to 3.0 litres, i.e. containers used to hold
liquids, such as beverage bottles and composite beverage containers, including their closures
and lids. Beverage containers made of glass or metal with closures or lids made of plastic are
not beverage containers in this sense.
4. beverage cups, including their closures and lids
5. lightweight plastic carrier bags, i.e. plastic carrier bags with a wall thickness of less than 50
micrometres, with or without handles, offered to consumers at the point of sale of goods or
products;
6. wet wipes, i.e. wet wipes for personal and household care;
7. balloons, with the exception of balloons for industrial or commercial use and
applications that are not sold to consumers;
8. tobacco products with filters and filters intended for use in combination with tobacco
products
Fireworks
From 2027, the levy will also include fireworks containing plastic parts. Fireworks within the meaning of Section 3(1)(4) of the Explosives Act can be found in the list of disposable plastic products (Annex 1 EWKFondsG) from 1 January 2026.
Further reading
For more detailed information, you can refer to these official sources:
Registration
Third parties like AVASK cannot provide the required information and declarations – this is in accordance
with the Act on the Single-Use Plastics Fund, Section 10 (5) EWKFondsG (PDF).
Registration
Third parties like AVASK cannot provide the required information and declarations – this is in accordance
with the Act on the Single-Use Plastics Fund, Section 10 (5) EWKFondsG (PDF).
Expand into the EU/UK market with AVASK
Venturing into the EU involves tackling various aspects, such as VAT compliance, following EPR guidelines and ensuring smooth product shipments. Our team has your back, making sure your journey into the EU market is smooth and successful
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