Germany is strengthening its environmental regulations by introducing Extended Producer Responsibility (EPR) for Single-Use Plastics (SUP). Starting 1 January 2025, companies selling products containing single-use plastics in Germany must register and contribute to a national waste management fund.
This regulation is based on the German Single-Use Plastics Fund Act (Einwegkunststofffondsgesetz – EWKFondsG) and applies to manufacturers, importers, and online sellers placing single-use plastic products on the German market.
In this guide, we explain the 10 essential steps for SUP EPR registration in Germany and how businesses can remain compliant.
What is Single-Use Plastics (SUP) EPR in Germany ?
The Single-Use Plastics EPR system requires producers to take financial responsibility for the collection, cleaning, and disposal of plastic waste generated by their products.
This regulation complements Germany’s existing EPR categories:
- Packaging
- Batteries
- Waste Electrical and Electronic Equipment (WEEE)
- Single-Use Plastics (SUP) – new category from 2025
Companies must register, report sales volumes, and pay environmental contributions based on the amount of SUP products they place on the market.
Examples of Products Covered Under SUP Regulations
Products that may require SUP registration include:
- Food containers for immediate consumption
- Beverage cups and lids
- Plastic beverage containers (under 3 litres)
- Wet wipes containing plastic fibers
- Tobacco filters with plastic
- Lightweight plastic bags
These products are considered single-use plastics because they are designed for one-time use and disposal.
Who Must Register for Germany SUP EPR?
You must register if you are considered a “producer” under German law. This includes:
- Manufacturers located in Germany
- Importers bringing SUP products into Germany
- Brand owners selling SUP products
- Online sellers selling to German consumers
- Overseas companies selling via e-commerce platforms
Even non-EU businesses must comply when selling to Germany.
10 Step Germany Single-Use Plastics (SUP) EPR Registration Process
Step 1 – Check If Your Product Is a SUP Product
First determine whether your product falls under the Single-Use Plastics category.
Two key questions help determine this:
- Is the product made partly or fully from plastic ?
- Is the product intended for single use only ?
If both answers are yes, the product likely falls under SUP regulation.
Step 2 – Determine Your Producer Role
You are considered a producer if you:
- Manufacture SUP products
- Import SUP products into Germany
- Sell SUP products under your brand
- Sell directly to German consumers online
Even private label sellers and e-commerce brands are considered producers.
Step 3 – Appoint an Authorized Representative (For Non-German Companies)
If your company is not established in Germany, you must appoint an Authorized Representative (AR) to handle compliance obligations.
The AR is responsible for:
- Managing registration
- Reporting product quantities
- Communicating with authorities
Step 4 – Create an Account on the DIVID Portal
Registration is completed via the DIVID platform, managed by the German Environment Agency.
Businesses must:
- Create an online account
- Provide company details
- Identify their SUP product categories
Step 5 – Submit SUP Registration Application
Once your account is created, you must submit:
- Company information
- Product categories
- Estimated quantities of SUP products
After approval, you will receive a SUP registration number.
Step 6 – Obtain Your Official SUP Registration Number
After successful registration, the system issues a unique registration ID formatted like:
H-XXXXXX-DE
Where:
- H = Manufacturer
- B = Authorized Representative
- DE = Germany code
This number confirms your compliance with the regulation.
Step 7 – Submit Registration Number to Marketplaces
Online marketplaces such as:
- Amazon
- eBay
- Etsy
- Zalando
will require sellers to submit their SUP registration numbers to remain active on the platform.
Non-compliant listings may be blocked or removed.
Step 8 – Report Annual Sales Volumes
Companies must report annually:
- Quantity of SUP products sold
- Product categories
- Waste impact estimates
The annual reporting deadline is 15 May each year.
Step 9 – Pay Environmental Contribution Fees
Producers must pay SUP eco-fees based on the volume of plastic products placed on the market.
These funds are used to support:
- Waste collection
- Environmental cleanup
- Recycling systems
Step 10 – Maintain Ongoing Compliance
Businesses must maintain compliance by:
- Updating sales reports annually
- Paying contribution fees
- Updating registration information when product categories change
Failure to comply can result in:
- Marketplace listing removal
- Fines
- Sales restrictions in Germany.
Important Deadlines for Germany SUP EPR
| Timeline | Requirement |
|---|---|
| April 2024 | Account creation allowed for non-German companies |
| August 2024 | Registration opened |
| January 2025 | Regulation becomes mandatory |
| May 15 every year | Annual reporting deadline |
Why Businesses Must Act Early
Germany’s SUP regulation is part of the EU’s broader strategy to reduce plastic waste and improve recycling systems.
Companies selling in Germany must prepare early because:
- Marketplaces enforce compliance automatically
- Registration and verification can take time
- Non-compliance may block product listings.
How Complico Consulting Can Help
At Complico Consulting, we help international businesses with:
- Germany SUP EPR registration
- Authorized Representative services
- Compliance documentation
- Annual reporting support
- Marketplace compliance (Amazon, eBay, etc.)
Our experts ensure your business meets all German environmental compliance requirements so you can continue selling without disruption.
✔ Need help with Germany SUP registration ?
Contact Complico Consulting today for professional compliance support.
Sources:
- German Environment Agency (Official Authority) – Single-Use Plastics Fund
- DIVID Registration Portal – DIVID Portal for SUP Producer Registration
- European Commission – Single-Use Plastics Directive
- German Federal Ministry for the Environment – German Single-Use Plastics Fund Act (EWKFondsG)
- Official German Law Portal – Einwegkunststofffondsgesetz (EWKFondsG)
