TBA Ecofuture – Your Key to Extended Producer Responsibility in Germany

As a one-stop-shop for compliance solutions, TBA Global is always dedicated to delivering the best quality services to your business. With this in mind, we have launched TBA Ecofuture – a dedicated branch to assist with your Extended Producer Responsibility needs in Germany!

What is Extended Producer Responsibility?

Extended Producer Responsibility (EPR) is the general term used to describe environmental policies that are designed to hold producers accountable for the entire lifecycle of their products, including waste collection and disposal.  

For the purposes of EPR, ‘producers’ are usually one of the following:

• Manufacturers
• Retailers
• Resellers (including distance sellers)
• Importers

The European Union has implemented a set of EPR Directives which require individual Member States to implement their own individual EPR regulations, based on a common set of principles.

This means that many EU Member States (including Germany) will regulate similar categories of products.  If you’re selling any of these regulated products, you will need to double-check to see whether you also need to comply!

Which EPR categories apply in Germany?

There are currently four EPR categories enforced in Germany:

1. German EPR – Batteries

The relevant legislation is the Battery Act – also known as BattG.

This category covers most types of batteries (including those sold as a component of other products).  The types of batteries include:

• Single-use
• Rechargeable
• Automotive

2. German EPR -Packaging

The relevant legislation is the Single-Use Plastics Fund Act – also known as EWKFondsG.

This category covers:

• Primary packaging (e.g. product packaging)
• Secondary packaging (e.g. shipping and/or protective packaging)

3. German EPR – Waste Electrical and Electronic Equipment

The relevant legislation is the Electrical and Electronic Equipment Act – also known as ElektroG.

There are numerous subcategories under the WEEE category, all of which will require a separate entry under the main WEEE registration number.    

Since 2018, the European Union has consolidated the number of WEEE subcategories into the following:

1. Heat exchangers
2. Screens, monitors and equipment containing screens (surface area > 100 cm²)
3. Lighting and lamps
4. Large appliances where at least one of the external dimensions exceeds 50 cm
5. Small appliances where none of the external dimensions exceeds 50 cm
6. Small IT and telecommunications devices (external dimensions < 50 cm)

Accordingly, this approach has been implemented in Germany.

4. German – Single-Use Plastics (SUP)

The relevant legislation is the Single-Use Plastics Fund Act – also known as EWKFondsG.  

This category covers products which are designed for single-use and consist of plastics.  To determine whether an item is a single-use plastic, you can apply the following two-step test:

• Check if your products are made entirely or partially out of plastic
• Check if your products are designed to be used once, or multiple times

At the moment, only the following categories of products are classed as single-use plastics:

• Food containers
• Bags and film packaging containing food
• Non-deposit beverage containers
• Beverage cups
• Lightweight plastic carrier bags
• Wet wipes
• Balloons
• Tobacco products with filters, filters for tobacco products

Fireworks is due to be added to the product category list in 2026.  

It’s also important to note that for all categories, if your business is not based in Germany already, you will need to appoint a local Authorised Representative before you can register for EPR!

What are my ongoing responsibilities once my business is registered?

For some categories, you may be required to enrol with a local Producer Responsibility Organisation to handle waste management locally.   

For all three categories, your business will need to declare the volume of regulated products used/sold – the declaration frequency will be based on each individual category.

You will then need to pay a proportional contribution fee for each registered category, based on the volume.

The contribution fee rates are usually revised every calendar year.   

Why did you set up TBA Ecofuture?

TBA Global already provides a wide variety of compliance services across the EU.  

We have decided to demonstrate our commitment to helping business fuel the transition to more environmentally friendly practices and ensure that no one is caught out by new regulations by establishing a dedicated local branch in Germany, one of the most popular commerce hotspots in the EU.   

TBA Ecofuture is officially listed as an Authorised Representative in Germany under local EPR regulations.  You can view a full list of Authorised Representatives here.

How can TBA Ecofuture help my business?

This is what you can expect from TBA Ecofuture:

• Quality services supported by the TBA Global brand
• Industry leading expertise in Extended Producer Responsibility compliance
• Budget friendly options tailored to each individual business
• Professional and localised support through both TBA Globaland TBA Ecofuture 

What services will I have access to when I sign up for German EPR with TBA Global?

Our dedicated team will ensure your business follows all the necessary steps for compliance.

This includes:

• Acting as your local Authorised Representative (if your business is not already based in Germany)
• Registering your business with the relevant local authority for each required EPR category
• Enrolling your business with the appropriate Producer Responsibility Organisation where applicable
• Calculating your usage and filing the necessary declarations in a timely manner
• Ensuring that you pay the correct contribution fee
• Renewing your EPR registration(s) at the start of each calendar year

Our expert team will also be on hand to assist with any other EPR queries you may have – we’re dedicated to helping your business grow!

The information provided is correct at the time of writing – for up-to-date information, check with one of our experts.  We offer a free one-to-one consultation at info@tbaglobal.com.