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Important Update: Germany Introduces EPR for Single-Use Plastics in 2025
New EPR Category in Germany: Single-Use Plastics (SUPs) – Effective from January 1, 2025
Starting January 1, 2025, Germany will introduce a new Extended Producer Responsibility (EPR) category for Single-Use Plastics (SUPs). This requirement is based on the Single-Use Plastics Fund Act (EWKFondsG) and will complement the existing three categories: Packaging, Batteries, and WEEE.
Key Dates:
SUP regulation effective date: January 1, 2025
Registration for non-German businesses opens: August 2024
EPR laws make producers — including manufacturers, brand owners, and re-sellers — responsible for the full lifecycle of their products, including waste management and disposal. This is typically managed through contribution fees
– more information can be found here.
What Counts as a Single-Use Plastic (SUP)?
Products are considered to be SUPs if:
- They are made entirely or partly out of plastic, and
- Are not designed or developed to be used multiple times (such as not being designed for returning to the manufacturer/distributor for refilling, or re-used by consumers)
Here are some examples:
Food containers | Containers designed to store food to be consumed immediately and without any further preparation required, such as takeaway dishes |
Beverage/drinks cups | Lids and closures for beverage containers |
Beverage containers (<3 litres) | Plastic containers used to hold liquids up to 3 litres |
Wet wipes | Soaked wipes containing plastic |
More information is available from the German Environment Agency (DIVID) here. If you are not sure whether your product is categorised as an SUP, you can find out more here.
Additional SUP categories will also be introduced in the future. For example, fireworks are scheduled to be included from 2026 onwards.
Who Must Register?
This is line with other EPR regulations currently enforced in Germany – if you are designated as a ‘producer’ of SUPs, you will need to register. This includes businesses who are selling goods containing SUPs to customers based in Germany, even if they are not the original manufacturer.
Next Steps for Overseas Sellers
If your business is located outside Germany:
You must appoint an Authorised Representative to complete the registration.
Online marketplaces like Amazon, eBay, Etsy, and Zalando will be obligated to verify your SUP compliance status from January 1, 2025.
After registration, you’ll need to report sales and pay contribution fees based on the quantity of SUPs sold — similar to other EPR categories.
Registration for non-German businesses will not be available until August 2024, but you can register your interest now at info@tbaglobal.com.
