According to Euwid, 15 economic and industry associations are pushing for a suspension of testing requirements for manufacturers under the Single-Use Plastics Fund Act (EWKFondsG).

As reported by Euwid, the associations, including the German Trade Association (HDE), the Industry Association for Paper and Film Packaging and the IK Industry Association for Plastic Packaging, warn in their joint statement of disproportionate bureaucracy, significant additional costs and competitive disadvantages, especially for small and medium-sized enterprises. They are therefore appealing to politicians to permanently suspend the testing requirement. In addition, they say, the scope of application of the EWKFondsG must be clarified.
 
In the opinion of the signatories, the obligation set out in Paragraph 11 (1) sentence 2 EWKFondsG to have quantity reports audited by registered experts or auditors goes beyond the requirements of the underlying EU Single-Use Plastics Directive. The responsible Umweltbundesamt (UBA, Federal Environment Agency) had suspended the audit requirement for the 2024 reporting year. In the opinion of the associations, this should apply permanently. The reason given for this request is that, according to the associations' estimates, the low audit threshold of 100 kilograms per year would mean that around 80 per cent of the companies subject to the obligation – predominantly small and micro-enterprises – would be subject to auditing. However, the costs of the audit would in many cases far exceed the actual special levy, they say. For example, a company with a reported quantity of around 350 kilograms would have to pay 3,000 to 9,000 euros in audit costs, compared to a fund levy of only around 100 to 200 euros. In addition, many approved auditors were already working at full capacity and were turning down new orders, making it difficult to fulfil legal obligations on time. The audit requirement thus acted as a barrier to market entry and led to distortions of competition at the expense of small businesses, according to the alliance of associations.
 
Sources:

• euwid-recycling.de (20.1.2026)
• Photo: © Agenlaku Indonesia / Unsplash (Symbolbild)