DIVID quantity declarations and audits: frequently asked questions

The regular audit threshold of 10,000 kg first applies to reporting year 2026, whose declaration is due by 15 May 2027, including that date. Exactly 10,000 kg reaches the threshold. For earlier periods, the reporting and filing years must be distinguished. The separate exemption for exclusively deposit-bearing beverage bottles and any UBA order must be considered independently of quantity.

Further information · Official sources: EWKFondsG § 11 · UBA · DIVID

The annual quantity declaration is generally due through DIVID by 15 May of the following year, including that date. For 2026 quantities, the deadline is therefore 15 May 2027. If an audit is required, the audit report and confirmation bearing a qualified electronic signature must accompany the filing. Requesting or commissioning an audit does not extend the deadline; any different official deadline must be considered individually.

Further information · Official sources: EWKFondsG § 11

A manufacturer that first supplied or sold exclusively the deposit-bearing beverage bottles specified in section 11(4) EWKFondsG during the relevant calendar year has a separate exemption from the regular audit and confirmation requirement. This applies independently of the quantity threshold. It must not be extended to all beverage containers or mixed product ranges. The UBA may still require an audit in an individual case.

Further information · Official sources: EWKFondsG § 11

The reporting year is the calendar year in which the relevant products were first supplied in Germany or sold directly into Germany. The declaration is filed in the following year. Quantities from 2026 are therefore declared in filing year 2027. Audit thresholds, data boundaries and deadlines must be assessed in that context; the upload year alone does not identify the quantities reported.

Further information · Official sources: EWKFondsG § 11

For the first declaration of 2024 quantities, the UBA exceptionally waived regular external audits in 2025; individual orders remained possible. For reporting year 2025, filed in 2026, the quantity exemption covered totals below 100 kg. Exactly 100 kg was not covered. The separate exemption for exclusively deposit-bearing beverage bottles and any UBA order must also be considered.

Further information · Official sources: UBA · DIVID · EWKFondsG § 11

No. Exemption from the regular external audit is not a general exemption from the EWKFondsG. Depending on the manufacturer role and products, registration, annual quantity reporting and the levy may still be required. A small quantity must therefore not be equated with having no obligations. The UBA may also require an individual audit and confirmation despite a regular audit exemption.

Further information · Official sources: EWKFondsG § 11

Yes. The UBA may require an audit and confirmation even where a declaration would otherwise be exempt. The specific order, reporting year, requested records and deadline determine the requirements. An order does not automatically mean the declaration is incorrect. For engagement planning, provide the complete notice and the corresponding reporting data.

Further information · Official sources: EWKFondsG § 11

Covered fireworks have separate transitional rules. Manufacturers already active before 2026 must observe the registration requirements in section 29 EWKFondsG by the end of 2026. The first levy relates to calendar year 2027; the first quantity declaration is due by 15 May 2028, including that date. This deadline must not be confused with declarations of other product categories for 2026.

Further information · Official sources: EWKFondsG § 29 · EWKFondsG · Anlage 1

DIVID is the German Environment Agency’s digital platform for the Single-Use Plastics Fund. It handles manufacturer registration and annual quantity declarations, among other procedures. The EWKFondsG makes manufacturers of specified single-use plastic products contribute to the costs those products cause as waste in public spaces. Registration, quantity reporting, the levy and external audit are separate obligations with their own conditions.

Further information · Official sources: UBA · DIVID

The statutory manufacturer role matters, not merely the business’s industry label. Relevant factors include who first commercially supplies covered products in Germany or sells them directly from abroad to users in Germany. Imports, own brands, contract manufacturing and intra-group supplies require an assessment of the actual supply and distribution structure. Not every retailer or brand owner is automatically the manufacturer responsible for reporting.

Further information · Official sources: EWKFondsG § 3

Yes. Manufacturer obligations can arise without a German establishment, particularly when covered products are sold directly by distance communication to households or other users in Germany. Whether the foreign business, an importer or another party is the manufacturer depends on the actual distribution route. A foreign registration or declaration in another country does not replace an assessment of German obligations.

Further information · Official sources: EWKFondsG § 3

Annex 1 covers specified food containers, food-containing packets and wrappers, beverage containers up to three litres, beverage cups, lightweight plastic carrier bags, wet wipes, balloons and tobacco filter products. Plastic-containing fireworks have separate transitional rules. Not every package or plastic product is covered: material, single-use character, intended use and precise statutory product criteria matter. Products with plastic coatings may also require classification checks.

Further information · Official sources: EWKFondsG · Anlage 1

Quantity calculation generally uses the mass of the covered single-use plastic product, not merely its plastic component. This matters particularly for composite materials and plastic-coated products. The relevant product boundary and product-category classification must be documented transparently. Unit counts alone are insufficient for a declaration in kilograms; reliable product weights and a traceable calculation method are needed.

Further information · Official sources: UBA · Prüfleitlinien 2026

No. DIVID duties under the EWKFondsG must be distinguished from other registration, participation and reporting requirements. A product or business can fall under several regimes. Auditing the DIVID declaration does not automatically mean all packaging, EPR or other environmental obligations have been checked or met. The commissioned scope is expressly defined.

Further information · Official sources: UBA · DIVID

A standard remote audit usually takes three to five working days once all required records are available. Company size, data volume and outstanding questions influence the actual process, so this is not a blanket deadline guarantee. Where a UBA order or filing deadline is approaching, timing and available capacity should be expressly agreed before engagement.

Further information

The audit must be carried out by a person registered under the statutory requirements, such as an appropriately registered tax adviser, auditor, sworn accountant or expert. The professional title alone is insufficient. The applicable UBA audit guidelines must also be followed. At TAXORA, the registered examiner retains personal professional responsibility, while the firm team coordinates records and follow-up questions.

Further information · Official sources: EWKFondsG § 11

QES means qualified electronic signature. The legally required audit confirmation must bear the examiner’s qualified electronic signature. A scanned signature image or ordinary electronic signature is not equivalent. The current DIVID template and the portal’s technical requirements must be followed for filing.

Further information · Official sources: EWKFondsG § 11

Typical records include product lists with materials and weights, quantity schedules for the reporting year, ERP, inventory or sales data, and suitable supporting documents such as invoices and delivery notes. Depending on the case, evidence for exports, returns and exclusions and DIVID registration data is also needed. Records must reconcile to the declared quantity. A case-specific checklist follows engagement.

Further information · Official sources: UBA · Prüfleitlinien 2026

We first clarify the business, reporting year, audit reason and approximate quantity and prepare an offer. After engagement, we request records, conduct the audit and coordinate follow-up questions. You provide the current DIVID confirmation template. On completion, you receive the report and QES confirmation; a closing discussion is available on request. You make the final portal filing as manufacturer.

Further information

Many engagements can be handled remotely using digital records and structured data. Whether this is sufficient depends on the evidence, scope and applicable audit guidelines. Necessary on-site procedures must remain possible and are agreed and quoted separately. Digital cooperation does not replace complete evidence or the company’s required participation.

Further information · Official sources: UBA · Prüfleitlinien 2026

The firm team groups audit-related questions and coordinates them with the responsible contacts. Clarification may take place in writing, by telephone or by video call. Differences between product master data, ERP reports and the declared total are documented transparently. Professional responsibility remains with the registered examiner. Complete, coordinated replies help avoid repeated clarification rounds.

Further information

The report documents the audit performed and its outcome. The confirmation is a separate document completed under the prescribed requirements and signed with a qualified electronic signature for DIVID. Where an audit is required, both accompany the quantity declaration. An offer, invoice or simple acknowledgement of receipt replaces neither document.

Further information · Official sources: EWKFondsG § 11

The manufacturer files the final quantity declaration and required audit documents through DIVID. TAXORA provides the agreed audit documents; you retain control of your portal access and check the data to be uploaded. Where an authorised representative is involved, the statutory and technical allocation of roles must be considered separately. An audit engagement alone does not automatically transfer portal access or reporting responsibility to TAXORA.

Further information · Official sources: EWKFondsG § 11 · UBA · Prüfleitlinien 2026

Yes. TAXORA works throughout the year and accepts late engagements where possible and subject to available capacity. Provide the original deadline and any UBA correspondence promptly. Acceptance of an audit does not remedy a missed deadline or guarantee any particular official decision. The manufacturer remains responsible for accurate and timely reporting.

Further information

Indicative fees start at €599 net for a voluntary audit, €999 net for an audit following a UBA order and €2,999 net for a regular mandatory audit from 10,000 kg. The fee depends on scope and annual quantity; you receive an individual fixed-fee offer before engagement. Express audits are available subject to capacity for an additional €999 net. On-site visits are quoted separately.

Further information

A voluntary audit can help with complex quantity calculations, internal control requirements or evidence requested by business partners, even when no regular statutory audit is required. Its objective, scope and documentation are agreed in advance. It does not replace correct product classification or existing reporting obligations and does not change statutory deadlines.

Further information

Yes. Options include a complete, defined DIVID audit engagement, specialist support behind the scenes or coordinated joint handling. Existing client relationships remain in place; scope, responsibilities and communication are agreed beforehand. For multiple companies, manufacturer status, registration and reporting duties must be assessed for each relevant legal entity. Quantities must not be pooled merely because companies share a brand.

Further information

Professional correspondence and coordination are conducted in German or English. The Spanish, Italian and French website versions provide accessible guidance and describe the same service scope. For foreign-language or extensive overseas data, we agree the format and necessary explanations case by case. A translated website is not a promise of a complete service in that language.

Further information

When form delivery is available, your entries are forwarded through the IONOS web server by email to info@taxora-steuerberatung.de. Confirmation appears only after acceptance by the mail server and does not guarantee final delivery. You can fill in the form. If sending is unavailable, an error appears after you attempt to submit and your entries remain on the page. Please contact us directly by email. Submitting does not create an engagement. Please do not submit tax records or particularly confidential data.

Further information