from €2,999 net
The entry price applies from 10,000 kg. Higher annual quantities increase the fee.
Mandatory audit
Mandatory DIVID audit from 10,000 kg
The regular 10,000 kg audit threshold first applies to reporting year 2026, whose declaration is due through DIVID by 15 May 2027, including that date. At or above this quantity, a registered examiner must audit and confirm the declaration unless the statutory exemption for exclusively deposit-bearing beverage bottles applies. A UBA order may require an audit even where an exemption applies.
Included in the service
Audit planning, audit of the documents, structured clarification of audit-related questions, the audit report and QES confirmation.
The 10,000 kg threshold applies from 1 January 2027.
A lower threshold may apply to earlier periods. Manufacturers of exclusively the deposit-bearing beverage bottles specified by law may be exempt from the regular audit regardless of quantity. The UBA may require an individual audit even where an exemption applies. We clarify the period, product categories and reason for the audit before engagement.
Threshold and scope
When does a DIVID quantity declaration require an audit?
Under section 11 EWKFondsG, the audit obligation is based on the total mass of covered single-use plastic products first made available on the German market or sold directly into Germany during the preceding calendar year.
Turnover and the number of product lines are not decisive. The relevant mass across all covered product categories is added together. The 10-tonne threshold concerns only the regular external audit; registration, reporting and levy obligations may still apply below it.
From 2024 to the 10-tonne threshold
The levy obligations under the Single-Use Plastics Fund Act have applied since 2024. Because quantities are reported in the following year, the reporting year and the filing year must be distinguished.
Reporting year 2024 · filing 2025
The first declaration covered quantities placed on the market or sold in 2024. For the 2025 filing, the UBA exceptionally accepted all declarations without an external audit; an individual order remained possible.
Reporting year 2025 · filing 2026
For the declaration due by 15 May 2026, the statutory exemption still covered totals below 100 kg. A regular audit was generally required from 100 kg, subject to the separate exemption for exclusively deposit-bearing beverage bottles.
Reporting year 2026 · filing 2027
The amendment effective on 1 January 2027 raises the exemption to totals below 10,000 kg. For 2026 quantities, a regular audit is therefore generally required at exactly 10,000 kg or more, subject to the statutory exemption for exclusively deposit-bearing beverage bottles.
UBA orders remain possible
Below the applicable threshold, the German Environment Agency may still require verification and confirmation in an individual case. The specific order determines the scope and deadline.
In short: the 10,000 kg threshold first applies to quantities from calendar year 2026 because that declaration is filed in 2027.
Why does the Single-Use Plastics Fund Act exist?
The Act implements extended producer responsibility for certain single-use plastic products in Germany. Producers contribute to the follow-up costs caused by these products as waste in public spaces, including collection, cleaning, disposal, waste advice and awareness measures, depending on the product category.
The levy is paid into a fund administered by the UBA. Municipalities and other eligible public bodies receive reimbursements for covered services. Costs previously borne mainly by the public are therefore allocated to the relevant product groups and their producers.
Why foreign companies may also be affected
The Act is not limited to companies established in Germany. A foreign company may qualify as a producer when it sells covered single-use plastic products directly to private households or other users in Germany by distance communication. The specific supply chain, producer status and product classification are decisive.
In each example below, a regular audit for reporting year 2026 arises if the company's total relevant mass reaches at least 10,000 kg. Each product must still be assessed against the statutory criteria.
1 · Beverage cups made in Germany
A German company manufactures single-use beverage cups containing plastic and first places them on the German market. Once the relevant annual mass reaches the threshold, its DIVID declaration requires audit.
2 · Ice-cream containers from Italy
A German company imports single-use plastic food containers for ice cream from Italy and first markets them in Germany. Its role, the product classification and the relevant mass must be reflected in the declaration.
3 · Wet wipes from France
A French company sells wet wipes directly to end users in Germany by distance selling. It may thereby trigger producer obligations even without a German establishment.
4 · Chocolate from Switzerland
A Swiss chocolate producer sells ready-to-eat products in covered bags and film packaging directly into Germany. If the packaging meets the statutory criteria, its mass is included in the DIVID declaration.
Request an audit
Enquire about your DIVID audit.
Provide your company name, country, reporting year, approximate total quantity and reason for the audit. Use the enquiry form when available or email info@taxora-steuerberatung.de.
Prepare an enquiryNon-binding · An engagement begins only after the offer has been accepted.