Fireworks and the EWKFondsG: New obligations for manufacturers, importers, and distributors from 2026

Manufacturers and importers of fireworks must prepare for new obligations under the Single-Use Plastics Fund Act (Einwegkunststofffondsgesetz - EWKFondsG). Plastic-containing fireworks have been added to the list of single-use plastic products covered by the EWKFondsG. This creates new requirements for registration with DIVID, determining the quantities placed on the market in Germany, the single-use plastic levy, and – from a certain annual quantity – the audit of the quantity report according to § 11 EWKFondsG.

Not only traditional fireworks manufacturers may be affected. German fireworks importers, pyrotechnic wholesalers, online retailers, private labels, foreign fireworks suppliers, and companies that sell New Year's Eve fireworks directly to Germany should now review their supply chains and product data.

Particularly important: The term "manufacturer" is defined by the Single-Use Plastics Fund Act and is broader than in common parlance. Anyone who imports fireworks from China, Poland, or another country into Germany and places them on the market there for the first time can be considered a manufacturer within the meaning of the EWKFondsG – even if the company does not produce a single firework itself.

In this article, you will learn which fireworks may be affected by the EWKFondsG, how plastic components are assessed, who is responsible as a manufacturer or importer, what deadlines apply, and how DIVID-Mengenmeldung can support you in preparing and carrying out the legally required audit.

Why are fireworks covered by the EWKFondsG?

The Single-Use Plastics Fund Act aims to involve manufacturers of certain single-use plastic products in the costs incurred in public spaces by discarded or abandoned product waste. This particularly includes cleaning measures, awareness-raising measures, data collection, and the administration of the single-use plastics fund.

Especially after New Year's Eve, parts of rockets, firework batteries, bangers, fountains, and other firework articles often remain on streets, sidewalks, squares, green areas, and parks. If the fireworks used contain plastic parts, these residues can remain in the environment as single-use plastic waste.

The legislator has therefore included fireworks as a separate product type in Annex 1 Number 9 EWKFondsG. Manufacturers are to contribute to the costs of cleaning, awareness-raising, data collection, and administration in the future.

However, the regulations do not mean a general ban on fireworks. The EWKFondsG is rather a system of extended producer responsibility. Manufacturers and importers must register, report their quantities, and pay a quantity-dependent single-use plastic levy.

Which fireworks are affected by the EWKFondsG?

Annex 1 Number 9 EWKFondsG refers to fireworks within the meaning of § 3 Paragraph 1 Number 4 of the Explosives Act. There, fireworks are defined as pyrotechnic articles for entertainment purposes.

This generally includes fireworks of the categories:

• F1: Fireworks presenting a very low hazard,
• F2: Fireworks presenting a low hazard for use in confined outdoor areas,
• F3: Fireworks presenting a medium hazard for use in large open outdoor areas,
• F4: Fireworks presenting a high hazard, which may only be used by persons with specialist knowledge.

However, the respective category alone does not yet determine whether a single-use plastic levy actually arises. In addition, the firework must consist entirely or partially of plastic and be classifiable as a single-use product.

Typical fireworks that should be checked

Depending on the design and material composition, the following articles, in particular, may be affected:

• New Year's Eve rockets and firework rockets,
• Firework batteries and composite fireworks,
• Compound fireworks and firework combinations,
• Bangers, crackers, and cannon shells,
• Fountains and volcanoes,
• Roman candles,
• Catherine wheels and suns,
• Bomb tubes and single shots,
• Ground fireworks and luminous fireworks,
• Small fireworks and youth fireworks of category F1,
• Professional fireworks of categories F3 and F4.

This list does not mean that every item mentioned is automatically subject to levy. The decisive factors are the specific explosives law classification, the material composition, and whether the individual firework contains plastic.

Are T1, T2, P1, and P2 articles also affected?

Not every pyrotechnic article is legally a firework. Explosives law distinguishes between:

• Fireworks of categories F1 to F4,
• Pyrotechnic articles for stage and theatre of categories T1 and T2,
• Other pyrotechnic articles of categories P1 and P2.

Annex 1 Number 9 EWKFondsG explicitly mentions fireworks within the meaning of the Explosives Act. Products of categories T1, T2, P1, or P2 are therefore not covered solely because they are colloquially referred to as fireworks or pyrotechnics.

For correct classification, companies should check the CE marking, product category, registration number, technical documents, and manufacturer documentation. In case of doubt, a binding product classification by the Federal Environment Agency according to § 22 EWKFondsG can be useful.

When is a firework considered a single-use plastic product?

A single-use plastic product according to the EWKFondsG is a product that consists entirely or partially of plastic and is not designed for multiple product cycles, refilling, or reuse for the same purpose.

Fireworks are intended for single use. The main decisive factor is, therefore, whether the firework itself contains a plastic component.

Possible plastic components can – depending on the respective design – include, for example:

• Plastic caps and protective caps,
• Plastic sleeves or housing parts,
• Plastic bases and stands,
• Plastic holders,
• Connecting or spacing elements,
• Plastic rods or plastic guides,
• Integrated plastic films,
• Cable ties or fixed plastic connection elements,
• Components of ignition or connection systems.

Whether a specific component belongs to the firework must be assessed based on the product, its design, and the technical documentation.

Is there a minimum plastic content?

No. According to current auditing guidelines, there is no general threshold for plastic content. Even small plastic components can lead to a firework being classified as a single-use plastic product.

Only paints, inks, and adhesives are not considered decisive plastic components according to current administrative practice. If, on the other hand, a firework consists, for example, of cardboard and paper, but also contains an integrated plastic cap or a plastic stand, this component alone can be relevant for classification.

Manufacturers and importers should therefore not rely on a purely visual assessment. A firework can consist predominantly of paper, cardboard, wood, clay, or pyrotechnic composition and still fall under the EWKFondsG due to a small integrated plastic part.

What applies to completely plastic-free fireworks?

If the firework itself does not actually contain plastic within the meaning of the EWKFondsG, it is generally not a single-use plastic product. The mere inclusion of the product type "fireworks" in Annex 1 is not sufficient if the specific product is completely plastic-free.

However, the claim "plastic-free" should be verifiable with reliable documents. Suitable documents may include, in particular:

• Bills of materials or material lists,
• Technical product data sheets,
• Material declarations from the producer,
• Supplier declarations,
• Design drawings,
• Test reports or material analyses,
• Documentation for individual components.

Firework or sales packaging: What counts?

For manufacturers and importers, the distinction between the actual firework and its packaging is particularly important.

The EWKFondsG covers the firework itself in Annex 1 Number 9. A plastic film, shrink wrap, carrier bag, or plastic packaging in which a firework article is sold or transported does not automatically make the firework contained therein a plastic-containing firework.

Example: Firework battery in shrink wrap

A firework battery consists entirely of cardboard, paper, clay, and pyrotechnic components. Only a removable plastic film serves as sales packaging around the battery.

In this case, a separate assessment must be made:

• Is the plastic film merely packaging?
• Is it a fixed or functional component of the firework?
• Does the firework battery itself contain further plastic components?

Pure sales or transport packaging is regularly subject to the provisions of the Packaging Act. It is not treated as part of the firework under Annex 1 Number 9 EWKFondsG solely for this reason.

Example: Integrated plastic cap

If a firework rocket has a plastic cap that is part of the firework's design, it is not merely an outer sales packaging. The plastic is then part of the product and can trigger classification as a single-use plastic product.

What weight must be reported for fireworks?

One of the most important questions for fireworks manufacturers and importers is:

Is only the weight of the plastic parts or the weight of the entire firework reported?

According to the current auditing guidelines of the Federal Environment Agency, the entire single-use plastic product must generally be weighed. Not just the individual component with plastic content is taken into account.

If, for example, a firework battery contains a relevant plastic component and is thus classified as a single-use plastic product, the weight of the entire firework battery is generally decisive – not just the weight of the plastic cap, the plastic base, or a connecting element.

Example of quantity calculation

An importer places a total of 10,000 identical firework batteries on the market in Germany for the first time in the calendar year 2027.

• Weight of a complete battery: 1.4 kg
• Of which plastic components: 18 g
• Quantity sold: 10,000 pieces

If the battery is classified as a single-use plastic product according to Annex 1 Number 9 due to its plastic components, the total product weight is generally decisive for the quantity calculation:

10,000 pieces × 1.4 kg = 14,000 kg single-use plastic products

It would not be merely 180 kg of plastic content.

This example shows why correct product classification can have significant economic implications for manufacturers and importers.

May fireworks be opened for weight determination?

Fireworks may not be opened, dismantled, or manipulated uncontrollably. All explosives law and safety requirements must be complied with when determining product weights.

For master data determination, the following can be used, among others:

• Manufacturer's information on the complete product weight,
• Technical product data sheets,
• Bills of materials and specifications,
• Lawfully and professionally conducted control weighings,
• Weighing protocols,
• Documents from independent experts.

The weight determination should be documented transparently. Companies should secure retained samples and product documents early, as fireworks are a seasonal assortment with frequent item changes.

Who is considered a manufacturer of fireworks under the EWKFondsG?

The term "manufacturer" under the EWKFondsG is not synonymous with the actual producer or factory. A manufacturer can also be an importer, seller, or foreign distance seller.

It is particularly crucial who first commercially places the plastic-containing firework on the German market or sells it directly from abroad to users in Germany.

German Fireworks Producer

A company produces plastic-containing New Year's Eve rockets in Germany and sells them for the first time to wholesalers or retailers. The company is generally a manufacturer within the meaning of the EWKFondsG.

German Fireworks Importer

A German company imports firework batteries from China and makes them available for the first time in Germany to wholesalers, hardware stores, discounters, or online retailers. In this typical constellation, the German importer is regularly a manufacturer under the EWKFondsG.

Private Labels and Own Brands

A trading company has fireworks articles produced abroad and distributes them in Germany under its own brand. Who is the manufacturer under the EWKFondsG depends on the specific supply and distribution structures. Often, the company that imports the goods and makes them available in Germany for the first time is responsible.

German Retailer

A retailer obtains fireworks from an already properly registered German manufacturer or importer. The retailer is generally not a manufacturer simply by reselling them. However, they must check whether the products come from a registered manufacturer.

Online Retailers and Marketplace Sellers

Sellers on online marketplaces or in their own fireworks online shops can also be affected. Particularly relevant is whether they import goods themselves from abroad or ship directly from a foreign warehouse to German end-users.

EWKFondsG for foreign fireworks manufacturers and retailers

The Single-Use Plastics Fund Act (EWKFondsG) applies not only to companies based in Germany. Foreign manufacturers and retailers can also be directly obligated.

A company without a branch in Germany is considered a manufacturer, especially if it sells plastic-containing fireworks directly to private households or other users in Germany via remote communication means.

Remote communication means can include, for example:

• its own online shop,
• an electronic marketplace,
• a sales platform,
• email orders,
• telephone orders,
• other distance selling systems.

The regulation can cover sales to private consumers as well as direct sales to commercial or professional users in Germany.

Authorised representative for foreign manufacturers

Manufacturers without a branch in Germany must generally appoint an authorised representative. This representative takes on the duties assigned to them under the EWKFondsG in Germany.

However, registration and the annual quantity report remain the responsibility of the foreign manufacturer themselves. They cannot be fully transferred to the authorised representative.

For foreign fireworks manufacturers who started their activities before January 1, 2026, the law provides a transitional period until December 31, 2026, for the appointment of an authorised representative.

EWKFondsG Fireworks: All important deadlines from 2026 to 2028

Special transitional rules apply to fireworks. Manufacturers and importers should carefully distinguish between the individual dates.

What applies to companies starting operations only in 2026?

The transitional period until December 31, 2026, applies to manufacturers who started their activities before January 1, 2026.

A company that begins manufacturing, importing, or directly selling plastic-containing fireworks only from 2026 onwards should generally register before starting operations and observe the requirements for an authorized representative.

Sales ban from 2027

From January 1, 2027, fireworks from a non-duly registered manufacturer may generally not be first placed on the market or sold.

The law is not only aimed at the manufacturer. Other parties in the distribution chain are also included:

• Retailers may not offer products from an unregistered manufacturer for sale.
• Operators of electronic marketplaces may not enable such offers.
• Fulfillment service providers may not provide their services for such products.

Fireworks retailers should therefore check in good time before the 2027 sales season whether their suppliers and brands are duly registered in the DIVID manufacturer register.

How high is the single-use plastic levy for fireworks?

The single-use plastic levy is generally calculated from the reported mass of single-use plastic products and the levy rate set for the respective product type.

For fireworks, the specific levy rate according to § 14 EWKFondsG must be determined by statutory ordinance by December 31, 2026.

Therefore, as of July 2026, a calculation with an estimated or unofficial euro amount per kilogram should not yet be made. Manufacturers and importers should await the final amendment of the Single-Use Plastics Fund Ordinance and simultaneously prepare their product and quantity data.

Regardless of the levy amount yet to be determined, it is already clear today that quantity calculation can be complex for many companies. This is especially true for extensive assortments, frequently changing seasonal items, and imported goods with incomplete material data.

Audit obligation for fireworks under § 11 EWKFondsG

Manufacturers must report their annual quantities by type and mass in kilograms to the Federal Environment Agency via the DIVID platform.

From a total quantity of 100 kilograms or more of single-use plastic products according to Annex 1 EWKFondsG, the quantity report must generally be audited and confirmed by a registered auditor.

The limit does not refer exclusively to fireworks. All product types according to Annex 1 provided or sold by the manufacturer in the reference year are added together.

Example: Fireworks only

An importer places a total of 8,000 kg of plastic-containing fireworks on the market in Germany for the first time in 2027. The quantity report for 2027 must be submitted by May 15, 2028, and audited and confirmed by a registered auditor.

Example: Fireworks and other single-use plastic products

A trading company places the following quantities on the market in Germany for the first time in 2027:

• 70 kg of plastic-containing fireworks,
• 40 kg of lightweight plastic carrier bags.

The total quantity is 110 kg. Although the fireworks alone are under 100 kg, there is generally an audit obligation because the total quantity of all product types according to Annex 1 reaches at least 100 kg.

What applies below 100 kg?

Anyone who made available or sold a total of less than 100 kg of single-use plastic products according to Annex 1 in the previous calendar year is generally exempt from the regular audit and confirmation obligation.

However, the quantity report itself may still be required. In addition, the Federal Environment Agency may also order an audit in individual cases below the 100 kg limit.

Who is allowed to audit the quantity report?

The audit may only be carried out by a person registered for this purpose. These include:

• registered experts,
• duly registered auditors,
• duly registered tax advisors,
• duly registered sworn auditors.

The auditor must be entered in the relevant auditor register of the Central Agency for Packaging Register. After successful auditing, they prepare the legally required audit report and audit confirmation. The confirmation must be provided with a qualified electronic signature.

What documents do fireworks manufacturers need for the audit?

Auditing a fireworks quantity report requires more than a simple list of sold items. The auditor must be able to trace which products are subject to the levy, how product weights were determined, and whether the reported quantities are complete.

Depending on the company structure, the following documents, in particular, may be required:

• complete item list of the fireworks assortment,
• article numbers, GTIN, and brand names,
• explosives law categories F1, F2, F3, or F4,
• CE marking and registration numbers,
• product data sheets and technical specifications,
• material and bill of materials,
• declarations from foreign producers regarding plastic components,
• complete product weights,
• weighing protocols or verifiable manufacturer information,
• purchase invoices and import documents,
• customs documents,
• goods receipt and inventory data,
• sales and outgoing invoices,
• evaluations from merchandise management or ERP system,
• proof of returns, destruction, or goods not sold in Germany,
• distinction between exports and deliveries to other countries,
• documentation of delivery and distribution channels.

Why supplier data alone is not always sufficient

For imported fireworks, only information on the net explosive mass, shipping mass, carton weight, or number of sales units is often available. However, for the EWKFondsG, the weight of the relevant single-use plastic product is required.

The following weight specifications should not be confused:

• net explosive mass or NEM,
• gross weight of the shipping carton,
• weight of the sales packaging,
• weight of individual plastic components,
• complete weight of the firework.

For the DIVID quantity report, the mass of the single-use plastic product is crucial. Manufacturers and importers should therefore clarify early on which weight information is stored in their master data.

Retention samples for seasonal items

The current audit guidelines explicitly refer to companies with frequent assortment changes and seasonal goods. Fireworks companies should therefore retain samples of relevant products, provided this is legally, safety-wise, and storage-wise permissible.

Since many fireworks items are no longer available after one season, missing samples can significantly complicate the subsequent verification of material, product components, and weights.

LUCID and DIVID for fireworks: What's the difference?

Many fireworks importers are already registered in the LUCID packaging register. However, this registration does not automatically cover the obligations under the Single-Use Plastics Fund Act.

LUCID and Packaging Act

The Packaging Act primarily concerns sales, shipping, secondary, and transport packaging. A fireworks importer may, for example, be responsible for cartons, plastic films, and other packaging filled with goods.

DIVID and Single-Use Plastics Fund Act

DIVID is the platform of the Federal Environment Agency for registration, quantity reporting, and processing of the single-use plastic levy according to the EWKFondsG. For fireworks, it concerns the plastic-containing firework as a product type according to Annex 1 Number 9.

A company can therefore simultaneously:

• be subject to registration in the LUCID packaging register,
• be required to participate packaging in a dual system,
• be required to register on DIVID as a manufacturer of fireworks,
• be required to submit an annual EWKFondsG quantity report,
• require an audit according to § 11 EWKFondsG.

Common errors with fireworks under the EWKFondsG

Error 1: Only the actual producer is considered a manufacturer

An importer, private label provider, or foreign direct seller can also be a manufacturer in the sense of the EWKFondsG.

Error 2: Small plastic parts are ignored

There is generally no minimum plastic content. Even small integrated plastic components can be relevant.

Error 3: Only the plastic content is weighed

According to the audit guidelines, the entire single-use plastic product should generally be weighed, not just the plastic component.

Error 4: Packaging and fireworks are mixed up

An outer sales film is not automatically part of the firework. Product and packaging must be assessed separately.

Error 5: The net explosive mass is used as the product weight

The NEM is not to be equated with the complete weight of the firework.

Error 6: T1, T2, P1, and P2 articles are reported collectively

Annex 1 Number 9 covers fireworks in the sense of the Explosives Act. Other pyrotechnic categories must be considered separately.

Error 7: Foreign direct sales are not considered

A company without a German domicile can also be a manufacturer if it sells directly to private or commercial users in Germany.

Error 8: Only the quantity of fireworks is considered

For the 100 kg audit threshold, all single-use plastic product types of the company are generally added together.

Error 9: Preparation only begins in 2028

The quantity report for 2027 must be based on reliable article master data and sales data. These should be set up before the start of the reference year.

What companies should prepare in 2026

1. Determine manufacturer role: Check who in your supply chain is considered a manufacturer under the EWKFondsG.
2. Perform DIVID registration: Observe the transitional period and register new activities in good time.
3. Clarify authorized representative: Foreign manufacturers should organize the legally required representation in Germany.
4. Classify assortment: Separate F1 to F4 fireworks from T and P products.
5. Obtain material data: Request binding information on all plastic components from producers and suppliers.
6. Check product weights: Store the complete weight of the respective firework.
7. Distinguish packaging: Differentiate between product components and sales or transport packaging.
8. Prepare inventory management: Record the quantities first placed on the market in Germany or sold directly to Germany.
9. Distinguish exports: Deliveries outside Germany must be demonstrably separated from German quantities.
10. Plan inspection process: If quantities are expected to be at least 100 kg, a registered auditor should be scheduled early.

EWKFondsG Audit for Fireworks Manufacturers with DIVID Quantity Reporting

The initial recording of fireworks presents manufacturers and importers with particular challenges. Product classification, material composition, total product weight, import quantities, returns, and seasonal assortment changes must be comprehensibly documented.

DIVID-Mengenmeldung specializes in organizing and preparing audits according to § 11 EWKFondsG.

Our services are aimed at, among others:

• Fireworks manufacturers,
• German fireworks importers,
• Pyrotechnics wholesalers,
• Fireworks online shops,
• Marketplace sellers and e-commerce companies,
• Private label and store brand providers,
• Foreign fireworks manufacturers,
• Foreign retailers with direct sales to Germany.

Our Services

• Structured checklists for your product and quantity data,
  
• Organizational preparation of audit documents,
• Plausibility check of the submitted data,
• Completely digital and confidential data transmission,
• Coordination of the audit by an independent, registered auditor,
• Provision of audit report and audit confirmation with QES,
• You will receive all documents you need for submission to DIVID

The statutory audit is carried out by one of our independent external auditors, who meets the legal requirements and is registered in the auditor register of the Central Agency Packaging Register.

How the Audit Process Works

1. You select the audit package that matches your annual quantity.
2. You receive access to a secure online form.
3. You submit your company, product, and quantity data.
4. The audit documents are prepared in a structured manner.
5. The registered auditor conducts the audit according to the applicable audit guidelines.
6. You receive the audit report and audit confirmation with a qualified electronic signature.

Frequently Asked Questions about Fireworks and EWKFondsG

Are fireworks covered by the Single-Use Plastics Fund Act?

Yes. Fireworks within the meaning of the Explosives Act have been listed in Annex 1 Number 9 EWKFondsG since January 1, 2026. Fireworks that consist wholly or partially of plastic are generally subject to fees.

When does a single-use plastic levy have to be paid for fireworks?

The first single-use plastic levy for fireworks concerns the quantities first made available in Germany or sold directly to Germany in the calendar year 2027. The levy will be determined for the first time in 2028.

When must the first quantity report for fireworks be submitted?

The first annual quantity report for fireworks must be submitted by May 15, 2028. The relevant quantities for the calendar year 2027 will be reported.

By when must fireworks manufacturers register with DIVID?

Manufacturers who were already active before January 1, 2026, must register by December 31, 2026, at the latest. New manufacturers must generally register before commencing their activities.

Does the EWKFondsG also apply to importers of fireworks?

Yes. Anyone who imports plastic-containing fireworks from abroad and places them on the market in Germany for the first time can be considered a manufacturer under the EWKFondsG.

Does the law also apply to fireworks imports from China?

Yes. The country of origin is not decisive for the general application of the EWKFondsG. A German importer of fireworks from China can be a manufacturer if he makes the products available in Germany for the first time.

Does the EWKFondsG also apply to foreign fireworks online shops?

Yes. A foreign company can be a manufacturer if it sells fireworks directly to private or commercial users in Germany via distance communication.

Does a foreign fireworks manufacturer need an authorized representative?

A manufacturer without a branch in Germany must generally appoint an authorized representative in Germany. However, registration and annual quantity reporting remain with the foreign manufacturer.

Which fireworks categories are affected?

Fireworks generally include categories F1, F2, F3, and F4. Whether a specific product falls under the EWKFondsG also depends on whether it contains plastic.

Are P1 or P2 articles automatically affected by the EWKFondsG?

No. P1 and P2 articles are other pyrotechnic articles and not automatically fireworks within the meaning of Annex 1 Number 9 EWKFondsG. The actual classification under explosives law is decisive.

Does the EWKFondsG also apply to stage fireworks of categories T1 and T2?

T1 and T2 products are pyrotechnic articles for stage and theater and are not automatically fireworks according to Annex 1 Number 9. The exact classification of the product is decisive.

Is a small plastic content sufficient?

Yes. In principle, there is no general minimum plastic content. Even small integrated plastic components can be sufficient. Paints, inks, and adhesives are excluded according to current audit guidelines.

Does the plastic film around a fireworks battery count as part of the fireworks?

Not necessarily. If the film is merely a removable sales or transport packaging, it must be assessed separately from the actual fireworks. If, on the other hand, it is an integrated functional product component, the assessment may be different.

Is only the plastic weight reported?

No. According to current audit guidelines, the entire single-use plastic product must generally be weighed. If a fireworks item is classified as a single-use plastic product due to a plastic component, its total product weight is therefore generally decisive.

Is the net explosive content relevant for the DIVID report?

No. The net explosive mass is not to be equated with the full weight of the fireworks. For quantity reporting, the weight of the single-use plastic product must be correctly determined.

From what quantity is an audit required?

From a total quantity of 100 kg of single-use plastic products according to Annex 1 in the calendar year, the report is generally subject to audit. For exactly 100 kg, the regular audit requirement already applies. Only quantities totaling less than 100 kg are generally exempt.

Who is allowed to audit the fireworks quantity report?

The audit may be carried out by registered experts and correspondingly registered Wirtschaftsprüfer (auditors), Steuerberater (tax advisors) or vereidigte Buchprüfer (sworn auditors).

Do I also need to register in LUCID?

This depends on the packaging sold and the company's role under the Packaging Act. However, an existing LUCID registration does not replace registration on DIVID.

What happens if a fireworks manufacturer is not registered?

From 2027, sales and offering bans can take effect. Retailers, electronic marketplaces, and fulfillment service providers are also generally not allowed to offer or support products from unregistered manufacturers.

What fines are imminent?

Depending on the type of violation, fines of up to 100,000 euros can be imposed. Sanctions can also arise from a quantity report that has not been submitted, has been submitted incorrectly, incompletely, or not in time.

Conclusion: Fireworks Manufacturers and Importers Should Use 2026 for the 2027 Quantity Report

With the inclusion of fireworks in the Single-Use Plastics Fund Act, a new compliance area is emerging for the fireworks and pyrotechnics industry.

Affected companies will not only have to clarify whether their products contain plastic. They must also determine the manufacturer's role within the supply chain, register with DIVID in good time, record complete product weights, and document their German annual quantities in a comprehensible manner.

Particularly relevant is the requirement that for a fireworks item classified as a single-use plastic product, the entire product weight is generally reported. Even a small plastic content can therefore have significant effects on the reported mass and the subsequent single-use plastic levy.

German importers, foreign direct sellers, fireworks online shops, and private label providers should therefore not wait until spring 2028. The data required for the first quantity report will already arise during the calendar year 2027 and must be recorded correctly from the outset.

DIVID-Mengenmeldung supports you in the structured preparation of your documents and organizes the legally required audit by an independent, registered auditor.

Note: This article provides a general overview of legal and administrative practice as of July 2026. It does not replace individual legal advice or binding product or manufacturer classification. For fireworks that cannot be clearly classified, an application for determination under § 22 EWKFondsG may be necessary. DIVID-Mengenmeldung is an independent service provider and not the official single-use plastics fund platform DIVID of the Federal Environment Agency.