The 500g Limit in the EWKFondsG: Which Food Packaging is Exempt from Fees

Since November 3, 2025, a significant 500g limit applies to the Single-Use Plastics Fund Act (EWKFondsG). This limit can determine whether certain food packaging falls under the EWKFondsG, needs to be included in the annual DIVID quantity report, and is relevant for calculating the single-use plastic levy.

However, this regulation does not apply to all packaging across the board. It specifically targets food containers as well as bags and film packaging containing food. Furthermore, the decisive factor is not the weight of the packaging, but the quantity of the food contained.

In this article, manufacturers, importers, online retailers, and trading companies will learn how the 500-gram limit works, what applies to a package weighing exactly 500 grams, how multi-packs should be handled, and what impact the new regulation may have on EWKFondsG quantity reporting and the statutory audit obligation.

What does the 500g limit mean for the EWKFondsG?

The EWKFondsG covers certain single-use plastic products whose manufacturers must contribute to the costs of collection, cleaning, waste management, and disposal. The product types listed in Annex 1 of the Act include, among others, certain food containers as well as bags and film packaging containing food.

For these two product types, the concept of immediate consumption plays a central role. Put simply, the aim is primarily to cover packaging whose contents can be consumed directly from the packaging or immediately after opening, without further preparation.

To standardize the distinction between a typical single portion and a larger bulk or family pack, a quantity threshold has been introduced:

If a food container or a bag or film packaging contains more than 500 grams of food, the contents are not considered to be intended for immediate consumption due to this quantity threshold.

The packaging in question is then not assigned to the corresponding product type according to Annex 1, number 1 or number 2 EWKFondsG. In principle, no single-use plastic levy is due for this packaging under these product categories. Therefore, an assessment is not necessary for these quantities.

When did the 500-gram threshold come into effect?

The 500g limit was published on the official Single-Use Plastics Fund platform DIVID on November 3, 2025. The current administrative regulation is dated March 23, 2026.

This date is particularly important for businesses. Product assessments, quantity calculations, and older blog posts from before November 2025 may still be based on earlier administrative practice and may not take the 500-gram threshold into account.

Manufacturers should therefore check whether their current article list is still correct. Under certain circumstances, larger packaging may have been treated as subject to fees, even though, according to current administrative practice, it no longer falls under the relevant product type due to a food content of more than 500 grams.

Which packaging is covered by the 500g limit?

The 500-gram limit applies exclusively to two product types under the EWKFondsG:

1. Food containers according to Annex 1, number 1 EWKFondsG
2. Bags and film packaging made of flexible material with food content according to Annex 1, number 2 EWKFondsG

Food containers

Food containers are typically rigid or partially rigid containers that hold food. These may include, for example:

• Salad bowls,
• Delicatessen cups,
• Dessert cups,
• Meal trays,
• Plastic containers,
• Trays for ready-to-eat meals,
• Paper-based containers with plastic coating.

For a food container to fall under the EWKFondsG in principle, several criteria must be met. The food must be intended for immediate consumption, usually consumed directly from the container, and consumable without further preparation such as cooking, frying, baking, or heating.

Bags and film packaging with food content

This category concerns flexible packaging whose shape changes when the contents are filled or removed. Typical examples include:

• Snack bags,
• Biscuit packaging,
• Film bags for confectionery,
• Packaging for crisps or nuts,
• Individual bar wrappers,
• Wrappers for chocolate or pastries,
• Film packaging for ready-to-eat baked goods.

Here too, it is crucial that the contained food can be consumed directly from the bag or film packaging and requires no further preparation.

For which products does the 500g limit not apply?

The 500g limit is not a general exemption limit for all single-use plastic products. In particular, it must not be applied to other product types under the EWKFondsG.

For example, the limit does not apply to:

• Beverage cups,
• Beverage containers,
• Lightweight plastic carrier bags,
• Wet wipes,
• Balloons,
• Tobacco products with plastic-containing filters,
• Separately marketed filters for tobacco products,
• Certain fireworks.

For beverage containers, for example, the law contains its own distinction based on filling volume. Beverage cups also constitute a separate product type. A beverage cup with a large content cannot therefore be excluded solely by reference to the 500g limit.

Which weight is decisive for the 500g limit?

A particularly common mistake is to refer the 500g limit to the weight of the packaging. This is incorrect.

The mass of the contained food is decisive. The weight of the plastic tray, the film, the lid, or a plastic coating does not determine whether the threshold is exceeded.

Example: Potato salad in a plastic tray

A package contains:

• 750 grams of potato salad,
• a plastic tray weighing 28 grams,
• a plastic lid weighing 7 grams.

For the 500g limit, the 750 grams of potato salad are decisive. Since the food content is more than 500 grams, the packaging is not classified as a food container according to Annex 1, number 1 EWKFondsG due to the quantity threshold.

However, for packaging that is generally subject to fees, the weight of the food is not reported for the subsequent DIVID quantity report. For the quantity report, the mass of the relevant single-use plastic product or packaging is decisive.

What applies to a pack weighing exactly 500 grams?

The administrative regulation expressly refers to a food content of more than 500 grams.

This results in the following distinction:

A blanket internal rule such as "exempt from 500 grams" would therefore be imprecise. The correct statement is: The exclusion only applies above 500 grams.

Are packs up to 500 grams automatically subject to fees?

No. Packaging with a food content of no more than 500 grams does not automatically fall under the EWKFondsG.

The 500g limit is merely an additional distinguishing criterion. Even for smaller packs, all legal requirements of the respective product type must still be checked.

For example, packaging may be outside the scope of the EWKFondsG despite having a content of less than 500 grams if:

• the food must be cooked before consumption,
• the food must be fried or baked,
• other significant preparation is required,
• the food is not usually eaten directly from the packaging,
• the packaging is not intended for single use,
• the product does not contain plastic,
• the product cannot be assigned to any product type from Annex 1 EWKFondsG.

Example: 400 grams of uncooked pasta

The package is below the 500g limit. Nevertheless, the film packaging generally does not fall under the corresponding product type, because the pasta must be cooked before consumption and is not eaten directly from the packaging.

Example: 400 grams of biscuits

The biscuits can be consumed directly from the film packaging without further preparation. Provided all other conditions are met, the packaging may fall under Annex 1, number 2 EWKFondsG.

Example: 750 grams of biscuits

Although the biscuits can be consumed immediately, the packaging contains more than 500 grams of food. Due to the quantity threshold, it is not treated as intended for immediate consumption and therefore does not fall under the relevant product type.

Practical examples of the EWKFondsG 500g limit

What applies to multiple individually wrapped portions?

Special attention is required for multipacks and bulk packs.

For example, if a sales package contains twelve individually wrapped bars in plastic film, each with 50 grams of content, the total weight of 600 grams must not simply be used to exempt all films from the levy.

Each individual wrapper can constitute a separate single-use plastic product. In this case, each individual packaging with its associated food content must be assessed separately.

This particularly concerns:

• Cereal bars,
• Chocolate bars,
• Individually wrapped biscuits,
• Sweets,
• Portioned pastries,
• Snack products,
• Collection boxes with individually wrapped single portions.

An outer cardboard box and several plastic films contained therein do not automatically form a single single-use plastic product with the total weight of all foods.

What applies to paper-based packaging with plastic coating?

Packaging does not have to consist entirely of plastic to be classified as a single-use plastic product. Packaging made of paper or cardboard can also be affected if, for example, it has a plastic coating or a plastic lining.

The 500g limit can therefore also be relevant for plastic-coated food containers.

A coated paper container with 750 grams of ready-to-eat food may be excluded due to the quantity threshold. For a content of 250 grams, however, the other requirements of the product type must be fully checked.

Special case: Empty food containers

For empty food containers provided on the German market, it is often not yet clear at the time of placing on the market what specific quantity of food will be filled in later.

According to the current administrative regulation, the 500g limit is initially not applicable to such empty food containers. The containers are generally considered to be subject to fees, provided the other requirements are met.

However, the manufacturer can prove in individual cases that the containers in question are actually filled with more than 500 grams of food.

This may concern, for example, the following products:

• Empty salad bowls,
• Takeaway boxes,
• Meal trays,
• Delicatessen containers,
• Ice cream containers,
• Plastic containers for ready-to-eat food.

The theoretically available filling volume alone may not always be sufficient for proof. Companies should document in a comprehensible manner that the containers are actually used for a food quantity of more than 500 grams.

Depending on the individual case, the following documents, among others, may be helpful:

• Product specifications,
• binding usage information,
• technical data sheets,
• labels or product descriptions,
• customer documents,
• proof of actual filling.

What impact does the limit have on the DIVID quantity report?

Food containers as well as bags and film packaging that are not classified as product types according to Annex 1, number 1 or number 2 of the EWKFondsG due to a food content of more than 500 grams do not generally trigger a single-use plastic levy for these products.

The corresponding packaging quantities are therefore generally not included as leviable quantities of these two product types in the annual DIVID quantity report.

However, this does not automatically mean that the entire company is exempt from its obligations under the EWKFondsG.

Example of a mixed assortment

A manufacturer sells:

• 750 g packs of potato salad,
• 200 g packs of ready-to-eat salad,
• beverage cups,
• lightweight plastic carrier bags.

The 750g packs may be excluded due to the 500g limit. However, the 200g packs, beverage cups and plastic carrier bags must still be assessed independently according to the respective legal criteria.

Therefore, for a correct EWKFondsG quantity report, the entire assortment must always be considered.

What impact does the 500g limit have on the audit obligation?

According to Section 11 of the EWKFondsG, the annual quantity report must generally be audited and confirmed by an approved and registered auditor. We at DIVID-Mengenmeldung can carry this out for you and provide you with the necessary documents (audit report and audit confirmation with QES).

Anyone who placed a total of less than 100 kilograms of single-use plastic products on the German market for the first time in the previous calendar year or sold them directly to Germany is generally exempt from the regular audit obligation. However, the Federal Environment Agency can also order an audit in individual cases below this quantity.

Products that do not fall under Annex 1, number 1 or number 2 due to a food content of more than 500 grams are generally not included in the leviable quantities. They therefore do not increase the total quantity relevant for the regular audit obligation.

Example of the audit obligation

A company places the following packaging on the German market within one calendar year:

• 1,000 kilograms of film packaging for stollen, each with 750 grams of food content,
• 80 kilograms of plastic packaging for biscuit packs, each with 200 grams of food content.

If the stollen packaging is excluded due to the 500g limit and there are no other relevant single-use plastic products, 80 kilograms of leviable packaging remain.

The company would thus generally be below the legal limit of 100 kilograms for the regular audit obligation. The prerequisite, however, is that the products have been correctly classified and the calculations have been comprehensibly documented.

Why clean documentation is indispensable

Manufacturers should not simply remove products with more than 500 grams of food content from their quantity list without comment.

During an EWKFondsG audit, it is not only checked whether the reported kilograms are numerically correct. The auditor must also be able to understand whether products have been correctly differentiated as single-use plastic products or non-single-use plastic products and assigned to the correct product type.

A structured article list should therefore contain at least the following information:

• article number,
• product designation,
• type of packaging,
• net filling weight of the food,
• packaging material and plastic content,
• information on preparation,
• information on typical consumption,
• classification into the respective product type,
• justification for an exclusion,
• annual sales,
• weight of the relevant single-use plastic product.

A well-prepared product matrix reduces queries, speeds up the audit process, and improves traceability for the auditor and the authorities.

What manufacturers, importers, and distributors should do now

1. Fully record filling weights

The net filling weight should be clearly documented for each potentially affected item. Terms such as "large pack," "economy pack," or "family pack" are not sufficient for applying the 500g limit.

2. Distinguish precisely between 500 grams and more than 500 grams

A pack of exactly 500 grams cannot be excluded solely on the basis of the quantity threshold. The exclusion due to the 500g limit only applies from 501 grams.

3. Determine the correct product type

The quantity threshold only applies to food containers as well as bags and film packaging. Beverage cups, beverage containers, and other product types must be assessed according to their own criteria.

4. Correctly divide multipacks

For individually packaged portions, the individual film packaging, not the total weight of the sales carton, is often decisive.

5. Document empty food containers

Anyone who sells empty containers and wishes to refer to a later filling with more than 500 grams should have suitable evidence of actual use.

6. Update existing quantity calculations

Companies should check whether older product evaluations and quantity statements already take into account the quantity threshold applicable since November 2025.

EWKFondsG audit with DIVID-Mengenmeldung

The 500g limit can significantly reduce a company's leviable quantity. At the same time, new demarcation questions arise: Which filling weight is decisive? How are individually packaged portions to be treated? Which documents are required for empty food containers? And which products remain outside the EWKFondsG despite a pack size of less than 500 grams?

DIVID-Mengenmeldung supports manufacturers, importers, online retailers, private labels, and foreign companies in the structured preparation of their EWKFondsG audit.

Our service includes, among other things:

• structured checklists for data collection,
  
• preparation and plausibility check of the audit documents,
• coordination of the fully digital audit process,
• organization of the audit by an independent external auditor,
• provision of the audit report and the audit confirmation with QES for DIVID.

The actual audit is not carried out by DIVID-Mengenmeldung itself. It is carried out by an independent external auditor who meets the legal requirements and is registered in the auditor register of the Central Agency Packaging Register.

Companies without a registered office in Germany can also use our audit service. The submission of documents and the organizational processing are done digitally.

The 500g limit creates an important quantitative demarcation for food containers as well as bags and film packaging with food content.

For practical purposes:

• More than 500 grams of food content: The product is not treated as intended for immediate consumption due to the quantity threshold.
• Exactly 500 grams of food content: No automatic exclusion; further criteria must be checked.
• Less than 500 grams of food content: Also a complete check of all legal requirements.

The limit refers to the food content and not the weight of the packaging. It also does not apply to beverage cups, beverage containers, or any other product types of the EWKFondsG.

Manufacturers, importers, and distributors should update their article master data and quantity calculations accordingly. Correct classification can not only affect the amount of the single-use plastic levy but also determine whether the legal limit for a regular audit of the quantity report is reached.

Frequently asked questions about the 500g limit for the EWKFondsG

Are all food packaging over 500 grams exempt from the EWKFondsG?

No. The 500g limit only applies to food containers as well as bags and film packaging according to Annex 1, number 1 and number 2 of the EWKFondsG. Other product types are not excluded due to this threshold.

Does the 500g limit apply to the food or to the packaging?

The food content is decisive. The weight of the plastic film, the tray, the lid, or a plastic coating is not decisive for applying the 500g limit.

Is a pack of exactly 500 grams levy-free?

Not solely due to the quantity threshold. The exclusion only applies to a food content of more than 500 grams. For exactly 500 grams, the other requirements for the product type must be checked.

Are packs under 500 grams automatically leviable?

No. Even with a smaller filling quantity, it must be checked, among other things, whether the food is intended for immediate consumption and can be consumed without further preparation.

Does the limit also apply to beverage cups?

No. Beverage cups are a separate product type of the EWKFondsG. The 500g limit does not apply to them.

What applies to a 600g pack with individually wrapped bars?

As a rule, the individual bar packaging must be considered. If each bar contains, for example, 50 grams, each individual film packaging can still be relevant. The total weight of the multipack does not automatically lead to exclusion.

What applies to empty salad bowls or takeaway boxes?

For empty food containers, the 500g limit is initially not applicable. However, the manufacturer can prove in individual cases that the containers are actually filled with more than 500 grams of food.

Must packaging over 500 grams be reported to DIVID?

Insofar as they are not classified as food containers or bags and film packaging according to Annex 1, number 1 or number 2 due to the quantity threshold, they are generally not reported as leviable quantities of these product types.

Can the 500g limit affect the audit obligation?

Yes. If products are excluded from the relevant quantity calculation due to a content of more than 500 grams, the total leviable quantity can be reduced. This may allow a company to remain below the legal limit of 100 kilograms for the regular audit obligation.

Who may audit an EWKFondsG quantity report?

The audit can be carried out, among others, by registered experts as well as appropriately registered auditors, tax advisors, or sworn auditors. The auditor must meet the legal requirements and be registered in the designated auditor register.

Note: This article provides a general overview of current legal and administrative practice. It does not replace individual legal advice or binding product classification. For products that are not clearly classifiable, a classification application according to Section 22 EWKFondsG may be considered.