Who needs to be tested – and why?
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Audit Obligation under the EWKFondsG: Who must have their plastic quantities (legally: single-use plastic quantities) audited - and why?
Everything about the legal audit obligation for manufacturers, importers and retailers
Many companies know that they have to submit a quantity report of their plastic packaging (plastic packaging) under the Single-Use Plastics Fund Act (EWKFondsG). Less well known, however, is that for certain companies, a legally required audit of this report applies.
This audit is not optional - it is mandatory when quantity thresholds are exceeded. In this article we explain:
- Who exactly is subject to the audit obligation
- Why the audit is legally required
- What role accredited auditors play
- How you can fulfill your obligation simply and legally compliant with DIVID quantity reporting
Who needs to be audited?
The audit obligation applies to manufacturers who exceed certain quantity thresholds (> 100 kg / year).
Typically affected are:
- Manufacturers who place plastic packaging on the market for the first time
- Importers who import more than 100 kg of single-use plastic products into Germany
- Private label bottlers as fillers of private label packaging
- International companies that supply large quantities to Germany
Important: The exact quantity thresholds are determined by the Central Agency Packaging Register (ZSVR). Even companies that are just below these thresholds should carefully document their quantities, as follow-up audits are possible.
Why is there an audit obligation?
The reasons are clear:
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Equal treatment of all manufacturers
→ Manufacturers should make their fair contribution. -
Ensuring correct quantity reports
→ Avoidance of under- or false statements. -
Financial stability of the Single-Use Plastics Fund
→ The fund finances, among other things, municipal cleaning and waste disposal. -
Avoidance of distortion of competition
→ Companies that report correctly should not be disadvantaged.
Who is allowed to conduct the audit?
The audit may only be conducted by accredited auditors who are officially recognized by the ZSVR. These include, among others:
- Auditors
- Tax advisors
- Sworn accountants
- Approved experts
Why have it audited via DIVID quantity reporting?
- Direct access to audited and listed auditors
- Digital processing without paper chaos
- Dedicated contact person throughout the entire audit process
Deadlines for auditing your plastic quantities (plastic quantities)
- Quantity report: Must be submitted by May 15 of the following year
- Audit confirmation: Must be issued by an accredited auditor with a qualified electronic signature (QES)
- Audit report: Must also be issued by the DIVID auditor and submitted on the DIVID platform
Tip: Start commissioning the auditor by mid-March at the latest to avoid bottlenecks.
⚠️ Risks of disregarding the audit obligation
Companies that do not carry out an audit despite the obligation risk:
- Fines of up to €100,000
- Sales ban for affected products in Germany
- Damage to reputation with business partners and customers
How does an audit of your single-use plastic quantities work and how do I find an auditor? – Briefly explained
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Commissioning of an accredited auditor
→ Via DIVID quantity reporting, you can directly commission us with the organization of your plastic audit. Our accredited experts will take care of checking your quantities. You don't have to worry about anything else.
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Provision of all relevant documents
→ After commissioning, you will receive a checklist from us. There you will see what documents and information you should provide us - e.g. sales reports, invoices, production data, import documents.
-
Document review & plausibility check
→ Ensuring correct quantity recording. The EWKFonds experts will review your documents and take care of issuing the necessary documents.
-
Creation of the audit confirmation
→ Your DIVID auditor will prepare an audit report and an audit confirmation with a qualified electronic signature (QES) if the result is positive. Only with the QES is an audit confirmation valid and can be submitted on the DIVID platform.
Conclusion: Take the audit obligation seriously – act now
The audit obligation under the EWKFondsG is not a tedious formality, but a legal obligation with high risks in case of violation.
With DIVID quantity reporting, you secure a legally compliant, fast and completely digital processing - no matter whether you are located in Germany or abroad.