System participation
Are you a producer of packaging that is subject to system participation as defined in the EU Packaging and Packaging Waste Regulation (PPWR)? If the answer is 'yes', then you must assume extended producer responsibility (EPR) for this packaging. This means: you must finance the recycling of your packaging by participating that packaging in a system.
What is 'system participation'?
To pay for the recycling of your packaging that is subject to system participation, you are required to conclude a system participation agreement with a system operator.
The costs for participating your packaging with a system depend on different factors such as the volume and material type of your packaging.
You can conclude your system participation agreement with the system operator of your choice.
Who are the system operators, and what do they do?
End user dispose of their packaging waste in yellow bags/bins, paper bins and paper/glass containers.
System operators ensure that this packaging waste is collected, sorted and recycled across Germany, and that recycling quality is as high as possible.
System operators recover six million tons of packaging from private final consumers every year.
Paying the single-use plastic fee does not replace the system participation requirement
While the system participation requirement pursuant to the Verpackungsrecht-Durchführungsgesetz (Packaging Law Implementation Act) and the payment obligation pursuant to the Einwegkunststofffondsgesetz (Single-Use Plastic Fund Act) apply to the same object, they operate independently. Each regulation has its own reference points, content and goals, and they function side by side without affecting one another.
Specifically, system participation fees are used to fund the kerbside collection and recovery of packaging, while the single-use plastic fee helps cover the costs of recovering single-use plastic products from public spaces. These fees cannot be offset against each other, nor can volumes be deducted from one fee to reduce the other.
More detailed information about the Einwegkunststofffondsgesetz (Single-Use Plastic Fund Act), about registering, volume reporting to DIVID and other relevant issues can be found on the German Environment Agency's (UBA) Single-Use Plastics Fund platform.