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Single-Use Plastics Directive – Obligations in Germany and Austria

The Single-Use Plastics Directive (EU 2019/904) applies across all EU Member States.

Its aim is to reduce the environmental impact of certain plastic products – particularly on marine and public environments – and to promote the transition toward a sustainable circular economy.

The implementation differs among countries: In Germany, through the Single-Use Plastics Fund Act (EWKFondsG) and the Single-Use Plastics Ban Ordinance (EWKVerbotsV) In Austria, through the Packaging Ordinance (VVO) (§ 18a and § 21a)

Both regulations apply only to filled single-use plastic products that are typically consumed or discarded directly by end users, such as beverage cups, take-away containers or flexible wrappers for snacks.

The obligation to report and pay the so-called “littering fees” lies with the first distributor of the filled packaging – that is, the filling company or importer. Pre-licensing by packaging suppliers is not possible, as only the packer knows the filled quantities and the intended use. 

Single-Use Plastics Directive – Comparison Germany / Austria

Criterion Germany (EWKFondsG) Austria (VVO) Comment / Example
Legal Basis Single-Use Plastics Fund Act (EWKFondsG)
+ Single-Use Plastics Ban Ordinance (EWKVerbotsV)		 Packaging Ordinance (VVO)
§§ 18a and 21a		 Based on EU Directive (EU) 2019/904
Objective Financing municipal cleaning costs through manufacturer contributions Financing municipal cleaning costs (“littering costs”) Same goal – different reporting path
Start of Obligation 2024 (first report in 2025 for 2024) 2022 (retroactive reporting from 2023 for 2022) Different timeline, same principle
Products Covered Cups, food containers, lightweight carrier bags, wet wipes, tobacco products, fishing gear, etc. Cups, food containers, flexible film packaging, fishing gear containing plastics Both countries cover packaging for immediate consumption
Obligated Party First distributor / filler / importer First distributor / filler / importer Always the party placing the filled packaging on the market
Pre-licensing by supplier possible? ❌ No ❌ No Only the filler knows quantity and purpose
Competent Authority German Environment Agency (UBA) Licensed partners (e.g. ARA, Reclay, Interzero) DE = government fund, AT = system partner
Reporting / Payment Path Direct reporting to the Single-Use Plastics Fund (UBA) Reporting via the licensing system under the VVO Both with annual report due by March 15
Affected Quantity All filled products for immediate consumption Cups, boxes, films, wrappers for direct consumption Defined by intended use, not size
Exemptions Reusable packaging, glass, metal, medical products Reusable packaging, glass, metal, medical applications Both countries: only single-use plastics affected
Our Products We supply only empty packaging, which can become single-use plastic products only after being filled. The reporting and payment obligation lies solely with the filler or first distributor. No direct impact for customers buying empty packaging

Summary

Germany and Austria implemented the Single-Use Plastics Directive differently but pursue the same objective: Manufacturers and fillers of single-use plastic products must contribute to the costs of cleaning and public waste management.

Packaging suppliers are not directly affected. The obligation to report and pay the “littering costs” lies solely with the first distributor of the filled packaging.

Status: 2025 · Sources: BMUV, UBA, BMK, ARA, Interzero · All information without guarantee.