Audit requirement · last reviewed August 8, 2026
100 kg threshold under the EWKFondsG: from when does an audit apply?
The 100 kg threshold is the most commonly misunderstood rule in the EWKFondsG: it does not decide whether you have to report at all, only whether your annual quantity report additionally needs to be audited by an auditor or tax advisor (§ 11 EWKFondsG).
Under 100 kg/year
Registration, quantity reporting, and the levy are still mandatory — only the additional audit by an auditor is waived.
From 100 kg/year
In addition to reporting, an audit by a registered auditor or tax advisor with a qualified electronic signature is required.
The exception: exclusively deposit beverage bottles
Anyone who places exclusively deposit beverage bottles under § 31 VerpackG on the market is exempt from the audit requirement regardless of quantity — registration and reporting still apply. This exception applies only to the audit requirement, not to the general levy obligation.
What the audit covers
Not a mere plausibility check: the auditor confirms with reasonable assurance that the figures comply with the statutory requirements and the UBA audit guidelines — including the factual accuracy of the underlying records, correct product classification, and completeness of documentation. This is exactly where a complete audit file, logged from the start, helps avoid follow-up questions and therefore audit hours.
Consequences without registration or reporting
Without a registration number, an immediate sales ban applies to the affected products. Missed registration, reporting, or payment can additionally trigger fines of up to €100,000 as well as late-payment surcharges after just three business days (§ 26 EWKFondsG) — regardless of whether the 100 kg threshold is reached.
Frequently asked questions
Do I not have to report anything at all under 100 kg?
You do. Registration, annual quantity reporting, and paying the single-use plastics levy are mandatory regardless of quantity. The 100 kg threshold only decides whether this report additionally needs to be audited and confirmed by an auditor or tax advisor — a common misconception is confusing the threshold with a general de-minimis exemption.
Is there an exception to the audit requirement?
Yes: producers who place exclusively deposit beverage bottles under § 31 VerpackG on the market are exempt from the audit requirement — regardless of quantity. Registration and reporting still apply here too.
Who is allowed to perform the audit?
An auditor registered with the Federal Environment Agency, or a certified public accountant/tax advisor. The confirmation must be made with a qualified electronic signature and is not a mere plausibility check — among other things, the factual accuracy of the records, correct product classification, and completeness of documentation are checked.
What if I don't register at all?
Without a registration number, an immediate sales ban applies to the affected products. Missed registration, reporting, or payment can additionally trigger fines of up to €100,000 as well as late-payment surcharges after just three business days (§ 26 EWKFondsG).
Sources · last reviewed August 8, 2026
This page summarizes the basic statutory rules and doesn't replace a legal case-by-case review. EWKPilot does not replace legal or tax advice.