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EWKFondsG: Criticism of levy on sausage packaging

Profile picture Dr Martin Engelmann

According to the Umweltbundesamt (UBA, Federal Environment Agency), manufacturers are required to pay levies under the EWKFondsG for packaging containing ready-to-eat sausages.


According to the authority, a 150-gramme package containing six ready-to-eat sausages falls under the Einwegkunststofffondsgesetz (EWKFondsG, Disposable Plastics Fund Act). The authority had previously already argued in relation to other packaging that it depends on whether the contents of a package are suitable for immediate consumption after purchase. This was the case with the sausage packaging, which was why levies should be charged under the EWKFondsG. This is a general ruling that applies not only to the specific item examined, but also to similar products in general. Affected companies can lodge an appeal with the UBA within one month, until 8 February 2026.
 
According to Euwid, the UBA's decision has been met with criticism in the food and packaging industry. Industry representatives fear that the UBA's interpretation could mean that numerous ready-to-eat products sold in traditional food retail outlets could also be subject to the levy, even though they are not normally intended for consumption on the go. For example, Martin Engelmann, managing director of the IK Industrievereinigung Kunststoffverpackungen (German Association of Plastics Packaging Manufacturers), criticised in a statement that the UBA was disregarding the clear wording of the EWKFondsG. The law explicitly refers to foodstuffs that are intended for immediate consumption. For the UBA, on the other hand, it is sufficient that a product is suitable for immediate consumption. According to Engelmann's assessment, this would also include numerous ready-to-eat products from food retailers that are not typically intended as takeaway goods.
 
The IK also criticises the quantity threshold of 500 grams used by the UBA. Below this limit, the authority categorises packaging as suitable for immediate consumption without differentiating between product type or consumption context, according to the criticism.
 
Sources:

  • einwegkunststofffonds.de (8.1.2026)
  • Euwid Recycling und Entsorgung 4/2026 (20.1.2026)
  • Photo: © IK

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