What Is an Authorised Representative in DIVID (EWKF)?
What Is an Authorised Representative in DIVID (EWKF)?
One of the most confusing parts of registration in the Single-Use Plastics Fund (EWKF) via the DIVID portal is the term “Authorised Representative” (AR).
For many international Amazon, eBay, or Etsy sellers, this requirement is a major roadblock. In this article, we will clarify who this representative is, why they are essential, and whether you are legally required to have one.
⚠️ Is it Mandatory?
Unlike some other German compliance systems where an Authorised Representative is optional, the rules for the Single-Use Plastics Fund (EWKF) are very strict.
Use the table below to determine your requirements:
Requirement Overview
Your Company Location | Registration in DIVID | Is an AR Mandatory? |
Germany (Established branch) | Yes | No (You register yourself) |
European Union (Outside Germany) | Yes | Optional (But recommended) |
Non-EU Countries (USA, China, UK, etc.) | Yes | YES – MANDATORY |
Note: If you are located outside of Germany, you cannot legally complete your registration in the DIVID portal without a German-based Authorised Representative.
What Is an Authorised Representative?
An Authorised Representative is a legal entity or person based physically and legally in Germany. They act on behalf of your foreign company to handle legal and compliance obligations under the EWKF law.
The German authorities (UBA - Umweltbundesamt) require this because they need a responsible contact person within the German jurisdiction who can be held accountable for reporting and payments.
Which products are covered?
You need to register and have an AR if you sell products such as:
Food containers for immediate consumption.
Packets and wrappers (e.g., for chips or candy).
Beverage containers and cups.
Lightweight plastic carrier bags.
Wet wipes and balloons.
Tobacco filters.
Why Third-Party Companies Are Involved
When you begin the registration process, you will encounter terms like "Compliance Agencies" or "Service Providers." It is important to distinguish between them:
The Government (UBA/DIVID): The authority that manages the fund and collects the levy.
The Authorised Representative: A private company (like a consulting firm) that you hire to represent you. They are not the government, but they assume legal liability for your compliance.
Dual Systems: These handle packaging (LUCID). While they often provide information about DIVID, the Single-Use Plastic Fund is a separate legal requirement.
How the Process Works (Step-by-Step)
The registration isn't just a simple form. Because of the legal liability involved, the process usually looks like this:
Contracting: You sign a written agreement with a German-based AR (in German or English).
Account Creation: Your AR typically initiates or confirms the registration on the DIVID portal.
Validation: The German Environment Agency (UBA) verifies the appointment and the contract.
Reporting: You provide your sales data to the AR, and they submit the official reports to the DIVID system.
Where Can Foreign Sellers Find an AR?
Several specialized companies in Germany offer Authorised Representative services. Common providers include:
Deutsche Recycling
A-Compliance Services
eLing GmbH
ECOPV-EU
Pro Tip: Ensure your chosen provider has specific expertise in the EWKF/DIVID framework, as they will be handling your sensitive sales data and legal liability.
Why the Process Feels Complicated
The hardest part is "Solidary Liability." Because your Authorised Representative is legally responsible for your compliance in Germany, they will require detailed documentation about your products.
Key things to remember:
LUCID is for packaging.
DIVID is for single-use plastic content.
If you are outside Germany, the AR is your mandatory bridge to the German market.
Official Source
For official guidelines and the registration portal, visit:
DIVID / Single-Use Plastics Fund (SUPFund): www.einwegkunststofffonds.de
Final Thoughts
Navigating German environmental laws can be overwhelming, but it is a "must-do" to keep your shop active and avoid heavy fines or sales bans. If you are unsure which registration category applies to your company, we are here to help.
Nadezda Walz
Master’s Degree in Economics and Management Sciences