What is the difference between EPR registration fees and recycling fees in Germany?

Q: What is the difference between EPR registration fees and recycling fees in Germany?

Germany charges no registration fee: ZSVR says all activities in LUCID, data reports included, are free. The recycling cost is the dual-system licence, a private contract priced by material type and weight. A company with no establishment in Germany also pays its authorised representative; with us €149 a year, no setup fee. Representative fees and system fees are separate lines.

There is no registration fee: LUCID is free. The recycling cost is the dual-system licence, by material and weight. A foreign company also pays its authorised representative.

Since 12 August 2026, § 5 VerpackDG, implementing Article 45(3) of Regulation (EU) 2025/40, requires a producer with no establishment in Germany to appoint an authorised representative before it first makes packaging available in Germany. Read § 5

By Razvan Toma · Founder · Last checked 8 November 2026 · Sources linked below

Quick answer

Three different things, only two of which cost money.

Item	Who	Cost
LUCID registration and data reports	ZSVR	Free
Dual-system licence (the recycling fee)	A dual system	By material and weight
Authorised representative	Required with no German establishment	€149 a year with us

See is LUCID free, dual-system rates and what German EPR costs.

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Selling in Germany?

Your German authorised representative from €149 a year: help with your LUCID registration, dual-system contract and annual report included. No setup fee.

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