Rechtsstand: 21 September 2026 — the date every statement on this page was checked against the sources below.
Three layers, and mixing them is why quotes look incomparable. One: dual-system participation (Lizenzentgelt), paid to a duales System per kilogram by material — unavoidable, and identical whichever representative you use. Two: your representative’s service fee, which is what our price table compares. Three: the items nobody quotes — setup fees, B2B handled separately, and your own time collecting packaging weights. LUCID registration itself costs nothing. Sources (4)
VerpackDG § 5VerpackDG § 5VerpackDG § 7VerpackDG § 7VerpackDG § 9VerpackDG § 9VerpackDG § 13VerpackDG § 13
Layer 0 — registration, which is free
Start here because it is the one number people get wrong in the expensive direction. ZSVR: „Die Registrierung im Verpackungsregister LUCID ist kostenlos und erfolgt online.“ Registration, data reports and everything ZSVR does around them are free to producers. It is also the one duty that cannot be delegated (§ 5(2) carves out § 6), so anyone charging you for it is charging for form-filling you could do yourself.
Layer 1 — dual-system participation
§ 7(1) VerpackDG requires producers of systembeteiligungspflichtige Verpackungen to participate in a system before making them available. This is the layer that scales with your business.
- Charged per kilogram, by material. Paper, glass, plastic, ferrous metal, aluminium, composites and other materials are priced separately, and the spread between materials is large.
- Set by each system, not by your representative. Every approved system publishes its own rates and they differ. Which system you use is a commercial choice; the duty to be in one is not.
- Minimum fees are normal. Systems commonly set a floor, so very small volumes pay the floor rather than the calculated amount.
- Not covered by any representation fee unless a provider explicitly says so — and if it does, ask whether it is passed through at the system’s rate or resold with a margin.
We are not going to print per-kilogram figures we cannot link. The approved systems are listed with their authorising Land in the approved bodies dataset, and each publishes its own tariff. A dataset of the rates themselves is on our list; the schemes render them behind JavaScript and we would rather ship it late than quote numbers without a source.
Layer 2 — the representative’s service fee
This is the layer you can actually shop, and the one our price dataset exists to compare. What drives it:
- Streams covered. Household and e-commerce packaging is the base case. B2B transport packaging is a separate track under § 39 and is frequently excluded.
- Reporting regime. Above 10 tonnes a year you report each system participation to ZSVR as you make it (§ 9(1)); below 10 tonnes that collapses into a single annual submission by 1 June (§ 9(2)). That is a real difference in workload.
- Setup fees. Some providers publish an entry price plus a one-off onboarding fee. Our table computes a year-one total so the comparison is like-for-like.
- Whether the dual-system fee runs through them. Passing it through at cost and reselling it are both legitimate; knowing which you bought is the point.
Layer 3 — what nobody quotes
- Your packaging data. Weights per material per SKU. Nobody can file for you without it, and assembling it the first time is the real cost for most small sellers.
- B2B, if you have it. Take-back under § 39 or a § 22 organisation, with its own § 39(3) annual documentation due 15 May.
- Other EU countries. Article 45(3) PPWR runs per member state. Germany is one appointment; five countries is five, each under that country’s law. See whether that is about to change — short answer, not yet.
- Getting it wrong. § 66(3) VerpackDG tops out at €200,000, and § 13(1) and § 13(4) stop you selling and stop your fulfilment provider shipping long before any fine is issued.
Putting the three together
For a small seller shipping consumer goods into Germany the shape is usually: €0 to register, a representation fee in the low hundreds per year, and a dual-system bill that depends entirely on your tonnage and materials. The representation fee is the only one a provider controls — which is why it is the only one we publish a comparison of, and why we publish our own price in the same table.
Sources
Every claim above comes from one of these. Primary law and the competent authority first; no provider marketing pages.
- VerpackDG § 5 — read 2026-09-21
- VerpackDG § 7 — read 2026-09-21
- VerpackDG § 9 — read 2026-09-21
- VerpackDG § 13 — read 2026-09-21
- VerpackDG § 22 — read 2026-09-21
- VerpackDG § 39 — read 2026-09-21
- VerpackDG § 66 — read 2026-09-21
- ZSVR — LUCID registration — read 2026-09-21
- ZSVR — Systembetreiber — read 2026-09-21
Razvan Toma is the founder of EPR Germany Rep and of EPR France Rep, the French sister service. He reads the statutes and the regulator's own guidance directly, and publishes what they say — including when it means telling a visitor they do not need to buy anything.
Razvan on LinkedIn ↗