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What the PPWR packaging mandate fee covers

This is the mandate required by the new PPWR regime that applies from 12 August 2026 — PPWR Article 45(3), implemented in Germany by VerpackDG § 5. Every item below is included in Essential at €149 a year and in Standard at €199 a year, with no setup fee on either. Standard adds priority support on top; it does not add anything from this list, because nothing the law requires sits behind a higher tier. Regulation (EU) 2025/40 (PPW+1

• Named as your representative in LUCID
• Written mandate in German, as VerpackDG § 5(4) requires
• The system participation contract with a dual system, concluded in our name
• Annual packaging volume reporting
• Declaration of completeness where your volumes require one
• Working out which of your packaging falls under VerpackDG § 39 rather than a dual system
• Correspondence with ZSVR — we act in our own name, so the authority deals with us
• A ready-to-sign mandate in German, with an English translation alongside
• Quantities you have already licensed with a dual system this year are carried over, not licensed again
• Compliance monitoring — we tell you when the rules change
• Step-by-step guides, free to read: LUCID registration, working out your packaging weights, lowering your licence fees, entering your number on each marketplace and selling to both Germany and France
• Marketplace support: we help you answer Amazon, eBay, Kaufland and Otto requests about your packaging registration, including listing blocks

What the PPWR packaging mandate fee does not cover

• Your LUCID registration — by law that stays with you and cannot be delegated (VerpackDG § 5(2): a strictly personal duty)
• Dual-system licence fees, which depend on your materials and weights and are passed through at cost
• Electricals and batteries, which are separate regimes at stiftung ear — see below

How the appointment works, and why the contract is in our name

Three sentences of VerpackDG § 5 decide the whole shape of this service. They are worth reading before you compare providers, because they explain why a foreign seller cannot simply buy a licence from a dual system's web shop and be finished. VerpackDG § 5

We become the producer, in our own name

§ 5(3): “Der Bevollmächtigte … gilt im Hinblick auf die wahrzunehmenden Verpflichtungen als Hersteller im Sinne dieses Gesetzes. Die Aufgabenerfüllung … erfolgt im eigenen Namen.” (“With regard to the obligations it performs, the authorised representative … is deemed to be the producer within the meaning of this Act. These tasks … are performed in its own name.”) For the obligations we take on we are the producer in law, and we act as principal. That is why the dual-system participation contract is concluded in our name rather than yours, and why ZSVR deals with us.

One representative per producer, mandated in writing, in German

§ 5(4): a producer may appoint only one Bevollmächtigter, and the appointment must be made by written power of attorney in German, before packaging is first made available. Moving to a different representative therefore means ending the existing mandate first — it is not something you can hold in parallel.

You name us, and ZSVR confirms it

§ 5(5): the producer names the representative to ZSVR unverzüglich (without undue delay) after the mandate, as part of its own registration under § 6(2) no. 2 — and the naming “bedarf der Bestätigung durch die Zentrale Stelle Verpackungsregister.” (“requires confirmation by the Central Agency Packaging Register.”) There is a regulator confirmation step in onboarding, so allow time for it.

B2B transport packaging: how § 39 works

This is the part of German packaging law most often explained wrongly, so here is the mechanism in full. Transport packaging delivered to businesses is generally not system-participation packaging. That means there is no dual system for it and no eco-contribution is paid on it — nobody is being funded to come and collect it. Instead VerpackDG § 39 imposes a take-back duty directly on the producer:

• Free take-back of used, empty packaging of the same type, at the place of handover or nearby, collected separately from other waste (§ 39(1)).
• Recovery of what comes back, to the standard in § 42(5) — which may also be satisfied by returning it up the chain to your own supplier (§ 39(3)).
• Annual documentation by 15 May of what you placed on the market and what was taken back and recovered, broken down by material type and mass, in verifiable form, with self-control mechanisms, produced to the competent Land authority on request (§ 39(3)).

So who actually collects the pallets?

VerpackDG § 39+2

Add-ons

These are services, not statutory duties. Nothing here is required for the mandate to be valid.

Electricals and batteries

Packaging is one of three German EPR regimes. The other two sit at stiftung ear, and unlike packaging the representative there also performs the registration — a foreign producer cannot self-register at all. What differs is what the law asks of the representative. Our fee is €500 a year for each, and scheme fees are passed on at cost.

One limit worth knowing in advance: under ElektroG § 37(7) a representative holding more than 20 simultaneous registrations needs the authority's approval, which tests the management's reliability and expertise and the applicant's equipment and organisation. ElektroG § 8+2

Frequently asked questions