The PPWR packaging mandate in Germany, €149 a year

One fixed fee for acting as your Bevollmächtigter under PPWR Article 45(3) and VerpackDG § 5. No setup charge. Dual-system licence fees, where they apply, are passed through at the scheme's own rate with no markup — and for pure B2B transport packaging there may be none at all.

Pricing	Packaging mandate€149 / yearOne-time setup: €0Get started	CustomOn requestOne-time setup: €0Request a quote
EPR regimes covered	Packaging	Packaging, batteries, B2B electricals
Named as your Bevollmächtigter in LUCID
Written German mandate (VerpackDG § 5(4))
Dual-system contract, in our name
Annual volume reporting
Vollständigkeitserklärung when required
Take-back duties under § 39
B2B transport packaging: § 39 scope, agreement and 15 May documentation
ZSVR correspondence
Marketplace support (Amazon, eBay, Kaufland)	Add-on €290	Add-on €290
Batteries (BattG) representation	—	€249 / year
Electricals, B2B only (ElektroG)	—	€349 / year
Electricals for private households	—	Not yet — see below
System fees	At cost, 0% markup	At cost, 0% markup
Your LUCID registration	Stays yours	Stays yours

Which one applies to you

The packaging mandate is what PPWR Article 45(3) and VerpackDG § 5 actually require from 12 August 2026 — that is the duty almost everyone lands here for. Custom is only for companies that also place electricals or batteries on the German market: those are separate regimes at stiftung ear, and there the representative performs the registration on your behalf.

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.

Named as your Bevollmächtigter 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
Vollständigkeitserklärung where your volumes require one
Working out whether VerpackDG § 39 applies to your packaging at all, and papering the § 39(1) agreement with your business customers where it does
The annual § 39(3) documentation, due 15 May, broken down by material type and mass, kept in verifiable form for the Land authority
Correspondence with ZSVR — we act in our own name, so the authority deals with us

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), ZSVR: a höchstpersönliche Pflicht)
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
Marketplace support. Amazon and the other platforms ask <b>you</b>, the producer, for your own LUCID number — that is not a duty the law gives a representative. We do it as a paid add-on, and we would rather say so than bundle it and call it compliance.

What “B2B transport packaging handled” actually means

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?

The usual answer: your customer does, and the contract says so

§ 39(1) closes with a sentence that decides most real cases: producers and distributors may agree different terms on the place of return and the allocation of cost with end users, provided those end users are not consumers. A German business receiving pallets is not a consumer. So the normal commercial arrangement — your customer keeps and disposes of the transport packaging — is lawful when it is actually agreed. What matters is that it is agreed and documented, not assumed.

Or it goes back on your next delivery

“Im Rahmen wiederkehrender Belieferungen kann die Rücknahme auch bei einer der nächsten Anlieferungen erfolgen.” If you deliver repeatedly to the same customer, the empties travel back on a later run. Your logistics already go there.

Or you join an industrial take-back system, and pay them

If neither of the above fits, systems such as RIGK, GVÖ, KBS or their joint venture PACKLIANCE organise collection and recovery for industrial and commercial packaging. They charge their own fee for that, quoted on your volumes and materials. We can put you in touch and pass their invoice through at cost — that fee is not part of our €149, any more than a dual-system licence is.

The honest limit, so there is no misunderstanding: we are a compliance office, not a haulier. Nobody collects pallets for €149 a year, and we do not claim to. What the fee buys is the paperwork that decides and evidences the duty — scope, the § 39(1) agreement, and the annual § 39(3) documentation. Physical collection, where it is genuinely needed, is a separate contract with a take-back system at their price.

Add-ons

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

Service	Price
Marketplace support We answer Amazon, eBay, Kaufland and Otto compliance requests on your behalf, keep your registration numbers current in each seller account, and handle listing-suspension cases. Not a legal duty of a representative — the platforms ask the producer directly.	€290 / year
Batteries (BattG) representation Registration at stiftung ear and acting as your Bevollmächtigter. No financial guarantee is required for batteries.	€249 / year
Electricals, B2B only (ElektroG) Take-back concept rather than a guarantee, so we can act as your Bevollmächtigter.	€349 / year

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.

Regime	Our fee	Status
Batteries (BattG) We register you at stiftung ear and act as your Bevollmächtigter. No financial guarantee is required for batteries.	€249 / year	Available
Electricals, B2B only (ElektroG) Equipment sold only to businesses needs a take-back concept rather than a guarantee, so we can act as your Bevollmächtigter.	€349 / year	Available
Electricals usable in private households (ElektroG) ElektroG § 7(1) requires the representative — not the producer — to lodge an insolvency-proof financial guarantee with the authority every calendar year. We are not offering this until that guarantee is in place, and we would rather say so than take your money.	On request	Not yet

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.