Calculating packaging licence costs in Germany

Every seller asks one question: "How much do I need to budget?" Here is the answer in numbers, split into three things that must not be mixed up: statutory obligations (registration and volume reporting in the LUCID packaging register – free of charge), the licence fee to the dual system (depends on kilograms and material) and service providers: the authorised representative is mandatory if you have no establishment in Germany; all other services are optional. All prices net, verified on 8 October 2026.

Packaging EPR in Germany – 2026 costs on one page

Cost itemTypical priceMandatory?
LUCID registration (ZSVR)€0Yes
Volume reporting in LUCID€0Yes
Dual-system participation: licence feeby weight and material, 2026 market average: ≈ €0.26/kg paper, ≈ €1.17/kg plasticYes
Minimum fee of the dual system≈ €12–89/year depending on the systemYes, if your volume is below the threshold
Authorised representative in Germanyfrom ≈ €55/year; considerably more depending on volume and scope of servicesOnly for companies without an establishment in Germany
Provider handling registration and participation≈ €170–300/year + licence feeNo
Full service for larger companiesindividual quote, several hundred to several thousand €/yearNo

All prices are indicative market values, not statutory tariffs. There is no "official EPR price" in Germany: each dual system sets its own licence fee.

1. What exactly you pay for

1. LUCID registration – €0. The Central Agency Packaging Register (ZSVR) confirms officially: registration is free for all companies.

2. Dual-system participation – licence fee per kilogram. The only mandatory payment. You pay one of the 10 approved dual systems per kilogram of packaging, separated by material. A minimum or basic annual fee may be added.

3. Volume reporting – €0. You report volumes yourself: to the dual system and in LUCID. The state charges nothing for it.

4. Authorised representative – only without an establishment in Germany. Mandatory since 12 August 2026 for foreign companies selling directly to German consumers. A service by private providers at market prices.

5. Service provider or consultant – optional. Handles the paperwork, answers questions, sometimes also files the reports. Replaces neither registration nor the licence fee.

6. Other EPR obligations – if applicable. Electronics (WEEE), batteries (BattG), single-use plastics (EWKFondsG) – separate registers, separate fees.

2. Licence fee: prices per kilogram by material

Material2026 market average, netChange vs. 2025Examples
Glasscheapest fraction≈ +24 %bottles, jars
Paper, paperboard, cardboard≈ €0.26/kg—shipping boxes, folding boxes, paper cushioning
Ferrous metals, tinplate≈ €1.10/kg≈ +12 %cans, lids
Aluminium≈ €1.12/kg≈ +12 %cans, tubes, foils
Beverage cartons≈ €1.13/kg≈ +10 %Tetra Pak
Other composites≈ €1.16/kg≈ +8 %coated cardboard
Plastic≈ €1.17/kg≈ +9 %film, bubble wrap, tape, bags

Averages across the dual systems according to the market overview by verpackungslizenz24.de (as of August 2026). The actual price of your system may be higher or lower – online shops for small volumes are usually more expensive than contracts for large customers. In 2026 fees rose by 11.7 % on average and are around 42 % above 2020. Reasons: higher collection costs in the new tenders, lower revenues for waste paper and recyclates, rising recycling quotas. Since 1 January 2026 the ZSVR minimum standard on recyclability applies: mono-material and paper tend to get cheaper, poorly recyclable packaging more expensive. If your volume is below the threshold, the minimum fee is added – so comparing by €/kg alone falls short.

3. Dual systems: online shops compared

All 10 approved systems are legally equivalent. They differ in price per kg, minimum fee, contract term and notice period.

Online shop (system)Minimum price per year, netTermNotice period
activate (Reclay)from ≈ €12 per orderno commitment—
EASY-LIZE (EKO-PUNKT)€23.901 year3 months
Verpackung-Direkt (Noventiz)€351 year4 months
VerpackGo (Der Grüne Punkt)€361 year3 months
Lizenzero (Interzero)€391 year3 months
EASyShop (Landbell)€502 years6 months
Zmart (Zentek)€591 year3 months
PreZero Dual≈ €791 year3 months
BellandVision€891 year4 months

Minimum prices according to the providers and comparison portals, as of May–October 2026. For very small volumes (up to ≈ 50–100 kg) Reclay activate is usually the cheapest; for larger volumes or a lot of plastic, the models with a fixed minimum price often overtake it. For identical volumes, the most expensive system can cost almost twice as much as the cheapest. Independent comparison calculators show the exact price for your volumes in a minute: verpackungslizenz24.de and verpackungslizenz-vergleich.de. Beware of intermediaries: the same licence can be considerably more expensive there than directly from the system.

Not sure which dual system fits your volumes? In an initial consultation we clarify your obligations and suitable options — in writing, in your language, reply within 24 hours.Request a Consultation →

4. Switch provider and save: watch the notice period

Most contracts renew automatically – including at new prices. If you want to switch to a cheaper system for the next year, you must give notice in time. For contracts ending at the end of the calendar year:

Tip: put the notice deadline in your calendar and compare prices for the following year every summer. After switching, enter the new system in LUCID.

5. How to determine your packaging weight

  1. Weigh each component separately: box, film, filling material, tape. A kitchen scale is enough.
  2. Record the weight in kilograms with three decimal places, e.g. 0.152 kg.
  3. Multiply by the number of shipments per year.
  4. Add up by material.

Amazon FBA: you also license the shipping box in which Amazon sends your goods to the customer – not just the product packaging.

6. Service providers and authorised representatives: real prices

This is where most confusion arises. A provider charges for a service – representation, paperwork, advice. It does not cancel the licence fee per kilogram: you pay that to the dual system, directly or via the provider.

LUCID registration cannot be delegated. Even with an authorised representative, the company must register in LUCID itself. The authorised representative takes over system participation, reporting and the contact role towards the ZSVR. 2026 market range: authorised representative from ≈ €55/year. Many providers charge by packaging volume (e.g. ≈ €270 per 100 kg) – for larger volumes or with additional services the price can be considerably higher. Always ask what is included in the price. Prices verified on 8 October 2026; the companies named are examples from practice – you choose the provider yourself.

7. What changed in Germany on 12 August 2026

8. Worked examples by volume

The platform – Amazon, Etsy, eBay or your own shop – does not affect the price. Kilograms and material do. Calculated with ≈ €0.20–0.32/kg paper and ≈ €1.10–1.65/kg plastic.

ExampleVolume per yearLicence feeMinimum fee / authorised representativeTotal per year
1. Micro seller, German company40 kg cardboard + 10 kg plastic≈ €19–29minimum fee ≈ €12 (Reclay), €59 (Zmart) up to €89 (BellandVision)≈ €19–89
2. Small seller, German company400 kg cardboard + 100 kg plastic≈ €190–295—≈ €190–295
3. Foreign company without establishment320 kg cardboard + 80 kg plastic≈ €150–235authorised representative from ≈ €55, often €170–350 and more (mandatory since 12.08.2026)from ≈ €205, often €320–600
4. Medium seller2,400 kg cardboard + 600 kg plastic≈ €1,140–1,760—≈ €1,140–1,760
5. Large seller8,000 kg cardboard + 2,000 kg plastic≈ €3,800–5,860negotiated tariffs, supportfrom ≈ €3,800 (usually cheaper with an individual quote)

Examples for Amazon FBA sellers

Assumption per parcel: shipping box 150 g, paper cushioning 20 g, film and tape 20 g. Our own sample calculation – weigh your packaging yourself.

Parcels per yearPaper/cardboardPlasticEstimated licence fee
1,000170 kg20 kg≈ €56–87
5,000850 kg100 kg≈ €280–440
20,0003,400 kg400 kg≈ €1,120–1,750

Product packaging comes on top. A provider for the paperwork (optional) costs an additional ≈ €170–300 per year. From ≈ 2,000 kg it pays to request an individual tariff from the dual system.

9. Other costs that are often forgotten

10. What is coming in 2027

11. 7 ways to cut licensing costs

  1. Reduce plastic: paper tape and paper cushioning instead of bubble wrap.
  2. Choose mono-material instead of composites.
  3. Fit the box size to the product – less cardboard, fewer kilograms.
  4. Use the early-booking discount (Reclay up to 25 %).
  5. Do not over-license; correct volumes where possible (Lizenzero until 31.08., Grüner Punkt up to 10 %).
  6. Compare every year and keep an eye on the notice period.
  7. From ≈ 2,000 kg, request an individual tariff.

12. Your annual calculation

Annual cost = LUCID (€0) + licence fee per kg + system minimum fee + authorised representative (if you are based abroad) + provider (optional) + other EPR registers (if applicable).

13. What packaging EPR costs across Europe

There is no Europe-wide price. The PPWR harmonises the rules, but registers, systems, fees and reporting remain national.

CountryRegister / systemAuthorised representative for foreign sellersIndicative authorised representative package per year*Specific feature
GermanyLUCID / 10 systemsyes, without a German establishmentfrom ≈ €55, considerably more depending on volumepublic register; Amazon checks automatically
NetherlandsVerpactyes≈ €160fee only from 50,000 kg per year
BelgiumFost Plus, Valipacyes≈ €250household and industrial packaging separate
FranceCiteo / ADEMEyes≈ €250Triman logo and sorting instructions
SpainEcoembes / MIREyes≈ €320separate tax on plastic packaging
SwedenNPAyes≈ €370registration in the state register
AustriaARA / EDMyes≈ €480authorised representative mandatory for distance sellers
ItalyCONAIyes≈ €500environmental contributions by material
PolandBDO registeryes≈ €500annual report in BDO
IrelandRepakyes≈ €1,640one of the most expensive markets

* Prices for countries other than Germany according to the price list of the provider TBA Global (August–September 2026); the licence fee per kg is added separately.

14. Fines and hidden costs

Frequently asked questions

Is LUCID registration free?

Yes, the ZSVR confirms this officially. You only pay the dual system.

How much does a packaging licence cost in 2026?

For very small volumes from ≈ €12 per year; common minimum fees range from €23.90 to €89. Above that, billing is by weight: on average ≈ €0.26/kg paper and ≈ €1.17/kg plastic.

Is there a minimum volume below which no licence is needed?

No. The licensing obligation applies from the very first parcel to private customers.

Which dual system is the cheapest?

Up to ≈ 50–100 kg, usually Reclay activate. For larger volumes or a lot of plastic, often EASY-LIZE, VerpackGo or Lizenzero. Compare your volumes in the calculator.

As an Amazon FBA seller, do I also have to license Amazon's shipping box?

Yes. The shipping packaging is licensed by the seller, not by Amazon.

Does a foreign company need an authorised representative?

Since 12 August 2026, yes – if it has no German establishment and sells to German consumers.

How do I switch dual systems?

Give notice in time (usually 3 months before the end of the year) and sign a new contract. Enter the new system in LUCID.

Do I need a declaration of completeness?

Only for large volumes: more than 80,000 kg of glass, 50,000 kg of paper/paperboard/cardboard or 30,000 kg of lightweight packaging per year.

Will the packaging licence get more expensive in 2027?

Probably yes: eco-modulation is planned, and possibly a plastic packaging tax. There are no official prices for 2027 yet.

Does Amazon handle EPR for the seller?

No, the platform only checks whether a LUCID number and system participation are in place.

Does the PPWR replace LUCID?

No. LUCID remains the mandatory national register.

Sources

All prices are indicative, net, depend on volume and material and were verified on 8 October 2026. Only the providers' own offers are binding. We receive no commission from dual systems. We may receive a commission for referrals to individual partners; this has no influence on the prices stated here. This article is not legal or tax advice.