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 item | Typical price | Mandatory? |
|---|---|---|
| LUCID registration (ZSVR) | €0 | Yes |
| Volume reporting in LUCID | €0 | Yes |
| Dual-system participation: licence fee | by weight and material, 2026 market average: ≈ €0.26/kg paper, ≈ €1.17/kg plastic | Yes |
| Minimum fee of the dual system | ≈ €12–89/year depending on the system | Yes, if your volume is below the threshold |
| Authorised representative in Germany | from ≈ €55/year; considerably more depending on volume and scope of services | Only for companies without an establishment in Germany |
| Provider handling registration and participation | ≈ €170–300/year + licence fee | No |
| Full service for larger companies | individual quote, several hundred to several thousand €/year | No |
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
| Material | 2026 market average, net | Change vs. 2025 | Examples |
|---|---|---|---|
| Glass | cheapest 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, net | Term | Notice period |
|---|---|---|---|
| activate (Reclay) | from ≈ €12 per order | no commitment | — |
| EASY-LIZE (EKO-PUNKT) | €23.90 | 1 year | 3 months |
| Verpackung-Direkt (Noventiz) | €35 | 1 year | 4 months |
| VerpackGo (Der Grüne Punkt) | €36 | 1 year | 3 months |
| Lizenzero (Interzero) | €39 | 1 year | 3 months |
| EASyShop (Landbell) | €50 | 2 years | 6 months |
| Zmart (Zentek) | €59 | 1 year | 3 months |
| PreZero Dual | ≈ €79 | 1 year | 3 months |
| BellandVision | €89 | 1 year | 4 months |
- Reclay activate: prepaid, early-booking discount of up to 25 %; unused credit expires on 31.12.
- Der Grüne Punkt: volume credit of up to 10 % possible.
- Lizenzero: volume correction until 31.08.
- Recycling Dual: licensed via EASY-LIZE since July 2026.
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.
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:
- 3 months (most systems): notice by 30 September
- 4 months (Noventiz, BellandVision): by 31 August
- 6 months (Landbell): by 30 June – with a 2-year term
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
- Weigh each component separately: box, film, filling material, tape. A kitchen scale is enough.
- Record the weight in kilograms with three decimal places, e.g. 0.152 kg.
- Multiply by the number of shipments per year.
- 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.
- TBA Global: authorised representative + registration + annual participation fee (23 countries) – ≈ €100/year. Licence fee not included (billed separately by actual weight).
- AuthoriseMe: authorised representative + licensing – ≈ €300/year. Licence fee included up to 100 kg of packaging.
- BellaCocool GmbH: handles registration and system participation; advice, including on electronics and batteries; over 10,000 clients – ≈ €170/year. Licence fee not included.
- Deutsche Recycling, Landbell, take-e-way, Lizenzero.eu: authorised representative, full service, several countries – price on request (individual quote for larger companies).
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
- The PPWR (EU Regulation 2025/40 on packaging and packaging waste) applies. It works directly in all EU countries and sets requirements for the packaging itself: composition, labelling, declaration of conformity.
- The VerpackDG is in force – the German act implementing the PPWR. It replaces the VerpackG but keeps its core: LUCID register, dual systems, licence fee, reporting.
- What stayed the same: LUCID registration is free and mandatory, dual-system participation is mandatory, Amazon and other marketplaces block unregistered sellers.
- What changed for foreign companies: a company without an establishment in Germany that sells directly to German consumers must appoint an authorised representative based in Germany and confirm it in LUCID. This applies to companies from the EU just as from China or the USA – what matters is not the country but the lack of a German establishment. Companies with an establishment in Germany do not need an authorised representative.
- New producer role: due to the new definition of producer, for some companies the party obliged to license has changed – for example for private labels and importers. Existing system participations under the old law remain valid at most until 31.12.2026 under § 68(1) VerpackDG. If your role has changed, check that the system participation for 2027 is in the name of the right company.
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.
| Example | Volume per year | Licence fee | Minimum fee / authorised representative | Total per year |
|---|---|---|---|---|
| 1. Micro seller, German company | 40 kg cardboard + 10 kg plastic | ≈ €19–29 | minimum fee ≈ €12 (Reclay), €59 (Zmart) up to €89 (BellandVision) | ≈ €19–89 |
| 2. Small seller, German company | 400 kg cardboard + 100 kg plastic | ≈ €190–295 | — | ≈ €190–295 |
| 3. Foreign company without establishment | 320 kg cardboard + 80 kg plastic | ≈ €150–235 | authorised representative from ≈ €55, often €170–350 and more (mandatory since 12.08.2026) | from ≈ €205, often €320–600 |
| 4. Medium seller | 2,400 kg cardboard + 600 kg plastic | ≈ €1,140–1,760 | — | ≈ €1,140–1,760 |
| 5. Large seller | 8,000 kg cardboard + 2,000 kg plastic | ≈ €3,800–5,860 | negotiated tariffs, support | from ≈ €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 year | Paper/cardboard | Plastic | Estimated licence fee |
|---|---|---|---|
| 1,000 | 170 kg | 20 kg | ≈ €56–87 |
| 5,000 | 850 kg | 100 kg | ≈ €280–440 |
| 20,000 | 3,400 kg | 400 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
- Vollständigkeitserklärung (declaration of completeness): mandatory above 80,000 kg of glass, 50,000 kg of paper/paperboard/cardboard or 30,000 kg of lightweight packaging (plastic, metal, composites) per year; due by 15 May. As a rule of thumb, the audit by a registered auditor costs ≈ €2,500–3,000.
- Single-use plastics fund: a separate levy on certain single-use plastic products, e.g. bags and wrapper packaging €0.876/kg, takeaway food containers €0.177/kg, beverage cups €1.236/kg. Annual reporting via DIVID – in addition to the packaging licence.
- B2B and transport packaging: not subject to dual-system participation, but with a take-back obligation – via industry solutions or take-back contracts, considerably cheaper than household tariffs.
10. What is coming in 2027
- Eco-modulation: fees are to be graded by recyclability and recycled content (§ 26a VerpackDG), targeted for 2027. The required ordinance has not yet been issued. Likely: poorly recyclable packaging more expensive, mono-material and paper relatively cheaper.
- Plastic packaging tax: a draft by the coalition parliamentary groups provides for €550 per tonne of plastic from 1 July 2027. Not yet adopted. If it comes, that would be around €0.55/kg extra on plastic – probably via the purchase price of the packaging.
- Fines for PPWR infringements apply in Germany from 12.02.2027.
- The systems' prices for 2027 have not yet been published.
11. 7 ways to cut licensing costs
- Reduce plastic: paper tape and paper cushioning instead of bubble wrap.
- Choose mono-material instead of composites.
- Fit the box size to the product – less cardboard, fewer kilograms.
- Use the early-booking discount (Reclay up to 25 %).
- Do not over-license; correct volumes where possible (Lizenzero until 31.08., Grüner Punkt up to 10 %).
- Compare every year and keep an eye on the notice period.
- 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).
- Small seller, German company (up to 500 kg): ≈ €19–295 / year
- Small foreign seller with authorised representative (up to 500 kg): from ≈ €75 / year, often €250–650
- Medium seller (2,000–5,000 kg): ≈ €800–3,000 / year
- Large seller (from 10,000 kg): from ≈ €3,500 / year (individual)
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.
| Country | Register / system | Authorised representative for foreign sellers | Indicative authorised representative package per year* | Specific feature |
|---|---|---|---|---|
| Germany | LUCID / 10 systems | yes, without a German establishment | from ≈ €55, considerably more depending on volume | public register; Amazon checks automatically |
| Netherlands | Verpact | yes | ≈ €160 | fee only from 50,000 kg per year |
| Belgium | Fost Plus, Valipac | yes | ≈ €250 | household and industrial packaging separate |
| France | Citeo / ADEME | yes | ≈ €250 | Triman logo and sorting instructions |
| Spain | Ecoembes / MIRE | yes | ≈ €320 | separate tax on plastic packaging |
| Sweden | NPA | yes | ≈ €370 | registration in the state register |
| Austria | ARA / EDM | yes | ≈ €480 | authorised representative mandatory for distance sellers |
| Italy | CONAI | yes | ≈ €500 | environmental contributions by material |
| Poland | BDO register | yes | ≈ €500 | annual report in BDO |
| Ireland | Repak | yes | ≈ €1,640 | one 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
- Retroactive licensing: the full licence fee for every missed year. This does not rule out fine proceedings.
- Fine: up to €200,000 for missing system participation, up to €100,000 for missing registration or declaration of completeness (§ 66 VerpackDG, previously § 36 VerpackG). Fines are imposed by the state (Länder) authorities; the ZSVR reports infringements to them – around 20,750 suspected cases for 2019–2022, half of them foreign companies. More on fines
- Sales ban: unlicensed packaging may not be sold.
- Warning letter (Abmahnung) from competitors: ≈ €280–1,600 in legal fees (typically €800–1,000); contractual penalty of €3,000–5,000 for repeat infringements. LUCID is public – anyone can check.
- Amazon suspension: lost sales until reactivation (2–5 working days after correction).
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
- ZSVR — registration and reporting are free
- ZSVR — authorised representative since 12.08.2026
- European Commission – PPWR enters into application
- Verpackungslizenz24 — price trends and average prices 2026
- Verpackungslizenz-Vergleich — minimum prices, terms, notice periods
- § 68 VerpackDG – transitional provisions
- EWKFondsV – levy rates of the single-use plastics fund
- Händlerbund — warning-letter costs
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.