Detailed answers for sellers and companies working with the German market.
A dual system is a private provider you pay to fund the collection, sorting and recycling of your system-participation-liable packaging. Germany has several approved systems, including Der Grüne Punkt, Interseroh, Landbell, Reclay and others — the ZSVR maintains a full list of approved providers.
The systems differ in price and service scope but all cover the same legal duty. You only need one contract, not several systems at once. More on choosing one in What does packaging licensing cost?.
The fee is calculated mainly from two factors: material (paper, plastic, glass, metal, composites — each with its own price per kilogram) and the weight of packaging actually placed on the market.
In practice, multiply the weight per material by the chosen system's price per kilogram for that material, then sum across materials. Plastic is generally more expensive than paper or board, since recycling costs are higher. Concrete price examples are in What does packaging licensing cost?.
Yes, switching is generally possible at any time, usually at the end of the contractually agreed term or notice period. Check your existing contract's notice period beforehand to ensure uninterrupted system participation.
Important: your LUCID registration stays unchanged when switching — you simply update the new system participation there. Avoid any time gap between cancelling the old contract and starting the new one, since no valid system participation exists during that gap.
No. The "green dot" is a trademark of one specific dual system (Der Grüne Punkt / Duales System Deutschland), not a legal labelling requirement. You only need to display it if you're actually a contract partner of that specific provider.
Use a different dual system and this labelling doesn't apply — there's no general requirement to make system participation visible on the packaging itself. Compliance is proven solely through LUCID registration and the dual system contract.
For multi-material packaging — say, a plastic bottle with a paper label and a metal cap — weight is tracked separately by material share and billed at the respective material price, not as a total weight at a blended rate.
In practice, weigh each component individually or determine the percentage material share of the total weight. Composite materials that can't be clearly assigned to one material are often placed in a separate material category with its own price — check with your dual system for the correct classification if unsure.
If you source finished, pre-packaged goods from a manufacturer and resell them unchanged, the packaging may already be licensed by the manufacturer — but that doesn't automatically release you from your own duties. Ask for written proof of the licensing.
If you add your own elements — shipping box, extra filler, an outer wrap for dispatch — you're the first placer for those additional elements and reporting- and licence-liable accordingly.
Overestimating your advance report generally results in a credit or offset at the year-end report, depending on your dual system's terms — you'll have paid for more packaging than was actually placed on the market.
At the year-end report, correctly report the actual figures by 15 May, even if they're below the original forecast. Deliberately inflating a standing declaration "just in case" is unnecessary and can lead to unnecessary extra cost.
Yes. FBA (Fulfilment by Amazon) doesn't change the licensing duty — Amazon handles storage and shipping, not legal responsibility for packaging compliance. The owner of the goods remains the first placer on the market.
You must register with LUCID and join a dual system yourself regardless of the shipping model — for the product packaging as well as any additional Amazon shipping packaging, such as air pillows in envelopes, where used.
Recycling targets are legally mandated minimum shares that collected packaging must actually be recycled into — they vary by material. These targets indirectly affect fees: materials with more complex or costly recycling technology are generally more expensive to licence.
Practically, that means choosing recycling-friendly materials and designs can reduce licence costs over time, since dual systems also link their prices to the actual recycling effort involved.
Compare several providers based on the concrete price per kilogram for your relevant materials — differences between approved systems can be noticeable, especially at larger volumes.
Beyond the raw price, check minimum fees, contract terms and notice periods, and whether the provider offers extras such as automated LUCID reporting. A price comparison is especially worthwhile as your packaging volumes grow, since differences matter more at scale.
With most dual systems, you first pay an advance report for the coming year, based on an estimate of your packaging volumes — usually due by 31 December of the prior year.
If the actual volume diverges significantly during the year, many systems allow a mid-year adjustment to the advance report. At year-end, the final reconciliation against actual volumes happens through the year-end report.
Freistellung, also called self-fulfilment, refers to the option to organise the take-back and recycling duty for certain packaging outside a dual system yourself — for example, through your own take-back schemes.
In practice, self-fulfilment is rarely relevant for most online retailers, since it demands high organisational effort and is primarily designed for specific B2B arrangements with direct take-back. For regular e-commerce, participation in a dual system is the standard route.
Your legal duty to participate in a system remains even if your existing dual system becomes insolvent — you need to switch promptly to another approved provider to keep participation uninterrupted.
Fees already paid for services not yet delivered are generally treated as insolvency claims; whether and how much is refunded depends on the insolvency proceedings. Monitor your chosen system's financial standing and act early at the first signs of trouble.
No, a joint contract for two separate companies isn't available with dual systems — system participation is tied to the individual registered legal entity, just like LUCID registration.
Each company needs its own contract and its own LUCID registration, even if they're closely linked economically, such as sister companies. Pooling packaging volumes across company boundaries isn't legally permitted.
Returned, unused packaging that's reused for a new shipment was only placed on the market once and is therefore only reportable once — a return doesn't automatically reduce the originally reported volume.
If new packaging is used for the replacement shipment, that counts in addition to the original volume. Dual systems generally don't offer an automatic "credit" for returned but already-reported packaging.
Dual systems run plausibility checks, such as comparing declared volumes against prior-year figures or industry averages, and can request evidence for anomalies.
They also cross-check their own data against the LUCID register to ensure the volume declared to them matches the LUCID report. For larger discrepancies, a formal data audit can be requested.
Yes. If you close the business permanently, you should properly notify or deregister with both your dual system and your LUCID registration, to avoid later reminders or unnecessary reporting requests.
For the final active period, still file the regular year-end report with actual volumes, even if operations have already ceased. An abrupt, unannounced closure without deregistration can create unnecessary administrative work on both sides.
Many dual systems charge a minimum fee per year, regardless of actual packaging volume — depending on the provider it's usually a low double-digit euro amount and covers basic administrative overhead.
At very low packaging volumes, this minimum fee can exceed the pure volume-based calculation. For small volumes, it's worth comparing minimum fees specifically across providers, not just the per-kilogram prices.
For a mixed product range, track packaging volumes by material across all product categories together — there's no separate calculation by product type, only by packaging material and weight.
In practice: plastic packaging from electronics and plastic packaging from textiles are combined and billed at the same material price. Track volumes by material, not by product line.
"E-commerce packaging" isn't a separate legal term — in online retail it typically covers the shipping box, filler material, tape and the product packaging itself, reported like any other system-participation-liable packaging by material and weight.
The only distinctive feature in e-commerce is the higher share of shipping packaging relative to the product packaging itself, compared to bricks-and-mortar retail. The reporting process itself doesn't differ from other retail.
Dual system licence fees are generally deductible as business expenses, since they represent a legally mandated cost of running the business.
Treat the advance report as an expense of the year it's for, even if payment partly falls in the prior year. For the exact accounting and tax treatment in your specific case — particularly for payments spanning periods — consult your tax adviser.
Dual systems process declared volume data mainly to calculate the licence fee and to meet their own statutory reporting duties towards the ZSVR — they need to demonstrate that fees collected actually flow into collection and recycling.
The data is also cross-checked against the LUCID register to confirm your declaration to the dual system matches your LUCID report. Discrepancies between the two are a common trigger for follow-up questions.
Self-licensing — independently organising collection and recycling without an approved dual system — is generally not available in Germany for the standard system participation duty. The legal duty is met through participation in one of the approved systems.
A limited exception exists via Freistellung for specific B2B arrangements with direct take-back — for regular online retail, though, this is practically not relevant.
There's no separate calculation method for fast-growing start-ups — fees are based, as for any company, on actual material and weight of packaging placed on the market.
What becomes practically relevant with rapid growth is mainly the advance report: a forecast set too low at the start of the year can lead to a substantial year-end top-up if revenue grows quickly. If growth is strong, check whether a mid-year adjustment to the advance report is possible.
Packaging volume monitoring systems — usually custom software or spreadsheet solutions — link sales data from your shop or inventory system with stored packaging weights per item to calculate the reportable volume automatically.
For larger ranges or multiple sales channels, such an automated solution is significantly better than manual calculation, since it reduces errors and speeds up monthly data maintenance.
Yes. Free samples and test kits are subject to the same reporting duty as sold goods, as long as they're shipped packaged to recipients in Germany — the law doesn't distinguish between sold and freely distributed goods.
For large sample shipments, such as in B2B distribution, the volume can add up noticeably. Track sample shipments separately so they aren't overlooked in the regular report.
If the business closes mid-year, the advance report already paid for the remaining part of the year generally isn't refunded proportionally — the exact terms vary by dual system provider and contract.
Report the actual volumes for the period the business was active as part of the regular year-end report, even if operations ended early. Clarify refund terms directly with your provider before cancelling.
If you start operations mid-year, report the advance volume for the remaining period of the current year, not for a full calendar year — the calculation is prorated from the actual start of sales.
For the following full calendar year, plan normally with the expected annual volume. A realistic first estimate matters, since new businesses naturally have no prior-year figures to reference yet.
When switching to private label, you as the brand owner are the first placer for the packaging, even if an external manufacturer produces and packages it — the licensing duty sits with the commissioning party, not the contract manufacturer.
Important: every brand name you sell under must be listed in the LUCID register. Launch a new private label without updating the registration and you're formally unregistered for its products, even if your existing dual system contract continues running.
There's no separate notification duty for every individual product launch — the dual system doesn't expect a per-product advance report, only the regular quantity report on the agreed schedule.
A notification only becomes necessary when a new product introduces a new brand not yet listed in the LUCID register — then the registration needs to be updated accordingly, independent of the dual system itself.
Licence costs factor into pricing but are usually low relative to the sale price for most products — often a fraction of a cent per unit for small, lightweight items. They only become a noticeable price factor for very packaging-heavy or low-margin products.
More practically relevant for pricing is usually the choice of packaging material itself: lighter, more recyclable materials reduce both shipping costs and licence fees at the same time.
A dual system's material liability covers the actual organisation of collection, sorting and recycling of the packaging volumes licensed with it — it's accountable to the ZSVR for ensuring fees collected flow into these processes as intended.
For you as a seller, that means: once you pay the licence fee, you've met your system-participation duty — operational responsibility for the actual recycling sits with the dual system, not with you.
Dual systems are private companies and follow standard German business hours and public holiday rules — expect limited or no customer service availability on statutory holidays.
Digital processes such as online reporting or contract signing via the customer portal are generally available at any time regardless of holidays, since they're automated. For personal enquiries, plan around holidays with appropriate lead time.
Yes, the licensing duty stands regardless of an overestimate — what changes is only the year-end reconciliation, not the requirement itself. You still need valid system participation for every packaging unit actually placed on the market.
An overestimate in the advance report simply means you paid for more than was used, and that's corrected at the year-end report. The underlying duty to be licensed at all is unaffected by whether your forecast was too high or too low.
No. Only packaging that was actually filled with goods and placed on the market is reportable — packaging material still sitting unused in the warehouse doesn't count towards the annual volume.
That leftover material only enters the report for the year it's actually used to pack a shipment. For larger stock, run a simple inventory calculation to avoid confusing purchase with actual use.
Even with zero sales, an existing system participation and LUCID registration stay active if you expect to continue trading. For the affected reporting period, simply enter a volume of zero — both with your dual system and with LUCID.
If you're permanently closing the business, both registrations should be properly deregistered to avoid later confusion and unnecessary reminders.
Submit the requested evidence completely and on time — typically sales reports, invoices, weight determinations, and the calculation basis behind your quantity report. A well-documented, traceable methodology significantly shortens the audit.
Be ready to explain the calculation method used — for example, how you determined packaging weight per item. For larger discrepancies or uncertainty about the requirements, early contact with the dual system or specialist advice is worthwhile.