Costs and fees in the VerpackG dual system - how much does a LUCID and packaging licence really cost in Germany?

Costs and fees in the VerpackG dual system has to be split into two parts: a free registration with LUCID and a paid packaging licence with the dual system operator. A trader selling packaged goods to Germany does not pay for obtaining a LUCID number per se, but bears the cost of packaging participation in the recycling system if he introduces packaging that falls under the mandatory participation system. In e-commerce, this usually applies to shipping cartons, envelopes, fillers, films, tapes, labels and product packaging going to the customer in Germany.

The most important conclusion for a company planning to sell to Germany is simple: LUCID is not a licensing cost, but without LUCID it is not possible to correctly conclude and report a contract in the dual system. The ZSVR points out that, with packaging covered by the participation scheme, you have to enter into a contract with the scheme operator, pay for recycling and report the same masses of packaging in the LUCID register.

How much does it cost to register with LUCID?

Registration with LUCID is free of charge. The ZSVR does not charge a fee for setting up an account, obtaining a registration number, reporting data or register administration activities. The cost only arises when a company needs to ensure that packaging is involved in the dual system.

This distinction is important because, in practice, entrepreneurs often ask: „how much does LUCID cost?”, while in reality they have three different things in mind:

Element	Is it payable?	Comment
Registration with LUCID	Not	the LUCID number is allocated free of charge
Data reporting to LUCID	Not	data must be reported, but the ZSVR does not charge for this
Agreement with the dual system	Yes	cost depends on weight, material and operator
Advisory services	Depends on the company	the cost of the services of an external advisor, if the entrepreneur is supported
Corrections and organisation of data	Indirectly yes	cost in terms of working time, systems, procedures and risk of errors

If you need a procedure for registration alone, the related material is the EKOPRO service: LUCID audit - LUCID registration step by step.

What is paid in the VerpackG dual system?

Paid is packaging licence, i.e. the share of packaging in the dual system. In practice, the entrepreneur enters into a contract with the system operator, declares the expected weight of packaging by material fraction and pays a fee to finance the collection, sorting and recycling of this packaging.

The ZSVR describes the participation system as the financial responsibility of the producer for the sales, bulk and shipping packaging covered. An agreement with the system operator is mandatory if a company markets such packaging in Germany.

The term „contract with a recycling company in Germany” often appears in the language of entrepreneurs. It is more accurate to speak of contract with the dual system operator. The operator is not a simple collector of waste from the company. It is a systemic entity that organises the financing of post-use packaging management in the German market.

What does the e-commerce recycling charge depend on?

The e-commerce recycling fee mainly depends on three factors: the weight of the packages, the type of material and the rates of the selected dual system operator. The ZSVR points out that the cost of the packaging share depends, among other things, on the volume and type of packaging material.

In practice, the online shop should count:

how many shipping cartons go to Germany each year,
what is the weight of one carton,
how many envelopes, foil, tape, labels and fillers it uses,
which product packaging reaches the German customer,
what materials the packaging is made of,
whether the sale involves B2C, marketplace, fulfilment or its own shop,
whether the declared weights are planned, actual or adjusted after one year.

The simplest operational formula looks like this:

annual cost = weight of packages of a given fraction × operator's rate for this fraction + minimum or administrative charges of the operator, if any

However, a one-size-fits-all price should not be published. Dual system operators use their own price lists, thresholds, minimum order values and billing models. Therefore, the cost for a shop sending 100 parcels per year will be completely different from an e-commerce brand sending several thousand orders per month.

Material fractions - what needs to be counted?

In the dual system, it is not only the number of packages that counts, but the weight of packages by material. The ZSVR indicates that the types of materials, such as paper, cardboard and cardboard, plastics, ferrous metals or glass, and the weight of the packages in kilograms must be reported when reporting the data.

The most common material fractions in e-commerce are:

Fraction	Examples in the webshop
Paper, cardboard, paperboard	shipping cartons, boxes, paper fillers, wrappers
Plastics	stretch foil, bubble foil, foil envelopes, plastic fillers
Glass	bottles, jars, cosmetic and food packaging
Ferrous metals	steel cans, some closures
Aluminium	tubes, trays, closures, aluminium foil
Composites	multi-material packaging that cannot be easily separated by hand
Beverage cartons	beverage cartons

In the ZSVR documents relating to the declaration of completeness, there also appears a collective category of lightweight packaging, covering ferrous metals, aluminium, plastics, beverage cartons and other composites together. Thresholds for declaring completeness include 80,000 kg for glass, 50,000 kg for paper/board/cardboard and 30,000 kg for this collective category of light packaging.

For most small online shops, these thresholds will not be a problem, but the way in which materials are grouped is already useful at the stage of daily packaging records.

Cardboard, paper and shipping cartons - the most common cost in e-commerce

In online shops, the largest fraction is usually paper, cardboard and cardboard. This includes shipping cartons, product boxes, paper fillers, dividers and other paper parcel items.

The mistake is to count only the main carton. If a paper filler, a paper wrapper, a leaflet that is part of the package or an additional product box is included in the package, these elements can also be relevant in the weight calculation.

A practical example:

Parcel element	Material	Do you count?
Shipping carton	cardboard	Yes
Paper filler	paper	Yes
Packaging tape	plastic or paper, depending on type	Yes
Courier label	paper / plastic, depending on execution	Usually so
Product box	cardboard	Yes, if the shop markets them in Germany
Receipt or invoice	sales document	Do not automatically treat as packaging; requires evaluation of function

If you are selling online, an EKOPRO article would be a good addition: Packaging in e-commerce and BDO and LUCID.

Glass and heavy packaging - why can they change the calculation?

Glass is a heavy material, so even a relatively small number of products can generate a lot of packaging weight. This is particularly true for cosmetics, supplements, candles, food, beverages, premium products and household chemicals.

For the trader, this means that the cost of the licence does not always increase in proportion to the number of orders. A shop sending few parcels but in heavy glass packaging may have a higher packaging weight than a shop sending more lightweight products in cardboard boxes.

With glass, you need to verify:

whether the shop is the first to introduce a product in glass packaging to Germany,
whether glass is sales packaging,
whether the product reaches a private consumer,
whether the weight of the glass is counted separately from the shipping carton,
whether the data is based on the manufacturer's specifications and not on an estimate.

This is particularly important for private label brands, importers and manufacturers selling directly to customers in Germany.

Lightweight packaging - plastics, aluminium, metals and composites

Lightweight packaging is often overlooked because the entrepreneur focuses on cardboard. Meanwhile, films, envelopes, tapes, tubes, blisters, laminates, sachets and composites can form an important part of the packaging mass, especially with cosmetics, electronics, accessories, food, toys and lifestyle products.

In e-commerce, lightweight packaging includes:

foil envelopes,
bubble wrap,
stretch film,
packaging tape,
plastic fillers,
blisters,
sachets,
aluminium tubes,
metal cans,
multi-material packaging.

The greatest risk concerns composite packaging, as it cannot always be intuitively assigned to a single fraction. If a package consists of several materials that cannot be separated manually, it requires a separate classification. With larger sales volumes, such errors can affect reporting and the cost of licences.

How do you calculate the cost of a dual system before entering the German market?

Before entering the German market, it is not necessary to know the exact mass for the whole year, but a reliable forecast must be prepared. The dual system operator needs planned data and after one year adjustments or reporting of the actual weights may be required according to the contract.

A good starting calculation should look like this:

Step 1: Identify all packages

Do not limit the list to the shipping carton. Include product packaging, wrapping, fillers, films, labels, tape and protective items.

Step 2: Divide packaging into material fractions

Assign each item to a material: paper/board/cardboard, plastic, glass, aluminium, ferrous metals, composites or another appropriate category.

Step 3: Determine the unit weight

The weight can come from a supplier's specifications, a product card, an invoice or your own weighing. For a small e-commerce business, a simple table will suffice, but the data should be reproducible.

Step 4: Estimate the volume of sales to Germany

Count sales to Germany separately, not all shop sales. LUCID and the dual system apply to packages entering the German market.

Step 5: Compare operator offers

The cost depends on the provider's rates, minimum charges, adjustment terms, scope of support, reporting panel and document handling. The lowest price is not always the best if a company needs a stable reporting process.

Step 6: Report the same data in LUCID

The ZSVR indicates that any mass reported to the system operator must also be reported in LUCID without undue delay and at the same value.

Example calculation without fictitious rates

Do not come up with prices per kilo, as rates change between operators and billing periods. However, a calculation model can be shown.

Let's assume that an online shop plans to send 2,000 parcels to Germany each year. Each parcel contains:

shipping carton: 120 g,
paper filler: 20 g,
tape and label: 5 g of plastic/paper, depending on the material,
product packaging made of cardboard: 40 g.

The annual weight of paper/cardboard can be:

2 000 × (120 g + 20 g + 40 g) = 360 000 g = 360 kg

To this must be added the remaining materials, e.g. plastics from tapes, labels, films or wrappers. Only the masses prepared in this way can be entered into the dual system operator's calculator or forwarded for quotation.

The greatest value of such a calculation is not the accuracy to the gram, but the consistency of the methodology. The company should be able to explain where it has taken the data from and why it has assigned packaging to specific fractions.

Contract with a recycling company in Germany - how to choose an operator?

The choice of a dual system operator should take into account not only price, but also quality of service and reporting compliance. The ZSVR indicates that the trader must contract with one or more system operators and then report to the relevant masses.

When choosing an operator, check:

whether the operator is a recognised dual system,
whether it handles small e-commerce volumes,
whether it has an easy-to-read online calculator,
whether it allows the masses to be easily corrected,
whether it accounts for all necessary material fractions,
whether it issues the documents needed for inspection,
whether data can be easily transferred to LUCID,
whether the service is available in a language the company understands,
whether there are minimum fees or administrative charges,
whether conditions are convenient for seasonal sales.

For a Polish company selling to Germany, the choice of operator should be part of a broader analysis of EU obligations. A natural internal link is the EKOPRO service: Solutions for the introduction of products and packaging in the EU.

Is the cheapest dual system operator always the best?

The cheapest licence does not always mean the lowest real cost of compliance. If an operator has a poor panel, unclear adjustment terms, lack of reporting support or difficult documentation procedures, the company may lose more time than it saves on the fee.

With small volumes, price will be important, but with larger sales, price also counts:

the possibility of reporting corrections,
availability of confirmations,
transparency of material fractions,
LUCID data compatibility,
marketplace operation,
easy contract renewal,
the possibility of reporting actual weights after the end of the year.

In practice, the entrepreneur should look at the total cost: licence + service time + risk of errors + potential blocking of sales on the marketplace.

Marketplace and fulfillment - additional costs of non-compliance

Marketplace and fulfilment operators may require a LUCID number and confirmation that packaging obligations have been met. Non-compliance can block sales, even if the shop has a finished product, logistics and advertising campaigns.

The ZSVR points out that breaches of VerpackG obligations can lead to distribution bans and penalties, with a penalty of up to €200,000 for lack of a participation system. For breaches of registration obligations, the possible penalty is up to €100,000 and for data reporting breaches up to €10,000.

For e-commerce, the cost of non-compliance is therefore sometimes greater than the licence itself. Risks include:

blocking of offers on the marketplace,
refusal of service by fulfilment,
the need for urgent data correction,
loss of sales in Germany,
risk of administrative penalties,
problems with B2B counterparties checking the public register.

Costs of the dual system and profitability of market entry in Germany

Before entering the German market, it is worth calculating the recycling fee as much as the cost of payment, marketplace commission, logistics, returns and advertising. With low-margin products, even a seemingly small fee can make a difference, especially if the packaging is heavy or multi-material.

Add to the profitability calculation:

the cost of the packaging licence,
the cost of data handling and reporting,
the cost of consultancy, if the company needs it,
the cost of potential corrections,
the cost of adapting packaging,
the cost of serving other EU countries separately,
Risk of sales blocking in the absence of EPR numbers.

The entrepreneur should not just ask „how much does LUCID cost?”, but rather: What is the cost of a compliant packaging launch in Germany in my sales model?

How to reduce the cost of recycling charges without risk?

The costs of the dual system can be reduced legally, but not by undercutting the masses. The safest measures are to optimise packaging and improve data.

Practical ways:

reducing the weight of the cartons without compromising transport safety,
limiting the number of layers of packaging,
dispensing with unnecessary inserts and decorative elements,
choice of homogeneous material packaging,
reduction in composite packaging,
standardisation of carton sizes,
better matching of the package to the product,
counting German sales separately, instead of inflating the figures with all EU sales,
keeping monthly records rather than reconstructing the masses after a year.

Packaging optimisation is doubly beneficial: it reduces the masses reported to the dual system and improves logistics costs. With a larger scale of sales, these two effects can be more important than the difference in the operator's price list alone.

If a company wants to put both BDO in Poland and LUCID in Germany in order, it will be helpful to comprehensive environmental consultancy.

The most common errors in VerpackG costing

The most common errors are due to counting costs too late or confusing registration with licence.

Typical mistakes include:

the assumption that LUCID registration is payable,
the assumption that the LUCID number is sufficient without a dual system,
not including tapes, labels and fillers,
counting the number of parcels instead of the weight of materials,
omitting product packaging when private labelling,
lumping all material into one category,
no adjustment after change in sales volume,
reporting of other masses to the operator and others to LUCID,
operator selection by price only,
no documentation confirming the weights of the packages.

The safest model is a monthly summary of packaging by fraction. Then the annual reporting is not a fallback, but a summary of the process.

Frequently asked questions

How much does it cost to register with LUCID?

Registration with LUCID is free of charge. The ZSVR does not charge for registration, data reporting or record-keeping activities. A fee may be payable for packaging participation in the dual system if a company introduces packaging covered by such an obligation.

What does it cost in the VerpackG dual system?

The cost is generated by the packaging licence, i.e. the contract with the operator of the dual system. The entrepreneur pays to finance the collection, sorting and recycling of packaging covered by the participation system.

What does the e-commerce recycling charge depend on?

The charge depends mainly on the weight of the packaging, the type of material and the operator's rates. Paper and cardboard are billed differently, glass, plastics, aluminium, metals or composites.

Does the shipping carton need to be included in the cost?

Yes, if it is shipping packaging covered by the mandatory participation system and goes with the product to the German market. In e-commerce, shipping cartons are usually one of the main cost fractions.

Do you have to report the same data to the operator and LUCID?

Yes. Data reported to the dual system operator must also be reported to LUCID at the same value and without undue delay.

Can the dual system operator be changed?

As a general rule, the trader selects a dual system operator and enters into a contract with it under certain conditions. A change of operator requires a check of the contract period, reporting obligations, corrections and data compliance in LUCID.

Do you need LUCID and dual system costing?

If you are planning to sell to Germany and would like to calculate the cost of a packaging licence, sort out material fractions or choose a dual system operator, contact EKOPRO Group. Go to Contact and describe your sales model, types of packaging, estimated number of shipments to Germany and sales channels. EKOPRO will help determine which packages need to be licensed, how to count the weights and how to prepare the data for LUCID and the dual system.