Compare identical volumes, periods and services
Compare packaging licences only with identical material type, identical weight, identical period and identical scope of services. Without current quotes built the same way, there is no provably cheapest provider. Each dual system sets its participation fees itself. On its overview of system operators, the Central Agency Packaging Register (ZSVR) states that it offers no advice and may give no information on the choice or prices of the system operators; for specific questions on options, contract terms and costs it refers directly to the system operators.[1]
A comparison stands or falls with its conditions. Four points must match in every quote:
- Material type: every quote must cover the same material groups, for example paper, paperboard and cardboard as well as plastics, glass and the other material types.
- Weight: the kilograms to be licensed per material type must be the same in both quotes.
- Period: both quotes must cover the same participation period, for example the same calendar year.
- Scope of services: check which additional services are included and which are charged separately.
You are free to choose your contract partner. The ZSVR overview lists ten system operators: BellandVision, Der Grüne Punkt - Duales System Deutschland, EKO-PUNKT, Interzero Recycling Alliance (Lizenzero), Landbell, Noventiz Dual, PreZero Dual, Reclay Systems, Recycling Dual and Zentek. The ZSVR makes clear there that every company may decide freely with which system operator it concludes a system participation contract.[1]
These four conditions apply to the standard case: you yourself place packaging subject to system participation on the German market and conclude the contract directly. If your setup differs, for example because you hold a different role in the supply chain, clarify your position first. A ClearoSystems consultation sorts out role and obligations before you compare prices: Request a consultation.
Approved scheme or intermediary
First check who your contract partner actually is. Under Section 7(1) sentence 1 VerpackDG, producers must participate with their packaging subject to system participation in one or more schemes to ensure nationwide take-back; participation may also be arranged through a commissioned third party, which Section 7(1) sentence 3 VerpackDG expressly presupposes.[2] Both routes lead to the same goal, but the contract and termination terms can differ.
For proof, Section 7(1) VerpackDG applies: the scheme must confirm to the producer without delay, in writing or electronically, that participation has taken place, stating the material type and weight of the packaging concerned. This expressly also applies where participation was arranged through a commissioned third party under Section 5(1) sentence 1.[2] A quote and an invoice alone are not such a confirmation.
Clarify four questions before you sign:
- Who is the contract partner: the approved scheme itself or an intermediary?
- Who issues the participation confirmation under Section 7(1) VerpackDG, and does it state material type and weight?
- Which material volumes does the quote actually cover, and for which period does it apply?
- Which services are included in the fee, and which are added separately?
If the scheme's confirmation is missing, participation may have taken place but cannot be proven. Ask for the confirmation promptly after signing the contract and file it with your records.
Termination rules, corrections and proof
Align first, then compare: once volumes, material types, period and scope of services match, the contract details decide. Four checkpoints reveal the difference between two otherwise identical quotes:
- Minimum fees: some providers charge a service flat fee regardless of the licensed volume.
- Notice periods: check by when and how you can terminate the contract.
- Corrections: how can volume deviations found later be corrected?
- Participation confirmation: when and in what form do you receive the confirmation under Section 7(1) VerpackDG?
As an example of differing contract and process details: in the online shop of the dual system Interzero, Lizenzero, you first license your packaging volume and check these figures at the start of the following year against the volumes actually placed on the market; it is confirmed through the year-end volume report, which is due each year by 15 May both with Lizenzero and with the Central Agency.[3] Other system operators handle renewal, termination and correction differently. So compare these points not only between providers but also within a quote against your own processes.
A transitional rule applies to existing contracts: system participations under the previous VerpackG that took place before 12 August 2026 continue under Section 68(1) VerpackDG, but at the latest until the end of 31 December 2026, subject to differing private-law agreements.[4] Check the contract text before you assume an end in 2026: the private-law exception can provide for a longer term.
Outlook: what still needs confirmation
The rules described so far are set out in the Packaging Law Implementation Act (VerpackDG);[5] its transitional provisions consistently refer to the Packaging Act in force until 11 August 2026 and attach the new obligations to facts arising from 12 August 2026.[4] Three points, however, are still open and remain provisional:
- Approval of schemes: schemes that were authorised under Section 18(1) of the previous VerpackG as of 11 August 2026 are deemed approved within the meaning of Section 20(1) under Section 68(11) VerpackDG, provided they prove by 1 January 2027 that they meet further requirements of Section 20(2), such as arrangements for waste management, sorting and recycling capacities, self-monitoring mechanisms and insolvency-proof security.[4] Whether a scheme remains approved beyond that depends on this proof.
- Fee levels: how participation fees can be modulated on ecological criteria is anchored in the law, but their specific level and calculation are not conclusively set. Projections of today's tariffs into the future are therefore not reliable.
- Operational practice: the termination and correction processes of individual system operators may change with new contract templates. What counts is always the provider's current price list and current contract text.
Finally, for termination rules and proof: clarify your role first. Producer, importer, reseller and authorised representative carry different obligations, and the boundaries are drawn case by case, for example by the delivery date, the customs declaration or the moment ownership passes. These distinctions cannot be settled reliably with a general checklist.
To clarify your position today, request a ClearoSystems consultation. Our experts support the implementation and stay with you as the rules evolve. More on this: EPR for online retailers.
Frequently asked questions
- Which packaging licence is cheapest for the same volume?
- There is no general answer. A provably cheapest provider requires at least two current quotes with identical material type, weight, period and scope of services. The ZSVR may not give information on the prices of system operators and publishes no scheme prices; the VerpackDG sets no fees. What matters is what your specific volume profile costs, not a general ranking. The condition that changes the answer: only packaging that typically ends up with private end consumers is subject to system participation.
- Can I switch dual system at the turn of the year without informing the ZSVR?
- The choice of system operator is free. But system participation is stated with material type, weight and LUCID registration number, and the volumes must be reported regularly both to the system operator and to the LUCID packaging register. A change of scheme must therefore be reflected in your data reporting. The condition that changes the answer: packaging not subject to system participation, such as pure B2B packaging, needs no system participation and therefore no corresponding report.
- Does my system participation contract from before August 2026 still apply in 2027?
- In principle, no. System participations concluded before 12 August 2026 continue under Section 68(1) VerpackDG until the end of 31 December 2026 at the latest, unless the contract provides otherwise. So check the contract term and any differing agreements before you assume it continues. The condition that changes the answer: a private-law agreement can continue the contract beyond 31 December 2026.
