Separate statutory fees, system participation, service and catch-up
Fully outsourced EPR compliance has no universal price. The budget consists of four blocks: statutory authority fees, system participation fees, the service provider's fee and, where applicable, costs for historical catch-up. Only this separation makes quotes comparable. Research on the legal position as of September 2026 found no flat service price for all setups; the reliable fixed values are at authority level.
- Statutory fees: registration and quarterly fees charged by the authorities. They apply regardless of the service provider.
- System participation: licensing of packaging volumes per material and kilogram; for electrical equipment and batteries, the contributions to the take-back schemes.
- Service: one-off setup and ongoing handling of registrations, reports and correspondence.
- Catch-up: retroactive licensing of past volumes and fee reviews by the authorities if obligations went unmet in the past.
The authority level is well documented. Registration in the LUCID packaging register is free of charge and done online, according to the ZSVR's help pages.[1] It is an obligation of the producer itself;[2] costs arise through system participation and the service contract, not through registration. For electrical equipment and batteries, stiftung ear charges fees on the basis of the ElektroGBattDGGebV.[3] Its fee examples list 9.50 euros per registration and type of equipment (fee 1.1) and a quarterly fee of 32.80 euros (fee 1.2) for the ElektroG.[4] For batteries, the rates are 16.40 euros per registration in a battery category (fee 2.1) and 3.80 euros per quarter (fee 2.2).[4] The lower battery fee does not replace the ElektroG quarterly fee: if you are registered in both streams, you pay both. The amounts stated by stiftung ear are net amounts, plus the VAT applicable at the time;[4] the fee ordinance also makes clear that VAT is added to the fee where the service is subject to it.[3]
At scheme level, the volume principle dominates. Fees depend on material and kilogram, and easily recyclable materials are rated lower. The tariff structure of the Dutch packaging scheme Verpact shows the logic: tariffs per material type, plus a discount for using recycled content, which according to Verpact's tariff page was raised from 10 cents to 20 cents per kilogram for 2025.[5] Which rate applies to you is decided by the scheme contract for your volumes, not by the service provider.
These four blocks affect every setup, but their size depends on your own. If you want to assign roles, countries and volumes properly, the overview How it works shows the process from analysis to implementation.
Setup and annual service fees
Calculate one-off and recurring items separately. The setup covers every registration that the outsourced scope touches: per country, per stream, that is packaging, electrical equipment and batteries, and per brand and type of equipment or battery category. Ongoing costs arise with every quarter and every volume report.
- Packaging registration: the producer's LUCID entry, free of charge; the ZSVR expressly states that registration is free.[1]
- ElektroG registration: 9.50 euros net per registration and type of equipment, fee 1.1 of the ElektroGBattDGGebV, according to the stiftung ear fee example.[4]
- Battery registration: 16.40 euros net per registration in a battery category, fee 2.1, also from the stiftung ear fee examples.[4]
- Setting up the contract with the dual system or take-back scheme and setting up the data reports.
| Recurring item | Due | Basis of assessment |
|---|---|---|
| stiftung ear quarterly fee, ElektroG | per calendar quarter begun | 32.80 euros net per ElektroG registration number, fee 1.2, according to the stiftung ear fee examples[4] |
| stiftung ear quarterly fee, batteries | per calendar quarter begun | 3.80 euros net per BattDG registration, fee 2.2, according to the stiftung ear fee examples[4] |
| Packaging system participation | per volume report | Kilogram per material, tariff under the scheme contract; Verpact shows this structure per material type[5] |
| Service fee | usually monthly or quarterly | Scope and price are set out in the service contract |
Historical catch-up does not belong in the annual budget. Retroactive licensing of past volumes, fee notices for earlier periods and register audits weigh once on the year in which they are dealt with. Show these items separately, otherwise you compare a clean-up year with a normal year.
Like-for-like quotes and assumptions
Request quotes on the basis of your own role. Whether you manufacture yourself, import, trade with suppliers who are already registered or have yourself represented determines the scope of registration, the reporting obligations and therefore the price. Only then fill in the template.
| Cost block | Year or cycle | Unit | Net basis | Assumption |
|---|---|---|---|---|
| LUCID registration | 2026 | per producer | 0 euros[1] | Registration is the producer's task, no authority fee |
| ear registration ElektroG | one-off per case | producer, brand, type of equipment | 9.50 euros (fee 1.1)[4] | Count the types of equipment in advance |
| ear quarterly fee ElektroG | per quarter begun | per ElektroG registration number | 32.80 euros (fee 1.2)[4] | Count the ElektroG registration numbers |
| ear registration BattDG | one-off per case | registration per battery category | 16.40 euros (fee 2.1)[4] | Define the battery categories in advance |
| ear quarterly fee BattDG | per quarter begun | per BattDG registration | 3.80 euros (fee 2.2)[4] | Count BattDG registrations separately |
| Packaging system participation | per volume report | kilogram per material | scheme tariff[5] | Use the material mix and previous year's volume |
| Service and catch-up | per quote | flat fee or per case | from like-for-like quotes | Fill in only from like-for-like quotes |
Enter the year, unit and net basis for each item. The ear rates are net; the VAT applicable at the time is added to the fee where the service is subject to it.[3][4] Deliberately leave service and catch-up prices open until like-for-like quotes are available; comparing across different cuts of countries, streams and volumes distorts the picture. The EPR needs analysis provides the country, stream and volume details for this template.
A general checklist cannot settle your setup. The decisive question is how roles are distributed in the individual case: who first places the packaging or the equipment on the German market, and who is the importer or consignee on the customs declaration? A ClearoSystems consultation assesses your role and next steps.
Outlook: what still needs confirmation
Today's position is documented; two points are still pending. The Packaging Law Implementation Act (VerpackDG) entered into force on 12 August 2026 and continues the implementation of the EU Packaging Regulation.[2] Registration, the obligation to participate in a system and data reporting remain core obligations.[2]
- Approval for packaging not subject to system participation: the ZSVR expects to provide the procedures under Section 19 VerpackDG from summer 2027 for organisations and from autumn 2027 for producers. The transition period for producers runs until 31 December 2027; from 1 January 2028, approval is required.[6]
- Cost of approval: whether and how much fees will apply for this has not yet been published. Only budget for this item once the ZSVR states it.
- Changes to fees and tariffs: both the ear rates and the scheme tariffs only change through a new instrument or a new tariff decision. Do not project today's rates onto future years.
What is settled today are the four cost blocks and the documented authority rates. What may change with the next instrument or tariff is the open part. To clarify your position today, request a ClearoSystems consultation. Our experts support the implementation and keep registrations, reports and deadlines in line with how the rules develop.
Frequently asked questions
- What does EPR compliance cost if I outsource everything?
- The budget consists of four blocks: statutory fees, system participation, service fees and catch-up costs. The authority fees are fixed and small: LUCID registration is free, and stiftung ear charges 9.50 euros net per producer, brand and type of equipment plus 32.80 euros per quarter for the ElektroG, and 16.40 euros plus 3.80 euros per quarter for batteries. System participation scales with material and volume; the service fee is set by the provider. There is no universal package price; what matters is your scope of countries, streams and volumes.
- Which authority fees apply regardless of the service provider?
- For packaging, registration in the LUCID packaging register is free and done online; it remains a strictly personal obligation of the producer. For electrical equipment and batteries, stiftung ear charges fees under the ElektroGBattDGGebV: 9.50 euros net per ElektroG registration (producer, brand, type of equipment) plus a quarterly fee of 32.80 euros per registration number; for batteries 16.40 euros per registration plus 3.80 euros per quarter. The amounts are net, plus VAT. The total changes with the number of brands, types of equipment and battery categories.
- From what size is a full-service provider worth it compared with handling it yourself?
- There is no fixed threshold. The effort grows with the number of countries, streams (packaging, WEEE, batteries), registrations and reporting cycles; every additional brand and type of equipment creates its own fees and reports. A service provider pays off when internal capacity and meeting deadlines can no longer be ensured, or when historical gaps need to be closed. The answer changes with your product range and sales structure, not with a tonnage or turnover threshold.
