Do I owe EPR fees Germany

Check your own case

Choose your role, add your revenue and the packaging you supply, and the checker applies the rules this page describes to your figures. It runs in your browser and stores nothing.

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How the checker reaches a result

The checker asks the same questions in the same order for every place, and it stops with a result as soon as a question settles the matter. It never fills a missing answer in for you.

1. Whose brand is on the packaging? If it is another company's brand, you are not the producer for those goods under the roles recorded for Germany. If you have not said, the checker asks first.
2. Do you sell into Germany? A place where you report no sales returns not obligated.
3. Does a size limit apply? The checker compares your revenue or packaging weight with each limit on record and, where a limit is not met, returns below threshold.
4. Is an exemption on record for your case? An exemption that is not yet verified is never assumed, and the checker asks for more data instead.
5. Are related companies counted together? Where the rules add up affiliated companies, their figures are combined before the limits are compared.

Who is the producer in Germany?

The first question is whose duty it is. Germany assigns the duty by packaging level, and the table shows which roles count as the producer at each level.

• Germany: for other packaging the producer is the manufacturer or brand owner, manufacturer, importer, first distributor, or authorised representative.
• Germany: for primary (sales) packaging the producer is the manufacturer or brand owner, importer, first distributor, or authorised representative.
• Germany: for secondary packaging the producer is the manufacturer or brand owner, importer, first distributor, or authorised representative.
• Germany: for service packaging the producer is the manufacturer or brand owner, manufacturer, importer, first distributor, or authorised representative.
• Germany: for shipping packaging the producer is the manufacturer or brand owner, packer or shipper, importer, first distributor, online marketplace seller, or authorised representative.
• Germany: for tertiary (transport) packaging the producer is the manufacturer or brand owner, manufacturer, importer, first distributor, or authorised representative.

Find the row that describes you. Where more than one role appears in a row, the checker asks whose brand is on the product before it gives a result.

Does revenue matter in Germany?

Size limits in Germany

Some rules switch the duty on or off by size. These are the limits on record for Germany, each with what happens when you meet it.

The tonnage limit: 80 tonnes

Germany: the tonnage limit is 80 tonnes. Germany: at the tonnage limit of 80 tonnes, a declaration of completeness becomes due. Germany: the tonnage limit of 80 tonnes applies to figures at or above it. Germany: the tonnage limit is counted as follows: glass placed on the German market in the previous calendar year (reached or exceeded).

The tonnage limit: 50 tonnes

Germany: the tonnage limit is 50 tonnes. Germany: at the tonnage limit of 50 tonnes, a declaration of completeness becomes due. Germany: the tonnage limit of 50 tonnes applies to figures at or above it. Germany: the tonnage limit is counted as follows: paper, paperboard and cardboard in total, previous calendar year (reached or exceeded).

The tonnage limit: 30 tonnes

Germany: the tonnage limit is 30 tonnes. Germany: at the tonnage limit of 30 tonnes, a declaration of completeness becomes due. Germany: the tonnage limit of 30 tonnes applies to figures at or above it. Germany: the tonnage limit is counted as follows: ferrous metals, aluminium, plastics, beverage cartons and other composites in total, previous calendar year (reached or exceeded).

The tonnage limit: 10 tonnes

Germany: the tonnage limit is 10 tonnes. Germany: at the tonnage limit of 10 tonnes, a reduced duty applies. Germany: the tonnage limit of 10 tonnes applies to figures below it. Germany: the tonnage limit is counted as follows: packaging subject to system participation made available for the first time in the previous calendar year.

Exemptions in Germany

The rules we hold for Germany record no exemption beyond the size limits above.

What the rules cover in Germany

A duty applies only to the packaging and the sales channels that the rules cover. This is what is on record for Germany.

Germany: the rules cover these sales channels: retail, wholesale, online sales, and online marketplaces. Germany: a producer may pass the duty to another party under the rules.

Every case, worked through

Below, the same engine that powers the checker is run on a set of standard cases for Germany. Each case states the input, the result and the next step. The figures are test inputs set at half, equal to and twice each recorded limit, read as of November 4, 2026; they are not rules.

Packaging of 160 tonnes: above the limit

Your own brand is on the goods and you supply 160 tonnes of packaging, twice the limit of 80 tonnes. The rules we hold set no size limit that applies here, so your own brand on packaged goods is enough and the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

Packaging of 100 tonnes: above the limit

Your own brand is on the goods and you supply 100 tonnes of packaging, twice the limit of 50 tonnes. The rules we hold set no size limit that applies here, so your own brand on packaged goods is enough and the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

Packaging of 60 tonnes: above the limit

Your own brand is on the goods and you supply 60 tonnes of packaging, twice the limit of 30 tonnes. The rules we hold set no size limit that applies here, so your own brand on packaged goods is enough and the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

Packaging of 20 tonnes: above the limit

Your own brand is on the goods and you supply 20 tonnes of packaging, twice the limit of 10 tonnes. The rules we hold set no size limit that applies here, so your own brand on packaged goods is enough and the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

Above every limit

Your own brand is on the goods and every figure is above every limit on record. The rules we hold set no size limit that applies here, so your own brand on packaged goods is enough and the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

If you owe: what happens next

If the result is obligated, these are the steps on record for Germany. You register, report and pay yourself; Instica prepares the figures and the files.

Germany: registration is made with LUCID Packaging Register (ZSVR). Germany: registration is made by this party: The producer, or for a foreign seller without a German branch, its authorised representative. Germany: registration renewal: Master data must always be correct and current; update after changes. Germany: the registration identifier is called: LUCID registration number. Germany: the registration fee: Free of charge.

Germany: producers meet the duty through more than one producer responsibility organisation. Germany: membership of an organisation is not required. Germany: an authorised representative is required.

Deadlines on record

• Germany: the reporting deadline is June 1, 2027.
• Germany: the reporting deadline is December 31, 2026.
• Germany: the reporting deadline is May 15, 2027.