Why a simple price comparison isn’t enough
The typical breakdown goes like this: on the one hand, the service provider’s fee; on the other, the staff costs of the employee who has been handling the reporting so far. It sounds logical – but it doesn’t go far enough.
This is because some EPR costs are incurred regardless of who handles the administration: contributions to take-back and recycling systems, government fees, guarantees, and disposal costs. A service provider can review and optimize these items—but it cannot eliminate them entirely.
When making a make-or-buy decision, what therefore counts is what the internal organisation actually costs:
- Research and review of legal obligations
- Research into and verification of the systems and, where applicable, authorised representatives abroad
- Registration and contract management with public authorities, systems and third parties
- Processing and checking quantities
- Preparation and timely submission of reports
- Monitoring deadlines and legislative changes
- Communication with public authorities, registers and systems
- Corrections, late entries and internal coordination
And then there are the costs that don’t appear on any invoice: the product launch that’s on hold because a registration is missing; the report that’s left undone because the only person trained to handle it is off sick; the regulatory requirement in the new sales market that simply nobody was aware of.
Country and region combinations: the key factor
For the purposes of economic assessment, we use the term ‘compliance unit’. Each cell represents a combination of a destination country and an EPR area. Germany + packaging: one unit. Add electrical components and batteries, and that makes three in total. If you also deliver to France and Austria, that figure rises to nine.
And these nine cells are not identical copies of one another. The following differ from one country to another:
- Manufacturer definitions and registration bodies
- Take-back schemes and reporting frequencies
- Product and material categories
- Duties of authorised representatives
- Rules on labelling, documentation and retention
The EU Packaging Regulation (PPWR) will take effect in phases starting in August 2026. It harmonizes packaging requirements—but does not replace national registration and reporting processes. You should check the specific transition periods for each target market.
Break-even: What does an internal hour really cost?
Gross salary alone is the wrong metric. What matters is the total cost: employer contributions, workspace and IT, management, holiday and sick leave, further training, time spent on coordination, and overheads. Depending on the role, this can be significantly higher than the calculated hourly rate.
The formula:
Economically justifiable service provider fee = hours of work saved × full cost rate + additional costs saved + risk costs avoided
Calculation example: A company with four compliance units requires around 200 hours per year internally, provided that the registrations have been granted. In the year of the initial registrations, the workload is significantly higher due to the necessary preparatory work and the establishment of partnerships. Let us consider a year in which all registrations have already been granted: At a full-cost rate of €75, this amounts to €15,000 in internal labour costs for 200 hours of work. A full-service solution reduces the workload to around 40 hours (data provision, approvals, checks) – leaving €3,000. With a service fee of €800 per country and sector, the total costs amount to €3,200 (plus tax). Savings: €8,800. This does not include fees and disposal costs charged by foreign third parties, although these would be incurred in both scenarios anyway. However, as your service provider, we can ensure that these are kept to a minimum, as we work with selected partners.
Important: This is an example, not a benchmark!
When it’s cheaper to buy in-house
Internally, it pays off when the obligations are stable and manageable: just Germany, just packaging, accurate data on materials and quantities, few reports per year, and clear lines of responsibility.
When it comes to compliance with German packaging regulations alone, outsourcing faces legal limitations anyway: German companies subject to these requirements must submit their LUCID data reports themselves or through authorized employees. External service providers may prepare, review, and assist with the process—but they cannot simply take over the submission itself. Exception: foreign companies without a German branch that have a designated authorized representative.
The situation is different when large volumes of packaging require a certified declaration of completeness. In that case, the amount of data required, the depth of the audit, and the time pressure all increase significantly.
When full service pays off
The benefits become apparent as soon as several factors contributing to complexity come together. For example, if a company places packaged electrical devices containing batteries on the market in Germany, obligations under the Packaging Act (VerpackG), the Electrical and Electronic Equipment Act (ElektroG), and the Battery Act (BattDG) may apply simultaneously, depending on the manufacturer’s role and the product.
Electrical and electronic equipment must be registered with a brand name and product type before being placed on the market—without registration, distribution is prohibited. Marketplaces and fulfillment service providers are not permitted to process unregistered products. The quantities placed on the market must be reported regularly in Germany , in some cases even monthly. Companies without a German branch office must also appoint an authorized representative in Germany.
For batteries, manufacturers must either participate in an approved producer responsibility organization for each category or fulfill their extended producer responsibility individually in accordance with the legal requirements. Battery categories and relevant quantities must be updated on a calendar-year basis.
Even within Germany, several registration, contractual and reporting processes run in parallel. With every additional country of sale, the number of points of contact, registrations, obligations and deadlines increases – and with it, the coordination workload.
Classification by number of country and sector combinations
| Scope | A Model That Is Often Useful |
| 1–2 combinations | In-house processing, ad hoc consulting |
| 3–5 combinations | Compare hybrid and full-service options |
| 6–15 combinations | Full-service is often more affordable |
| 16–30 combinations | Full service is definitely more affordable |
| >30 combinations | Compare a central competence center and internal management with external local implementation versus a full-service model |
The real effort comes before the notification
Clicking on the portal is rarely the problem. The real work happens beforehand: Which company is the designated producer in the relevant country? Which packaging components form part of a product – and how much do the cardboard, film, label and filling material weigh? Is it a domestic or commercial appliance? What type of battery is fitted? What quantities were actually placed on the market in which country? In which category should which material or product be reported? And in terms of total weight, number of items or sales unit?
If this information is missing, even the best service provider will be unable to produce a reliable report. A full-service solution therefore offers the greatest added value when it does not begin at the portal stage, but starts right from the outset with data requests, product classification, plausibility checks and quantity allocation – and when we are able to assist you with data preparation.
Even after outsourcing, responsibility remains in-house: coordinating data, reporting changes to the portfolio, checking and approving reports, and monitoring the service provider. The difference is that this person no longer needs to be fully familiar with every national portal and every detailed rule themselves.
The realistic cost-benefit analysis therefore does not compare “employees or service providers,” but rather full in-house processing versus the service provider’s fee plus the remaining management effort.
Quantifying risks – not just fines
Anyone who thinks of fines as the only risk involved is underestimating the issue. Sales suspensions, delayed product launches, blocked marketplace listings, tied-up stock – and the cost of urgent consultancy and retrospective notifications – are equally significant from a financial perspective.
For time-sensitive products, outsourcing can therefore be worthwhile, even if the sheer saving in working time seems modest.
Be wary of ‘full-service’ offers
‘Full-service’ is not a protected term – as a result, the scope of services varies across the market. Some providers simply supply fully processed data, whilst others also assist with registrations, classifications, contract management, legal representation and regulatory monitoring.
Five questions for a fair comparison:
- Billing basis: By country, legal entity, product range, brand, device type, registration or notification?
- External costs: Are government fees, system charges, guarantees and testing costs included – or not?
- Data preparation: Who carries out the classification and calculations – you or the service provider?
- Changes: How much do new countries, brands and products cost?
- Transparency: Do you have access to registrations, supporting documents, contracts, notifications and status updates?
- Termination: What happens if a country or region is no longer covered? Can you terminate the contract on a case-by-case basis, or are you bound by long notice periods and contract terms?
When exactly you should compare
We recommend carrying out a structured make-or-buy analysis as soon as at least two of the following points apply:
- Sales in at least two countries
- Several EPR areas affected
- Monthly or quarterly reports
- New products or brands on a regular basis
- Requirement for statutory representatives
- Product and packaging data are collated manually
- Knowledge is concentrated in one person
- A delay in registration would prevent sales or the launch of the marketplace
The following then applies: document internal costs, calculate the full cost rate and obtain a quotation with a clearly defined scope of services.
Conclusion: It is not size that matters, but structure
A full-service solution is not cost-effective once a certain turnover or packaging volume is reached. The decisive factors are the combination of countries, product categories, reporting frequency, data availability and financial risk. In the case of a single, stable German packaging obligation, handling the process in-house is usually the more cost-effective option – all the more so because LUCID reports can only be outsourced to a limited extent anyway. However, as soon as electrical appliances, batteries or multiple European markets are added to the mix, the picture changes rapidly.
According to our guidance model, a structured comparison between in-house processing, a hybrid model and a full-service approach should be on the table at an early stage. And even if the time savings alone seem modest, the balance often tips in favour of the reduced risk: sales suspensions, delayed launches or marketplace bans can significantly increase the economic benefits of a full-service approach.
The key question, therefore, is not ‘Can we carry out the reporting ourselves?’, but ‘What will it cost us to manage all these obligations ourselves on an ongoing basis, correctly and on time?’
We’ll assess your products, markets and existing processes, and show you specifically which tasks should remain in-house and where a full-service approach makes financial sense. Please contact us for a no-obligation EPR assessment.
This article does not constitute legal advice. The specific assessment of your EPR obligations depends on the individual circumstances and should be discussed with specialist lawyers.
