Drug Pricing
August 3, 2026
9 minutes

How Drug Pricing Works in Germany: Calculated

In Germany the retail price of a prescription medicine is calculated rather than negotiated. A regulated wholesale mark-up of up to 3.15 percent capped at 37.80 EUR plus 0.73 EUR is added to the manufacturer selling price, then a pharmacy mark-up of 3 percent plus 9.00 EUR plus two small fixed contributions, and finally 19 percent VAT.

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Table of contents
    Summary
    • German prescription prices are calculated, not negotiated: the mark-ups are fixed in the Arzneimittelpreisverordnung and identical in every pharmacy nationwide.
    • Wholesale adds at most 3.15 percent of the manufacturer selling price, capped at 37.80 EUR, plus a fixed 0.73 EUR per package.
    • The pharmacy adds 3 percent of the purchase price plus 9.00 EUR plus 0.21 EUR for emergency services and 0.20 EUR for pharmaceutical services.
    • VAT is the full 19 percent, applied last. Germany has no reduced rate for medicines.
    • A 100.00 EUR manufacturer price becomes a 103.88 EUR pharmacy purchase price and a 138.53 EUR retail price.
    • Fixed fees dominate at low prices and the wholesale cap bites above 1,200 EUR, so margins look completely different at the two ends of the market.
    • The Apothekenabschlag under section 130 SGB V has changed repeatedly and should be read from maintained data rather than hard-coded.

    The price of a prescription medicine in Germany is calculated, not negotiated: the manufacturer sets a selling price, then a wholesale mark-up and a pharmacy mark-up fixed by the Arzneimittelpreisverordnung (AMPreisV) are added in that order, and 19 percent VAT is applied to the total to produce the pharmacy retail price. Because the mark-ups are set in law and are identical nationwide, the same package costs the same in every German pharmacy, and the entire retail price can be reconstructed from the manufacturer selling price alone.

    This article walks the arithmetic end to end with worked numbers. It deliberately does not cover reimbursement policy, benefit assessment or discount contracts, and it does not cover where to license price data. Those are separate subjects, covered in how pharmaceutical pricing works in Germany and in the guide to German drug price data.

    The four price levels, in order

    German pharmaceutical pricing has four named levels. Every conversation about German prices is easier once you can say which one you mean.

    LevelGerman termAbbreviationDefinitionIncludes VAT
    Manufacturer selling priceHerstellerabgabepreis, also Abgabepreis des pharmazeutischen UnternehmersAPUWhat the manufacturer charges wholesaleNo
    Wholesale selling priceGrosshandelsabgabepreisGHAPAPU plus the regulated wholesale mark-upNo
    Pharmacy purchase priceApothekeneinkaufspreisAEPWhat the pharmacy pays, net of VATNo
    Pharmacy retail priceApothekenverkaufspreisAVPThe final price, the reimbursement referenceYes

    In the regulated Rx chain the wholesale selling price and the pharmacy purchase price are the same number viewed from the two sides of the same transaction. Everything below builds from APU upwards.

    Step 1: the manufacturer sets the APU

    The manufacturer selling price is the only genuinely free variable in the chain for a prescription medicine, and even it is constrained downstream by reference prices under section 35 SGB V and, for new patented products, by a negotiated reimbursement amount. Those instruments do not change the arithmetic below. They change the number you feed into it.

    The APU is set per package, not per product. A 20 pack and a 100 pack of the same strength are two separate prices attached to two separate PZNs, and the mark-up calculation runs independently for each.

    Step 2: the wholesale mark-up under AMPreisV section 2

    For prescription medicines, section 2 AMPreisV allows the wholesaler two components on top of the manufacturer selling price:

    • a fixed amount of 0.73 EUR per package, which is not negotiable and is not capped; and
    • a percentage of at most 3.15 percent of the manufacturer selling price, capped at 37.80 EUR.

    Two features of this design matter more than the numbers themselves. The percentage is a maximum, so a wholesaler may grant part of it back as a discount, whereas the fixed 0.73 EUR is a floor that must be charged. And the 37.80 EUR cap means the percentage stops growing once the manufacturer selling price passes 1,200 EUR, because 3.15 percent of 1,200 EUR is exactly 37.80 EUR. Above that threshold the wholesale mark-up is a flat 38.53 EUR regardless of how expensive the medicine is.

    Step 3: the pharmacy mark-up under AMPreisV section 3

    The pharmacy mark-up on a prescription medicine is deliberately built the other way round, with the fixed component doing almost all the work. Section 3 AMPreisV sets it as four elements added to the pharmacy purchase price:

    "ein Festzuschlag von 3 Prozent zuzueglich 9 Euro zuzueglich 21 Cent zur Foerderung der Sicherstellung des Notdienstes zuzueglich 20 Cent". Arzneimittelpreisverordnung, section 3 paragraph 1.

    In English: 3 percent of the pharmacy purchase price, plus a fixed 9.00 EUR per package, plus 0.21 EUR towards the emergency service fund, plus 0.20 EUR towards pharmaceutical services. The 9.00 EUR fixed fee is the core of German pharmacy remuneration for prescription medicines and it is identical whether the package costs 6 EUR or 6,000 EUR. That is a policy choice: it removes any financial incentive for a pharmacy to prefer the more expensive of two interchangeable products.

    Note that these are the figures in force as this article was reviewed in July 2026. The fixed fee in particular is a recurring subject of legislative debate, and any calculation you automate should read the rate from a maintained data source rather than hard-code it.

    Step 4: VAT

    Germany applies the full VAT rate of 19 percent to medicinal products, including prescription medicines. There is no reduced rate for medicines, which is unusual in European comparison and is one reason German retail prices look high next to neighbouring markets even when the manufacturer selling price is similar. VAT is applied last, to the sum of the purchase price and the full pharmacy mark-up.

    The calculation, worked end to end

    Take a prescription medicine with a manufacturer selling price of 100.00 EUR. Every figure below follows from the rules above.

    StepBasisRuleAmountRunning total
    1. Manufacturer selling price (APU)Set by manufacturerFree, per package100.00 EUR100.00 EUR
    2. Wholesale percentage100.00 EUR3.15 percent, capped at 37.80 EUR3.15 EUR103.15 EUR
    3. Wholesale fixed amountPer package0.73 EUR0.73 EUR103.88 EUR
    = Pharmacy purchase price (AEP)103.88 EUR
    4. Pharmacy percentage103.88 EUR3 percent3.12 EUR107.00 EUR
    5. Pharmacy fixed feePer package9.00 EUR9.00 EUR116.00 EUR
    6. Emergency service contributionPer package0.21 EUR0.21 EUR116.21 EUR
    7. Pharmaceutical services contributionPer package0.20 EUR0.20 EUR116.41 EUR
    = Net retail price116.41 EUR
    8. VAT116.41 EUR19 percent22.12 EUR138.53 EUR
    = Pharmacy retail price (AVP)138.53 EUR

    Read the structure rather than the total. On a 100 EUR manufacturer price, the wholesaler earns 3.88 EUR and the pharmacy earns 12.53 EUR before its own costs. The state takes 22.12 EUR in VAT, which is more than the wholesale and pharmacy margins combined.

    What the sickness fund actually pays

    The AVP is not the end of the story for a prescription dispensed at the expense of statutory health insurance. The pharmacy grants the fund a statutory discount per package, the Apothekenabschlag, under section 130 SGB V. The manufacturer separately grants its own statutory rebate under section 130a SGB V, and any discount contract between the fund and the manufacturer sits on top of that again.

    The Apothekenabschlag is a moving figure and worth stating carefully rather than quoting from memory. It stood at 2.00 EUR per prescription medicine under the GKV-Finanzstabilisierungsgesetz for the period running to the end of January 2025, after which the statutory base rate applied again. That base rate is 1.77 EUR, the figure ABDA gives as current, and a 2026 draft law would raise it to 2.07 EUR on a permanent basis. Applied to the worked example at the current base rate, the fund is invoiced 138.53 EUR less 1.77 EUR, or 136.76 EUR, before any manufacturer rebate or contractual discount.

    This is precisely the kind of parameter that should never be hard-coded into an ERP or billing routine. It has changed three times in four years.

    How the caps change the picture at the extremes

    The same rules produce very different economics at the two ends of the price range. Two more worked examples make the point.

    StepLow-price genericHigh-price specialty
    Manufacturer selling price5.00 EUR2,000.00 EUR
    Wholesale percentage0.16 EUR (3.15 percent)37.80 EUR (capped, not 63.00 EUR)
    Wholesale fixed amount0.73 EUR0.73 EUR
    Pharmacy purchase price5.89 EUR2,038.53 EUR
    Pharmacy mark-up total9.59 EUR70.57 EUR
    Net retail price15.48 EUR2,109.10 EUR
    VAT at 19 percent2.94 EUR400.73 EUR
    Pharmacy retail price18.42 EUR2,509.83 EUR
    Retail price as multiple of APU3.7x1.25x

    The 5.00 EUR generic leaves the factory at 5 EUR and reaches the counter at 18.42 EUR, because fixed per-package fees dominate at low prices. The 2,000 EUR specialty product gains only 25 percent on its way through the chain, and roughly four fifths of that gain is VAT. Anyone reasoning about German trade margins from a single mid-priced example will draw the wrong conclusion about both ends of the market.

    Prescription versus non-prescription

    The regulated chain above applies to prescription-only medicines. For non-prescription products the picture is different in one decisive respect.

    Prescription (Rx)Non-prescription (OTC)
    Wholesale mark-upFixed by AMPreisV section 2Freely agreed
    Pharmacy mark-upFixed by AMPreisV section 3Set by the pharmacy
    Price identical in every pharmacyYesNo
    Published AVPThe binding retail priceA recommendation only
    VAT19 percent19 percent
    Usual payerStatutory or private insuranceThe patient

    The practical consequence for anyone processing German price data: an AVP on a prescription article is a fact you can calculate and verify, whereas an AVP on an OTC article is an indication that individual pharmacies are free to undercut or exceed. Treating both as the same field type produces analyses that quietly overstate OTC market values.

    Running the chain backwards, from AVP to APU

    Because every step is deterministic, the chain inverts. This matters in practice, because many published sources give only the pharmacy retail price while the commercially interesting figure is the manufacturer selling price, and international reference pricing exercises almost always need the manufacturer level rather than the retail level.

    Working backwards from the 138.53 EUR example: divide by 1.19 to strip VAT, giving 116.41 EUR. Subtract the three fixed pharmacy elements of 9.00 EUR, 0.21 EUR and 0.20 EUR, giving 107.00 EUR, which is the pharmacy purchase price plus 3 percent of itself. Divide by 1.03 to obtain the pharmacy purchase price of 103.88 EUR. Subtract the fixed 0.73 EUR and divide by 1.0315 to recover the manufacturer selling price of 100.00 EUR.

    Two cautions. Above a manufacturer selling price of roughly 1,200 EUR the final division is wrong, because the wholesale percentage is capped, and you must subtract the flat 38.53 EUR instead. And the inversion is only valid where the full statutory percentage was actually charged, which is why a reconstructed manufacturer price should be treated as an estimate unless the APU is available directly in the data.

    Why the price is identical in every German pharmacy

    The uniform price for prescription medicines is not a market outcome, it is the point of the regulation. Because the mark-ups are fixed nationwide, patients cannot be steered towards a pharmacy by price, pharmacies compete on advice, availability and service instead, and a comprehensive dispensing network remains viable in rural areas where volume alone would not sustain one. The same design also explains the shape of the pharmacy mark-up: a large fixed fee and a small percentage make pharmacy income depend on the number of packages dispensed rather than on their value.

    Five places this calculation goes wrong

    • Applying the pharmacy percentage to the manufacturer price. The 3 percent is calculated on the pharmacy purchase price, after the wholesale mark-up, not on the APU.
    • Missing the wholesale cap. Above a manufacturer price of 1,200 EUR the percentage stops at 37.80 EUR. Uncapped formulas overstate high-priced products badly.
    • Calculating per product instead of per package. Every PZN is a separate calculation, and pack size differences do not scale the fixed fees.
    • Confusing AEP and AVP in a data feed. One excludes VAT and one includes it, and a 19 percent error is easy to miss when the field name is ambiguous.
    • Hard-coding rates. The pharmacy fixed fee, the emergency service contribution and the Apothekenabschlag have all moved in recent years. Read them from maintained data with an effective date, not from a constant in your code.

    For teams that need these figures resolved per PZN with the effective date attached rather than reconstructed by hand, pharmazie.com maintains German price data across 25+ databases with price history back to market launch and coverage extending to 50+ countries, which is what makes the same calculation reproducible for a date in the past as well as for today.

    This content is intended for healthcare professionals and does not constitute medical advice. Last reviewed: July 2026.

    Author Image
    Ursula Tschorn
    Ursula Tschorn is CEO of DACON Datenbank Consulting GmbH and has been building pharmaceutical information infrastructure since 1989. She writes on drug data standards, pricing regulation and market access in the DACH region.

    FAQ

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