Packaging EPR in Germany: who must register in LUCID under the VerpackDG

Every producer of packaging, before first making packaging available in Germany (§ 6(1) VerpackDG). The producer is the business that first makes the packaging available there (PPWR Article 3(1), point 15). A seller outside the EU that delivers directly to end users in Germany is the producer there; end users include businesses that use the goods themselves. If you sell to a German importer or distributor that resells the goods, it is the producer instead.

Under the old Packaging Act only packaging that ends up in households had to be registered; now every producer registers, transport and other business-to-business packaging included. Producers newly obliged had to register by 12 September 2026, and producers already registered had to update their data by 12 November 2026 (§ 68(2)).

There is no minimum quantity and no exemption by company size for registration: one package is enough. Size matters only for reporting. A producer that made less than 10 tonnes of household packaging available in the previous year reports its quantities once a year, by 1 June, instead of after each contract with a system (§ 9(2)). The declaration of completeness, due by 15 May and checked by a registered expert, is needed from 80 tonnes of glass, 50 tonnes of paper and cardboard or 30 tonnes of other materials made available in the previous calendar year; below that, the Zentrale Stelle or the Land authority can still demand one at any time (§ 10(1) and (4)).

The PPWR micro-enterprise rules change who counts as the manufacturer for the design and labelling rules, not who registers: see PPWR exemptions for micro-enterprises.

A producer with no establishment in Germany that must appoint an authorised representative for extended producer responsibility under PPWR Article 45(3) must do so before first making packaging available in Germany, by written mandate in German, and may appoint only one (§ 5(2) and (4)). It names the representative in its LUCID registration (§ 5(5)). The registration itself and the data reports to LUCID cannot be handed to a third party (§ 5(1)).

Packaging that typically ends up as waste in private households or comparable places, including transport packaging such as parcel boxes where that is typical, and service packaging, must be licensed with one or more dual systems before it is made available (§ 7(1), § 3(6)). Report the same quantities to LUCID (§ 9(1)). System contracts made under the old Packaging Act ran until 31 December 2026 at the latest (§ 68(1)).

The running costs are the systems' participation fees. Producers of packaging that does not go to a system pay a levy to the Zentrale Stelle under a financing agreement, unless an approved producer responsibility organisation takes over their obligations (§ 51(1)). Not registering can be fined up to EUR 100,000, not joining a system up to EUR 200,000 (§ 66(1) points 1 and 3, § 66(3)).

This page covers Germany only; other Member States run their own registers, see EPR registration. Check the current instructions on the LUCID site before you register.