Who must register for packaging EPR in Germany, and how

Checked against the VerpackDG as in force on 29 September 2026. This is general information about Regulation (EU) 2025/40 and Germany's national EPR scheme, not legal advice. Thresholds, fees, penalty amounts and go-live dates come from national law and PRO schedules that change: treat every figure as needing a fresh check, and confirm anything you act on with the national authority or qualified counsel.

The register and what it involves

Germany runs packaging EPR through the LUCID Packaging Register (“LUCID Verpackungsregister”), operated by the Zentrale Stelle Verpackungsregister (ZSVR). Since 12 August 2026 the governing law is the Verpackungsrecht-Durchführungsgesetz (VerpackDG), which replaced the VerpackG and makes LUCID Germany's register under Article 44 PPWR (s6). Registration is online, and the ZSVR confirms it with a registration number. A registration made under the VerpackG carries over (s68(2)); existing registrants have until 12 November 2026 to make any changes to their registration data.

Registration alone is not enough. For packaging subject to system participation, meaning packaging that typically ends up as waste in households or comparable places such as restaurants, you must also sign a system-participation contract with a licensed dual system (duales System) before first supply (s7). The data you give the dual system must go to the ZSVR as well, without delay (s9).

Packaging outside system participation, such as most transport packaging, works differently: its producers need an authorisation (Zulassung) from the ZSVR under s19, unless they hand the whole duty to an approved producer responsibility organisation. Until 31 December 2027 they may keep supplying without it (s68(9)).

De-minimis: none

LUCID has no minimum-quantity threshold. The obligation applies to every producer placing even a single packaged item on the German market, regardless of size or volume, so do not assume a small volume exempts you. Small producers get reporting relief, not an exemption: below 10 tonnes of system-participation packaging in the previous year, the data report to the ZSVR is filed once a year, by 1 June (s9(2)).

The Authorised Representative rule

If you have no establishment in Germany and sell packaged goods directly to German end users, you are the producer for that packaging and Article 45(3) PPWR requires you to appoint an Authorised Representative for EPR (Bevollmächtigter) in Germany. The representative must be established in Germany (Art. 3(1)(20) PPWR), and section 5 VerpackDG adds the German terms: the appointment is a written authorisation in German, made before your first supply (s5(2) and (4)). It applies to third-country producers as well (s5(2), second sentence). You may appoint only one, and you name it to the ZSVR when you register (s5(4) and (5)).

If you sell only to German retailers or distributors who pass the goods on unchanged, they are the producer in Germany and you need no representative there.

The representative takes on your VerpackDG duties in its own name and counts as the producer for them, so it can sign the dual-system contract and file data reports and completeness declarations. The LUCID registration itself cannot be delegated: you must do that yourself (s5).

Reporting and penalties

Reporting is by material and mass. Each time you license volumes with a dual system, the same figures go to the ZSVR without delay (s9(1)). Producers above the tonnage thresholds in s10(4) (in the previous year, 80 tonnes of glass, 50 tonnes of paper and board, or 30 tonnes of any other material) must also file a declaration of completeness (Vollständigkeitserklärung), checked by a registered expert or auditor, by 15 May each year (s10).

Under s66(3) VerpackDG, fines reach up to €200,000 for not joining a dual system, up to €100,000 for not registering or for a missing or wrong completeness declaration, and up to €10,000 for most other breaches, including late or wrong data reports. A producer that is not registered, or has not joined a dual system, may not supply that packaging in Germany at all, and distributors and fulfilment providers must not handle it (s13). Enforcement is by the federal states. The Single-Use Plastics Fund levy (EWKFondsG, via the DIVID platform) is a separate regime for single-use plastic producers.

How onerous is it?

High. A LUCID registration you must do yourself, with no volume floor; a separate dual-system contract; the same data filed with both the system and the ZSVR; a ZSVR authorisation (s19) for transport and other non-household packaging by the end of 2027; and a German-established representative if you sell direct to German end users from abroad.

Frequently asked questions