EPR · Germany
EPR in Germany: the LUCID and VerpackG guide for sellers
If you sell packaged goods to German customers, the Packaging Act (VerpackG) asks for three things before and around your first sale: register in the LUCID public register, license your packaging with a dual system, and report the same volumes back to LUCID. It applies whether or not you have a German company.
Who has to do this
Anyone who places packaged goods on the German market for the first time, including non-German and non-EU sellers shipping direct to consumers. There is no minimum quantity and no small-seller exemption. One parcel of one product counts.
The three steps
1. Register in LUCID
LUCID is the public packaging register run by the Zentrale Stelle Verpackungsregister (ZSVR). Registration is free, it is public, and you must do it in your own name before you sell. You receive a registration number that marketplaces and authorities can look up. A service can guide you, but the registration itself has to be in your name.
2. License your packaging with a dual system
Separately, you contract with a dual system (a duales System) and pay to license the weight of packaging you expect to place on the market, broken down by material such as paper and cardboard, plastics, and glass. This fee is what funds the collection and recycling of your packaging. Several dual systems compete, so prices differ.
3. Report your volumes to LUCID
You then report the same quantities to LUCID in a data report (a Datenmeldung). The figures you report have to match what you licensed with your dual system. A mismatch between the two is one of the most common reasons sellers get flagged.
The completeness declaration
Larger sellers must also file an audited completeness declaration (a Vollständigkeitserklärung) through LUCID by 15 May each year. The thresholds are 80,000 kg of glass, 50,000 kg of paper and cardboard, or 30,000 kg of lightweight packaging (plastics, composites, and metals) in the previous year. Most small sellers stay below these, but check your real weights rather than assume. Missing the 15 May deadline is itself an offence, with fines of up to €100,000, separate from the wider VerpackG penalties below.
Selling unregistered is prohibited
Without LUCID registration you may not place packaging on the German market. Fines can reach 200,000 euros, and because Amazon and eBay are required to check your LUCID number, an unregistered seller can simply be blocked from listing.
What changes on 12 August 2026
Under the EU Packaging Regulation (PPWR), non-EU producers will need an authorised representative for packaging in Germany, and in each other member state where they sell, such as France with Citeo and Triman. If your business is outside the EU, plan for this now rather than close to the date. The wider picture is in our EPR pillar guide.
How Assuro helps
The numbers you give a dual system and report to LUCID should come from your actual products, not a guess. Assuro totals your packaging by material across your Shopify catalogue, so your figures are grounded, and it tracks the 15 May and annual deadlines. It does not register in LUCID or file for you, and it links every flag to the rule behind it.
- Register in LUCID in your own name before your first German sale
- Contract with a dual system and license your packaging by material
- Report the same volumes to LUCID, matching your license
- Check whether you cross a completeness-declaration threshold by 15 May
- If you are outside the EU, plan for the 12 August 2026 representative rule
Frequently asked questions
Do I need LUCID if I am based in the US or UK?
Yes. VerpackG applies to whoever first places packaging on the German market, which includes non-EU sellers shipping directly to German consumers.
Is LUCID registration enough on its own?
No. LUCID registration, a dual-system license, and a data report to LUCID go together. Doing only one of the three does not make you compliant.
How much does it cost?
LUCID registration itself is free. The dual-system license depends on the weight and materials of your packaging, and for a small seller it is often a few hundred euros a year.
What is the difference between LUCID and a dual system?
LUCID is the public register run by the ZSVR. A dual system is the private company you pay to license and recycle your packaging. You need both, and the volumes you report to each must match.
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