EPR in Germany: the LUCID and VerpackG guide for sellers

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. Note the scope: LUCID is the packaging register and nothing else. If what is inside the box is electrical, that is a separate German registration with its own authority and its own representative rule, covered in WEEE registration in Germany.

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.

Those quantities are material types with the mass per material in kilograms to three decimal places, and working them out from a store's order data is its own job. Calculating packaging weight for EPR walks through it.

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. Austria uses the same idea for a different purpose: there, volume sets how often you report rather than whether you file an extra document. Missing the 15 May deadline is itself an offence, with fines of up to €100,000, separate from the wider VerpackG penalties below.

What changes on 12 August 2026

The EU Packaging Regulation (PPWR) does not change how Germany handles a foreign producer: you still register in LUCID in your own name rather than through an appointed representative. Where PPWR bites is other member states, and it works two ways. An EU-established seller must appoint a packaging authorised representative in each member state it is not established in. A non-EU seller follows each country's national rule, and several, such as France with Citeo and Triman, require a local representative. 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, register in LUCID yourself for Germany and check the representative rule for your other EU markets