Germany's packaging law (VerpackDG, formerly VerpackG): LUCID registration

Any business that puts packaging on the German market for the first time, including a UK ecommerce brand with no German office, must register in LUCID, Germany's public packaging register, before it ships. There's no minimum volume: one parcel is enough to trigger it. Since 12 August 2026, a UK brand with no German branch that sells directly to German end customers must also appoint a German-based authorised representative.

Last checked: 7 November 2026.

The pain points

• "We ship a handful of orders to Germany a month, and I didn't think a packaging register applied at that size."

• "Amazon is asking for a LUCID number before we can keep selling, and I don't know what it is."

• "I keep reading that an authorised representative became mandatory this year, and I don't know since when or what changed."

• "Nobody told us LUCID and the actual recycling system fee are two different things."

• "I want to know what happens if we just don't register, before it becomes a problem."

What VerpackDG and LUCID are

VerpackG was Germany's packaging act until 11 August 2026. Since 12 August 2026, the VerpackDG (Verpackungsrecht-Durchführungsgesetz, BGBl. I Nr. 207 of 17 July 2026) has applied instead, implementing the EU's own Packaging and Packaging Waste Regulation (EU) 2025/40, which applies from the same date. Most people still search for this by its old name, VerpackG, so we've kept it in this guide's title; the law behind it is now the VerpackDG.

LUCID, the public packaging register, and the Zentrale Stelle Verpackungsregister (ZSVR), the supervisory authority that runs it, continue exactly as before, with the same job: making producer responsibility visible and enforcing it evenly. The register sits at verpackungsregister.org, with the registration portal at lucid.verpackungsregister.org.

Who must register, and the threshold

The ZSVR states no minimum quantity or weight threshold. Whoever places packed goods on the German market for the first time, described as the "producer," including a mail-order or online retailer filling its own shipment packaging, must register in LUCID before doing so, regardless of volume. Registration is free, must be done personally by each company rather than through a third party, and each legally independent branch or subsidiary needs its own separate registration.

Dual system participation is a separate, paid obligation

LUCID registration and "system participation," a licensing contract with a dual system (duales System) operator, are two separate duties. LUCID registration is free and produces a registration number with the ZSVR. System participation is a paid contract, required for packaging that typically ends up as household waste with private end consumers, covering retail sales packaging, shipment packaging such as shipping boxes, bags, filler, straps, tape and labels, and some service packaging. You need your LUCID number before you can enter a system-participation agreement, and you then report volumes to both the system operator and LUCID.

The authorised representative rule, since 12 August 2026

A company based abroad with no branch in Germany that sells packaging, whether empty or already on packaged products, directly to end users in Germany without going through an intermediary retailer, must now appoint a German-based authorised representative (Bevollmächtigter). This became mandatory, with no exemption, from 12 August 2026, tied to the VerpackDG entering into force alongside the EU's packaging regulation. The representative must have a registered office or branch in Germany, must not be affiliated with your company, and only one may be appointed at a time, under a written, German-language agreement signed by both sides. The representative takes over your obligations except the LUCID registration itself, which stays a personal duty you have to fulfil yourself. The appointment must be entered in LUCID and confirmed by the representative before you first make packaging available on the German market.

Marketplaces and your LUCID number

Marketplaces operating in Germany, including Amazon and eBay, require sellers they identify as "producers" under German packaging law to supply their LUCID registration number before listing, or to keep selling. eBay states that listings from accounts without a LUCID number can be removed from its German site. This is the marketplace's own policy response to the law, not a rule published by the ZSVR itself, but it has the same practical effect: without a LUCID number, you risk losing the listing.

Penalties for not registering

The ZSVR's own enforcement guidance sets out fines by the obligation breached: up to €100,000 for breaching the registration duty, up to €200,000 for breaching the system-participation duty, and up to €10,000 for breaching the data-reporting duty, depending on severity, with separate fines possible for multiple breaches and profit confiscation possible on top. A company in breach may also face a distribution ban, meaning it may not distribute its packaging or packaged goods at all, in addition to any fine. Cases are referred automatically through the LUCID portal to state-level enforcement authorities, and a competitor can also raise a complaint based on the public register.

If you're also weighing VAT, not just packaging

LUCID registration and the authorised representative rule above are about packaging law, not VAT. A separate question, whether you need a fiscal representative for German VAT, follows its own rule. Our guide to fiscal representatives and EORI numbers for non-EU brands covers that side on its own.

What to ask your German representative or dual-system provider

• Can you confirm our LUCID registration number and that it's entered correctly for our company?

• Do we need an authorised representative, and will you take that role or arrange one?

• Which of our packaging types, sales, shipment or service, need system participation, and which operator do you recommend?

• What volumes do we need to report, and how often?

• If a marketplace asks for our LUCID number, what exactly should we give them?

Our recommendation: register before your first German shipment, not after

1. Register in LUCID before any packaging reaches a German end customer, regardless of your order volume.

2. If you have no German branch and sell direct to German end customers, appoint an authorised representative and confirm the appointment in LUCID before you ship.

3. Work out which of your packaging, sales, shipment or service, needs dual system participation, and sign with an operator.

4. Give any marketplace you sell on your LUCID number as soon as you have it.

5. Check verpackungsregister.org directly for any deadline specific to your business, since the detail sits with the ZSVR, not with this guide.

What waiting costs

Selling into Germany without a LUCID registration risks a fine that scales well past what registration or representation ever costs, plus a distribution ban that stops you selling into Germany at all until it's resolved, and a marketplace account suspension if you're selling through one.

These figures are made up to show the method. A brand pays a German authorised representative €80 a month, €960 a year, plus a dual-system contract priced on its packaging weight, say €600 a year at its current volume. That's €1,560 a year in total. A single enforcement fine at even the low end of the registration-duty range, reported up to €100,000, is more than 60 times that annual cost. These figures are made up to show the method.

People Also Ask

Do we need to register in LUCID if we only ship a few orders to Germany a month?

Yes. The ZSVR states no minimum quantity or weight threshold. Placing packed goods on the German market for the first time triggers the duty to register, whatever your volume.

Is LUCID registration the same as paying for recycling?

No. LUCID registration is free and is separate from system participation, the paid licensing contract with a dual system operator that actually funds collection and recycling of packaging that reaches private households. Most sellers need both.

Do we still need an authorised representative if we sell only through Amazon Germany?

The authorised representative rule applies to companies based abroad, with no German branch, that sell directly to German end users without an intermediary retailer. Whether a marketplace sale counts as going through an intermediary wasn't confirmed in this research, so check your own situation with a German-based adviser or the marketplace directly.

Finding the right EU fulfilment partner

Logan, FulfilQ's advisor on the website, matches brands to verified providers by order volume, product type and region. Tell Logan how many orders you send to Germany and whether you hold stock there, and you get a shortlist to ask about LUCID registration, authorised representation and dual system contracts. Start at fulfilq.com and Ask Logan, or Submit an RFP and verified providers come back to you. You can also browse the full provider directory.