Selling to Germany from the USA: EPR, VAT and product rules (LUCID, stiftung ear, Impressum)

Germany sets its own rules for packaging, electronics, batteries, single-use plastics and your website, on top of the EU rules in EPR in the EU and WEEE registration, and in the EU Battery Regulation. This page lists only what Germany adds. Each row links to its EU rule.

Packaging moved to a new law on 12 August 2026

Germany now carries out the EU packaging regulation through the VerpackDG. The name sellers still search for, the Verpackungsgesetz, is the old law. The register stays LUCID, run by the ZSVR, and registering has no fee.

You register yourself in LUCID. Without a German branch you also appoint one authorised representative, by written mandate in German, and name it in LUCID. The ZSVR confirms the appointment. For packaging that falls under system participation, your representative joins a system in its own name. A system contract you signed before 12 August 2026 runs out by 31 December 2026 at the latest. The EU side of this is in packaging EPR and the EPR authorised representative.

Register, with your representative named, before you first make packaged products available in Germany. If you are already in LUCID, name your representative there by 12 November 2026. 12 September 2026 was the transition date for a producer newly obliged under the new law and not under the old one. Not registering carries a fine of up to EUR 100,000, and not joining a system up to EUR 200,000.

Electronics and batteries go through a German representative

A foreign business cannot register itself for WEEE. It mandates one authorised representative in Germany, and stiftung ear confirms the mandate before the registration is processed. Batteries are registered per brand and category. Without a German establishment you appoint one representative for them, in writing and in German. The Umweltbundesamt is the competent authority. The law lets it entrust the registration tasks to stiftung ear, and stiftung ear takes the applications and issues the registration.

The rest is a short list

The single-use plastics levy, the VAT office, German-language safety information, the data protection supervisors and the Impressum are in the table above. The CE mark, the EU Responsible Person and the EORI number are EU rules, not German ones.