LUCID packaging register in Germany for non-EU sellers (VerpackDG)

If you ship packaged goods to a buyer in Germany, you register yourself in LUCID, the packaging register of the Zentrale Stelle Verpackungsregister (ZSVR), before your first sale. Registering has no fee. With no branch in Germany you also appoint one German authorised representative, in a written agreement in German, and name it in the same registration. The representative joins a system in its own name. This holds for a seller in another EU country as much as for one outside the EU (VerpackDG §5(2)).

The EU rule, and who counts as a producer, is in packaging EPR in the EU. This page is only what Germany adds. The other German rules are on the Germany page.

Do this, in this order

1. Appoint the representative. Any person or company with a registered office or branch in Germany that is not affiliated with you. It needs its own LUCID login and ID before you can pick it. You can appoint only one. The agreement is in German, and the German version binds if there are others. Both sides sign it, by hand or with a qualified electronic signature. Who and how is in the EU guide.
2. Register in LUCID as a producer and enter the representative in the first step, “Master data”. Without it you cannot finish. The ZSVR confirms the appointment once the representative confirms it in LUCID, and you get an e-mail (§5(5), ZSVR).
3. Have the representative join a system for packaging subject to system participation, before you make it available (§7(1)). Shipping packaging always needs one: boxes, bags, labels, tape and filler (ZSVR). The ZSVR publishes the list of system operators and may not share prices.
4. Report the volumes by material, in kilograms to the third decimal, to the system and to LUCID.
5. Give each marketplace and fulfilment provider your LUCID number. It is the German EPR number, and it works only for German packaging (ZSVR). The EPR number guide covers other countries.

You are the producer when you ship straight to the buyer

A foreign company is the producer in Germany when it ships from abroad directly to an end user, a consumer or a business (ZSVR). When you sell to a business in Germany that resells, that business is the producer for the packaging it first makes available there. There is no minimum quantity: neither §6 nor §7 names one.

A parcel marked “gift” does not change this when a business sends it. The EU text counts any supply “in the course of a commercial activity, whether in return for payment or free of charge” (PPWR Art. 3(1) point 11, VerpackDG §3(3)). A private person’s present to a friend is not such a supply.

What each of you does

The table follows the ZSVR’s description of the split. The law says the representative takes over every duty under the VerpackDG except registration, in its own name, and counts as the producer for them (§5(2), (3)). If an employee of yours does the LUCID work, enter that person as the contact person, not as the representative.

What to type in each LUCID field

You create a login with your company name, the name of the person in charge and a contact person with an e-mail address. The activation link works for 24 hours. After you activate it you have seven days to finish. Then:

Source for every row: ZSVR help centre and registration guide. The registration data the law asks for is in §6(2).

Deadlines

What it costs

LUCID has no fee. The system charges by the volume and material of your packaging, and the ZSVR does not publish prices. The representative charges its own fee, and no official figure exists. The auditor for a declaration of completeness is paid by you, and only above the thresholds, or when the ZSVR or the Land authority demands one (§10(4)).

Who checks your registration

A marketplace must hold proof that you are registered in LUCID and your self-certification before it serves you, and a fulfilment provider must do the same (ZSVR, PPWR Art. 45(4), §13(4)). Both read the public register of producers. It lists your number, name and address with your country, brands, packaging types, VAT or tax number and your representative (§6(4)). It updates once a day, so a new registration can take a day to show. It does not show whether you joined a system. Your system operator gives you a written or electronic confirmation of that (§7(1)).

The ZSVR compares your volume reports with those the systems send it (ZSVR). It investigates, and reports a suspected offence to the Land authority, usually the district or city waste authority (ZSVR).

If you do nothing

The packaging may not be made available in Germany, and a platform, distributor or fulfilment provider may not serve you (§13). The fines are in §66:

The ZSVR adds that the authority can confiscate the money you saved by not complying.

It has happened to sellers abroad. In 2025 the ZSVR published a case about a large online pharmacy based outside Germany. It was registered in LUCID but had not joined a system for its shipping packaging since 2019. The ZSVR saw this in its register data, contacted the company, and passed the case to the state authority. The back payment for five years came to at least EUR 2 million, before any fine (case report 02/2025, under the old Verpackungsgesetz). An online shop that sold deposit drinks with no deposit and no deposit label was the subject of a 2024 case report (case reports).

The two marks Germany sets

Material codes are optional. If you print them, use only the numbers and abbreviations of Annex 2, for example PET 1, PAP 20 to 22, ALU 41, GL 70 to 72, and “C/” for composites (§4). No other recycling mark is required. The EU sorting-mark rules are in packaging symbols.

Drinks are the exception. If you are the first to sell single-use drinks packaging under the deposit in Germany, you mark it as deposit-bearing before you make it available, charge at least EUR 0.25 per pack including VAT, and join the nationwide deposit system (§46(1)). Packs under 0.1 litre or over 3 litres are out, and so are several carton types and some contents such as wine, spirits and milk; the content exemptions never cover cans or single-use plastic bottles (§46(4), ZSVR). A seller selling online shows the “EINWEG” notice for single-use packs, or “MEHRWEG” for reusable ones, in the same medium and at least as large as the price (§47).

What does not apply

• The LUCID number does not cover other countries or other German registers. WEEE goes through stiftung ear and the single-use plastics fund through its own platform (ZSVR).
• You do not register again for the new law if you are already in LUCID. You update your details and add the representative (ZSVR).
• The old Verpackungsgesetz no longer sets the rules, except the 2026 transition rules in §68.