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EPR in Germany: LUCID, dual systems and the VerpackDG
Last checked · 6 min read
EPR in Germany is the first obligation most online sellers run into, because Amazon and Kaufland have been checking it for years. If you ship products to German consumers, you register in the LUCID packaging register, sign a contract with a dual system and report your kilograms. If you sell electronics or batteries, a registration with stiftung ear comes on top.
- +For packaging you need two things: a registration in LUCID (free) and a contract with a dual system (paid, per kilogram).
- +There is no threshold. One shipping box a month to Germany is enough to be in scope.
- +Whatever you report to your dual system, you also report to LUCID (the Datenmeldung). Above 80,000 kg of glass, 50,000 kg of paper or 30,000 kg of other materials, a Declaration of Completeness is due by 15 May.
- +Since 12 August 2026 the VerpackDG replaces the Packaging Act, and a foreign seller without a German establishment must appoint an authorised representative.
Who must register in Germany?
Anyone who is first to supply filled packaging to German end users. For a webshop or marketplace seller, that is you as soon as you ship to a German address, even when you are based in the Netherlands or Belgium, and even when you sell through Amazon, Kaufland or eBay. It covers all packaging that ends up with the consumer: the product packaging, but also the shipping box, the void fill and the tape.
There is no threshold. Where the Netherlands has a 50,000 kg limit, in Germany every kilogram counts from the first box. That makes Germany the strictest EU country for small sellers.
Step 1: register in LUCID
LUCID is the public packaging register of the Zentrale Stelle Verpackungsregister (ZSVR), the central agency for the packaging register. Registration is free and online. You receive a registration number starting with DE. That is the number Amazon and Kaufland mean when they ask for your EPR number for Germany.
The register is public. Anyone, a competitor or a regulator, can look up whether your company and your brands are registered. That is exactly how most enforcement starts.
Step 2: a contract with a dual system
Registering alone is not enough. For packaging that ends up in private households, you must take part in a dual system: a private organisation that collects and recycles household packaging waste. Well-known systems include Der Grüne Punkt, Interzero, Landbell and Reclay. You pick one and pay per kilogram, per material.
When you sign up, you estimate how many kilograms you expect per material this year. Afterwards you report the actual quantities and the difference is settled. Many systems charge a minimum fee, so for a small seller the fixed cost is often higher than the kilograms themselves.
Step 3: data reporting to LUCID
Every quantity you report to your dual system, you also report to LUCID: the Datenmeldung. The ZSVR compares the two reports, and differences stand out. Keep one source of truth for your kilograms and copy exactly those figures into both portals.
There is no fixed national date for the routine report: the rhythm follows your dual system contract. That is also why the deadlines table shows no date for Germany. What does have a fixed date is the Declaration of Completeness.
The Declaration of Completeness: 15 May
If in the past calendar year you placed more than any of these quantities of packaging on the German market, you must file a Declaration of Completeness (Vollständigkeitserklärung) by 15 May, audited by an accountant or registered expert:
| Material | Threshold per year |
|---|---|
| Glass | 80,000 kg |
| Paper, board and corrugated board (PPK) | 50,000 kg |
| All other materials combined (plastic, metals, aluminium, beverage cartons, composites) | 30,000 kg |
Most small and mid-sized webshops stay below. But recalculate every year: the paper threshold is reached sooner than you think, because shipping boxes are heavy.
What changed on 12 August 2026: the VerpackDG
With the EU PPWR, the German Packaging Act (VerpackG) was replaced by the Packaging Law Implementation Act (VerpackDG). The basics stay: LUCID registration, dual system participation, data reporting and the Declaration of Completeness. What changes:
- Authorised representative mandatory for foreign sellers. Under the old act, appointing a Bevollmächtigter was optional. Since 12 August 2026, a seller with no establishment in Germany that supplies German end users directly must appoint an authorised representative in Germany and record it in LUCID. LUCID flags registrations where that is missing.
- New definitions. The PPWR separates whoever designs the packaging (responsible for the packaging itself) from whoever places it on the market (responsible for EPR). For most webshops little changes in practice: you remain the one who registers and pays.
- Update your registration. LUCID is being aligned with the EU terms. Check that your registration is still complete.
Electronics and batteries: stiftung ear
If you sell electrical or electronic equipment in Germany, you register with stiftung ear under the ElektroG before your first sale. You receive a WEEE registration number (WEEE-Reg.-Nr. DE followed by eight digits) per brand and equipment type. Without a German establishment you need an authorised representative to do so.
Batteries, including batteries inside a device, are registered with stiftung ear too, since 18 August 2025 under the BattDG. Foreign producers can no longer register themselves since then and need an authorised representative. More in the guides on electronics and batteries.
Amazon, Kaufland and eBay check
Since 1 July 2022, marketplaces in Germany must check that their sellers comply with the packaging law. Amazon and Kaufland therefore ask for your LUCID number, and your WEEE number for electronics. When it is missing, listings in Germany are blocked. See exactly what Amazon and Kaufland ask for.
Note that a marketplace only checks that your number exists, not that you have a dual system contract or report your kilograms correctly. An accepted number does not mean you are compliant.
Fines and risks
Under the Packaging Act, a missing registration could cost up to 100,000 euros and missing system participation up to 200,000 euros per offence. More important in practice: unregistered packaging may not be sold. Competitors can also take action against you under unfair competition law, and in Germany they do.
Checklist for Germany
- 1Register your company and brands in LUCID and note your registration number.
- 2Appoint an authorised representative in Germany if you have no establishment there, and record it in LUCID.
- 3Sign a dual system contract based on an estimate of your kilograms per material.
- 4Enter your LUCID number at Amazon, Kaufland and any other marketplace.
- 5Record what each product's packaging weighs, per material, and count how many units you ship to Germany. See calculating packaging weight.
- 6Report the actual quantities to your dual system and the same figures to LUCID.
- 7Check every year whether you pass one of the Declaration of Completeness thresholds.
Frequently asked questions
What is the difference between LUCID and a dual system?
LUCID is the public register: your registration, your number and your reports. A dual system is a private organisation you pay to collect and recycle your packaging. You need both.
Is a LUCID number the same as an EPR number?
For packaging in Germany, yes. When Amazon or Kaufland ask for your packaging EPR number for Germany, they mean your LUCID registration number. For electronics it is your WEEE registration number from stiftung ear.
I only send a few parcels a month to Germany. Do I still need to register?
Yes. Germany has no threshold for packaging. Your costs will be low, although many dual systems charge a minimum amount per year.
Who registers when I sell through Amazon FBA?
You, for your product packaging. The shipping box changed on 12 August 2026: under the old act the FBA seller was its producer; under the PPWR Amazon is the producer of shipping boxes carrying its brand, and Amazon takes over EPR compliance for that FBA shipping packaging. See the Amazon guide.
Do I need an authorised representative under the VerpackDG?
If you have no establishment in Germany and supply German end users directly: yes, since 12 August 2026. Whether that obligation will stay for EU-based companies is being negotiated at EU level.
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This guide is general information, not legal or tax advice. Rules, thresholds and deadlines are set by the schemes themselves and they change. Check what applies to your situation with the scheme or an adviser.