If you sell packaged goods in Germany, there is hardly any way around the LUCID Packaging Register. For online retailers, registration is a key part of packaging EPR compliance in Germany.
Update September 2026
Since August 12, 2026, a new legal framework has applied. The European Packaging and Packaging Waste Regulation, or PPWR, is now applicable. At the same time, the German Packaging Law Implementation Act, or VerpackDG, has replaced the previous Packaging Act, known as the VerpackG, as the main national packaging law.
For many online retailers, the core obligations remain the same. These include registration in the LUCID Packaging Register, system participation for relevant packaging, and packaging quantity reporting.
One particularly important change affects international retailers. Companies based outside Germany are required to appoint an Authorized Representative in Germany under certain circumstances.
In this article, we explain what LUCID is, how registration works, and what has changed with the VerpackDG and the new Authorized Representative requirement.
Contents:
- What is the LUCID Packaging Register?
- What has changed with the VerpackDG?
- Manufacturer or producer: What is the difference?
- What is the LUCID registration number?
- Who needs to register with LUCID?
- Which packaging is subject to system participation?
- What information needs to be entered in LUCID?
- Authorized Representative for packaging in Germany
- How does registration in the LUCID Packaging Register work?
- Which packaging quantities need to be reported?
- Which deadlines are relevant?
- What happens if you do not register?
- Who can access the LUCID Packaging Register?
- LUCID, VerpackDG and ecosistant
- FAQ about the LUCID Packaging Register
What is the LUCID Packaging Register?
The LUCID Packaging Register is Germany’s central register for companies that have producer responsibility obligations for packaging.
It is operated by the Central Agency Packaging Register, known in German as the Zentrale Stelle Verpackungsregister or ZSVR.
Registration creates transparency about which companies place packaging on the German market and whether they comply with their extended producer responsibility obligations.
LUCID is particularly relevant for online retailers. Shipping products to private customers typically involves packaging such as:
- Shipping boxes
- Mailing bags
- Filling materials
- Adhesive tape
- Product packaging
- Secondary packaging
Depending on your company’s role, this can result in registration, system participation and reporting obligations.
LUCID registration itself is free of charge and completed online.
What has changed with the VerpackDG?
Since August 12, 2026, German packaging law has been based on a new combination of European and national legislation.
The EU Packaging and Packaging Waste Regulation 2025/40, better known as the PPWR, has replaced the previous European Packaging Directive. As a regulation, it applies directly across all EU Member States.
Germany supplements these European requirements through the VerpackDG.
The VerpackDG has replaced the previous German Packaging Act, the VerpackG.
For online retailers, this does not mean that packaging EPR starts from scratch. Several core requirements remain in place:
- Registration in the LUCID Packaging Register
- System participation for packaging subject to system participation
- Reporting of relevant packaging quantities
- Financing the collection and recycling of packaging
- Keeping company information up to date
However, certain roles, definitions and requirements relating to Authorized Representatives have changed.
What does this mean in practice?
If your online shop was already properly registered in LUCID before August 2026, you do not need to start again from zero.
However, it is worth reviewing your existing compliance setup. In particular, check the following:
- Are your company details and brand names still correct?
- Have you selected the correct packaging categories?
- Do your LUCID quantity reports match the information submitted to your system operator?
- Is your company based outside Germany?
- If so, do you need an Authorized Representative?
The last point is particularly important for international online retailers since August 2026.
Manufacturer or producer: What is the difference?
Two terms play a central role under the PPWR and the VerpackDG: Manufacturer and Producer. In everyday language, these terms can sound very similar. Legally, however, they describe different responsibilities.
Manufacturer
The manufacturer, called the “Erzeuger” in German legislation, is generally the person or company responsible for the conformity of the packaging. This can include a company that manufactures packaging itself or has packaging designed or manufactured under its own name or trademark.
This role relates, among other things, to the PPWR requirements that apply to the packaging itself.
Producer
The producer, called the “Hersteller” in German legislation, bears EPR responsibility in the country where the packaging is made available and eventually becomes waste. This role is particularly important for obligations such as registration, financing packaging recycling and quantity reporting.
A company can be both the manufacturer and the producer at the same time.
Example:
An online shop has its own product packaging developed under its brand and then sells the packaged product directly to customers. Depending on the specific supply chain, the online shop may be responsible both for the conformity of the packaging and for packaging EPR.
For LUCID, the key question is whether your company qualifies as a producer under the applicable EPR rules.
We have a detailed video on our YouTube channel addressing the question of when someone is considered a producer or manufacturer:
What is the LUCID registration number?
After successful registration, companies receive a unique LUCID registration number. It begins with “DE” and is followed by 13 digits. The number serves to uniquely identify your company in the Packaging Registry.
It is important to note a common misconception:
A LUCID registration number alone does not confirm that all packaging obligations have been fully met.
Registration is an important step. For packaging subject to system participation requirements, additional tasks apply, in particular:
- Entering into a system participation agreement
- Correctly reporting packaging quantities to the system operator
- Submitting the corresponding data reports in LUCID
The information provided to the system operator and in LUCID should be consistent.
Need help?
We understand how overwhelming such regulations can seem! But don’t worry, we are here to help. Feel free to inquire without any cost! Our team of experts will get back to you promptly.
Important: Registration does not complete packaging compliance
For packaging subject to system participation, further steps are required.
1. Complete system participation
You enter into a system participation agreement with an authorized system operator and contribute your packaging volumes to the recycling program.
2. Report packaging volumes
Your packaging volumes covered by the system are then also reported in LUCID.
In doing so, you must specify, among other things:
- Reporting period
- System operator
- Material types
- Respective packaging volumes
In general, the information provided to the system operator and in LUCID should match.
For companies that made packaging subject to system participation available in Germany for the first time in the previous calendar year in quantities of less than 10 metric tons, a simplified reporting requirement applies. In this case, an annual final volume report submitted by June 1 of the following year is sufficient.
In short: register, participate, report.
With these three steps, online retailers cover the key processes for packaging subject to system participation in Germany.
Who needs to register with LUCID?
Registration applies to companies that qualify as producers and make packaging available in Germany. In e-commerce, this can include:
- Online retailers
- Manufacturers of packaged products
- Importers
- Brand owners
- Foreign companies selling directly to customers in Germany
Small online shops can also be affected.
There is no general revenue threshold below which registration automatically becomes unnecessary. Instead, the decisive factors are the role your company has and which packaging it makes available in Germany.
Registration in the LUCID Packaging Registry is an important step toward promoting transparency and sustainability in the recycling process. By complying with regulations, you not only contribute to environmental responsibility but also strengthen your customers’ trust in your company. It’s a good idea to stay informed about legal changes and requirements in the area of packaging licensing on a regular basis to ensure you’re always up to date. If only there were a blog or even a YouTube channel that covered this topic regularly…!
Which packaging is subject to system participation?
Not all packaging is treated in the same way under German packaging law.
For B2C online retailers, packaging subject to system participation is particularly relevant. This generally includes packaging that typically becomes waste at private households or comparable sources.
Examples often include:
- Sales packaging
- Secondary packaging
- Shipping packaging
- Certain service packaging
There is one particularly useful rule for online retailers to remember:
Shipping packaging used in e-commerce is subject to system participation.
This can include cardboard boxes, mailing bags and filling materials.
For this type of packaging, LUCID registration alone is not sufficient. You also need to participate in an approved packaging system. Through system participation, your company contributes to the cost of collecting and recycling packaging waste. Packaging that typically becomes waste exclusively in industrial or commercial environments may fall outside the system participation requirement.
The correct classification depends on the specific type of packaging and distribution channel.
What information needs to be entered in LUCID?
During registration, various details about your company and packaging are entered into LUCID.
These can include:
- Company name
- Address
- Responsible persons
- Contact information
- Relevant packaging categories
- Brand names
- Information about your role as a producer
Once your registration has been completed successfully, you receive your individual registration number. For packaging subject to system participation, information about the system operator, reporting period, material types and packaging quantities is also reported.
Important for foreign companies
Since August 12, 2026, information about an Authorized Representative is also relevant if your company falls within the German Authorized Representative requirement.
Foreign companies that were already registered should therefore review their existing LUCID details.
Are you unsure whether you have done everything right?
Or should support you with registration? Write to us free of charge and without obligation:
Authorized Representative for packaging in Germany
The Authorized Representative requirement is one of the most important changes for international online retailers.
Who needs an Authorized Representative in Germany?
The requirement is relevant for companies that:
- Are based outside Germany
- Do not have an establishment in Germany
- Sell empty packaging or packaged products directly to end recipients in Germany
This can quickly apply to typical cross-border B2C sales.
Example:
A Dutch online shop does not have an establishment in Germany and ships orders directly to private customers in Germany. The German Authorized Representative requirement is therefore relevant for this retailer. The same can apply to companies based in Switzerland, the United Kingdom, the United States or other countries.
What does an Authorized Representative do?
The Authorized Representative represents the foreign company in fulfilling its extended producer responsibility obligations in Germany.
Once properly appointed, the Authorized Representative can take over responsibilities relating to areas such as:
- System participation
- Packaging quantities
- Ongoing activities in LUCID
- Communication relating to packaging EPR
- Further obligations under German packaging law
This gives the foreign company a local point of contact for its German packaging compliance.
One important exception: LUCID registration
The initial registration in the LUCID Packaging Register remains a personal obligation of the producer.
This means:
The foreign company completes its own LUCID registration. Changes to the actual registration details also remain the responsibility of the producer.
A service provider or Authorized Representative can support you during the process, but cannot complete the initial registration entirely on your behalf.
What requirements apply to the Authorized Representative?
The Authorized Representative needs to have a registered office or establishment in Germany and the appropriate access to the LUCID Packaging Register.
The producer and Authorized Representative enter into a written agreement covering the appointment.
Simply selecting a company in LUCID is not enough. The appointment should first be agreed contractually and then correctly entered and confirmed in the register.
What applies to foreign companies that are already registered?
An existing LUCID registration from before August 12, 2026 does not automatically remove the new requirement.
Companies without an establishment in Germany should therefore check whether they need to add an Authorized Representative to their existing registration.
The LUCID dashboard provides the relevant functionality.
Could the rules change again at EU level?
Yes. A legislative process is currently underway at EU level that could temporarily simplify the requirement to appoint EPR Authorized Representatives for certain companies established within the EU.
The process has not yet been completed.
For day-to-day compliance, the current legal framework therefore remains decisive. Companies should not base their compliance setup on a potential future exemption until it has been formally adopted and becomes applicable.
We also have detailed videos on the topic of Authorized Representatives:
How does registration in the LUCID Packaging Register work?
Registration in the LUCID Packaging Register is free of charge and completed online through the Central Agency Packaging Register, or ZSVR.
Important: Registration remains a personal obligation of the producer. External service providers can support you, but cannot complete the registration on your behalf.
First, create a manufacturer account in the LUCID packaging register.
During this process, you will be asked to provide information about the company, the person in charge, and the designated contact person, among other details.
After creating your account, you will receive an activation link via email.
After activation, please complete your company information.
This includes, in particular:
- Adress
- Packaging categories
- Brand names
- Additional relevant information about your business
Companies without a registered office or branch in Germany should check here to determine whether the requirement to appoint an authorized representative applies.
If this is the case, the authorized representative already appointed under the contract must be entered in LUCID.
After reviewing the information, submit the application.
Once you have successfully registered, you will receive your administrative decision and your individual LUCID registration number.
For packaging subject to mandatory participation in a recycling system, you must enter into a contract with a system operator.
For B2C online retailers, this applies in particular to typical shipping packaging.
The LUCID registration number is also used for unique identification by the system operator.
The packaging quantities reported to the system operator are also recorded in LUCID in accordance with the applicable reporting requirements.
This links system participation and data reporting.
We have additional guidance on mandatory volume reporting and obtaining a packaging license available for you in our digital compliance service. You can even use our packaging licensing service in Germany for free.
Which packaging quantities need to be reported?
An important change has applied since August 2026. In general, your reporting requirements depend on the reporting schedule agreed with your system operator.
For example, if your company reports quantities for a specific period to the system operator, the corresponding information is also entered in LUCID. The reporting period, material type and quantity should match.
Simplified reporting below 10 metric tons
The new legal framework includes a relevant simplification for smaller quantities. If a producer placed a total of less than 10 metric tons of packaging subject to system participation on the German market during the previous calendar year, a simplified reporting requirement applies.
In this case, one annual final quantity report by June 1 is sufficient. This can significantly reduce the administrative workload for smaller online shops.
Our practical tip:
Keep accurate records of your packaging quantities even if your company remains below this threshold. Good data makes the annual report easier and helps you plan your system participation.
Which deadlines are relevant?
There is no single general annual LUCID deadline.
The deadlines that apply depend on the specific obligation.
Before your first sale
Registration should be completed before the relevant packaging is first made available in Germany. If your company is based outside Germany and does not have an establishment in Germany, you should also arrange an Authorized Representative in good time where the legal requirements apply.
System participation for relevant packaging should also be arranged before the packaging is placed on the market.
Ongoing quantity reporting
The reporting schedule generally follows your agreement with the system operator.
The information in LUCID and the information provided to the system operator should match.
Simplified annual final quantity report
If your company placed less than 10 metric tons of packaging subject to system participation on the market during the previous calendar year, the deadline for the simplified annual final quantity report is June 1.
Declaration of completeness
Companies with particularly high packaging quantities may also be required to submit an audited declaration of completeness.
The general deadline is May 15 for the previous reporting year.
Special transitional rules apply to the 2026 reporting year due to the change from the VerpackG to the VerpackDG.
What happens if you do not register?
Missing or incorrect packaging compliance can have a range of consequences.
Depending on the type of non-compliance, these can include:
- Sales restrictions
- Fines
- Measures taken by the competent authorities
- Issues with marketplace compliance checks
- Questions from business partners
The best approach is therefore to establish a clear process covering registration, system participation and quantity reporting.
For international sales, checking whether an Authorized Representative is required should also be part of this process.
This keeps packaging compliance manageable and makes it easier to integrate into your existing e-commerce processes.
Who can access the LUCID Packaging Register?
The register of producers is publicly accessible.
This means that business partners, competitors, authorities and consumers can check whether a company is registered. Publicly available information includes details about the company, the registration number and registered brand names.
Packaging quantities are not publicly visible.
This transparency is also relevant for online marketplaces. Many platforms check EPR registration numbers before retailers can offer certain products or packaging.
LUCID, VerpackDG and ecosistant
Packaging compliance today involves much more than obtaining a LUCID number. For online retailers selling across borders, several steps need to work together:
- Determine your role as a producer
- Complete LUCID registration
- Classify your packaging correctly
- Arrange system participation
- Set up quantity reporting
- Check whether an Authorized Representative is required and appoint one where necessary
- Keep track of changes and deadlines
This is exactly where ecosistant can help.
For smaller companies
Our digital Self-Service platform provides online retailers with practical step-by-step guidance for EPR compliance.
You can see which requirements apply in your sales markets and which steps to take next.
For medium-sized and larger companies
With our Premium Service, we take over the operational implementation of your EPR obligations across Europe.
Depending on the country and waste stream, this can include registrations, quantity reporting, system participation and coordination with local organizations.
Authorized Representative for packaging
For companies without an establishment in Germany, we can also support you with the Authorized Representative requirement for packaging.
The personal LUCID registration remains your company’s responsibility. Once appointed, however, the Authorized Representative can take over key additional EPR responsibilities.
Do you sell to customers in Germany or multiple European countries and want to set up your EPR compliance properly?
With ecosistant, you can choose the solution that fits your company size and sales markets. Use our digital Self-Service platform or outsource your operational EPR compliance through our Premium Service.
FAQ: Die häufigsten Fragen zum LUCID Verpackungsregister
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The LUCID registration number is the individual identification number of a company registered in the Packaging Register.
It starts with “DE” followed by 13 digits.
Yes. Registration with the Central Agency Packaging Register is free of charge.
Costs may arise elsewhere, for example through system participation or if an Authorized Representative is required.
No.
The registration number confirms that your company is registered.
If you place packaging subject to system participation on the market, you also need to arrange system participation and submit the relevant quantity reports.
Companies without an establishment in Germany may additionally need to appoint an Authorized Representative.
Small companies can also be subject to registration.
There is no general minimum quantity or revenue threshold for LUCID registration.
However, a simplified reporting requirement applies to producers that placed less than 10 metric tons of packaging subject to system participation on the German market in the previous calendar year.
The requirement is particularly relevant for companies based outside Germany that do not have an establishment in Germany and sell packaged products or empty packaging directly to end recipients in Germany.
No. The initial registration remains the responsibility of the producer.
Once appointed, however, the Authorized Representative can take over other EPR responsibilities.
Foreign companies without an establishment in Germany should check whether an Authorized Representative now needs to be added to their existing registration.
An existing registration alone does not replace this assessment.
The specific Authorized Representative requirement applies to foreign companies without an establishment in Germany.
If your company has an applicable establishment in Germany, the situation is therefore different.
A legislative process is underway at EU level concerning potential simplifications to the Authorized Representative requirement.
Until any change has been formally adopted and becomes applicable, the current legal framework continues to apply.
We help online retailers implement their EPR obligations in a structured and efficient way.
Smaller businesses can use our digital Self-Service platform. Medium-sized and larger companies can outsource their operational EPR compliance through our Premium Service.
For cross-border sales, we can also support you with the coordination and provision of Authorized Representatives for relevant EPR areas.
No, there is no general requirement to include the LUCID registration number in the online store’s legal notice. The VerpackDG regulations on registration do not require retailers to publish this information. The registration number is made public anyway through the public manufacturer registry.
You receive your LUCID registration number automatically after successfully completing your registration in the LUCID Packaging Register.
There is no separate application for the number.
You can find your registration number in your LUCID dashboard, in the official registration notice and in the public register of producers.
Your registration details should always be kept up to date.
Changes should be entered in LUCID without delay. This can include changes to your business address, company details, packaging categories or brand names.
For foreign companies, changes relating to the Authorized Representative may also be relevant.
You need your registration number for activities including the system participation of your packaging.
Online marketplaces may also request your number to verify your EPR compliance. Many marketplaces therefore provide dedicated compliance areas where the registration number can be submitted.
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