Germany: LUCID packaging registration for online shops

Who has to register

Under the German Packaging Act (VerpackG), the “Hersteller” (producer) is whoever first places filled packaging on the market in Germany on a commercial basis. For distance selling to German consumers, that is the seller who ships the parcel, including sellers outside Germany. It covers:

• sales packaging around the product;
• shipping packaging: boxes, envelopes, padding, filler and tape;
• service packaging filled at the point of sale.

There is no minimum quantity for registration. A small shop sending a few parcels a month to Germany is covered too.

Step 1: Register in LUCID

Registration in LUCID is free and done online. You enter your company details, your brand names and a national tax or identification number. After registration you get a LUCID registration number. Since July 2022, every producer of packaging must be registered, including those whose packaging is not subject to system participation, such as transport packaging that stays with businesses.

Step 2: Join a dual system

Packaging that typically ends up with private end consumers is “systembeteiligungspflichtig”. You must sign a contract with one of the approved dual systems and pay fees based on the expected weight per material. Online shops usually license:

• paper, cardboard and carton (shipping boxes);
• plastics (bags, bubble wrap, tape, product packaging);
• glass, metals and composites if your products use them.

Estimate a year's quantities realistically and correct them with the actual figures at year end.

Step 3: Report the same data to LUCID

The quantities you report to your dual system must also be reported to LUCID: the planned quantities when you sign up and the actual quantities at year end. The Zentrale Stelle compares the two. Mismatches are a common reason for enquiries.

Step 4: Declaration of completeness (larger sellers)

Producers above certain annual thresholds of packaging subject to system participation must submit a declaration of completeness (“Vollständigkeitserklärung”) by 15 May for the previous year, checked by an auditor. The thresholds are high for small shops: 80,000 kg of glass, 50,000 kg of paper and cardboard, or 30,000 kg of the other materials combined. Check the current figures in LUCID.

Marketplaces and fulfilment providers

Since July 2022, online marketplaces may only allow sellers to offer packaged goods if they are registered in LUCID and participate in a system, and fulfilment service providers must check the same before handling the goods. That is why marketplaces ask for your LUCID number.

PPWR changes

With the PPWR applying from 12 August 2026, Germany is adapting its national law to the EU regulation. Registration in LUCID and participation in a system remain central. The PPWR adds the requirement for producers not established in Germany to appoint an authorised representative for EPR, subject to the open question of a postponement for EU-based producers. Check LUCID's current guidance for your situation.

Fines

Selling packaging without registration or without system participation is an administrative offence, and fines can reach six figures. Unregistered packaging may also not be offered at all, which marketplaces enforce by blocking listings.