By Nadezda Walz · 11 min read · Updated 05.08.2026
If you ship packaged goods to customers in Germany — even a single parcel — German law almost certainly applies to you, regardless of where your business is registered. This guide explains what the Packaging Act actually requires, in plain language, with links to the official sources.
TL;DR - The Verpackungsgesetz (VerpackG) requires anyone placing packaged goods on the German market for the first time to register in LUCID and take out a packaging licence with a dual system. - This applies to foreign online sellers too — there is no exemption for businesses based outside Germany. - Fines for missing registration or licensing reach up to €200,000 per violation, and competitors can send costly formal warnings (Abmahnung) if they spot you in the public LUCID register. - From 12 August 2026, additional EU-wide rules (PPWR) and a German Authorised Representative requirement come into force — see our dedicated guide on that.
Official sources: Gesetze im Internet — VerpackG, Zentrale Stelle Verpackungsregister (LUCID), Umweltbundesamt
What is the Packaging Act (VerpackG)?
The Verpackungsgesetz came into force on 1 January 2019, replacing the older Packaging Ordinance. Its purpose is to make manufacturers and sellers financially responsible for the packaging waste their products create — a principle known as Extended Producer Responsibility (EPR). In practice, this means: if you put packaging on the German market, you pay for its collection and recycling.
The law applies to sales packaging — the packaging that ends up with the private end consumer. That includes shipping boxes, padding material, product boxes, labels, and any packaging a private household in Germany would typically throw away or put in recycling.
Who exactly is affected?
You are covered by the VerpackG if all of the following are true:
- You place packaged goods on the German market for the first time (this includes shipping from abroad directly to a German customer)
- The packaging is sales packaging that typically ends up with a private end consumer
- You are the "first mover" — the first business to bring that packaging into Germany, which for most online sellers means you, not your supplier or manufacturer
Crucially, your registered business location doesn't matter. A seller based in the US, China, or anywhere else who ships packaged goods to a private customer in Germany is legally the "manufacturer" under German law and must comply, just like a German company would.
The three obligations in practice
1. Register in LUCID
LUCID is Germany's central packaging register, run by the Zentrale Stelle Verpackungsregister (ZSVR). Registration is free, done entirely online, and is a legal prerequisite before you're even allowed to sign a contract with a dual system. You'll need:
- Your company details (name, legal form, address)
- A responsible contact person
- The material types and estimated quantities you expect to place on the market
Once registered, you receive a LUCID registration number, which many marketplaces (Amazon, Etsy, eBay, Kaufland) now require before allowing you to list products shipping to Germany.
2. Take out a packaging licence (dual system)
Registration alone isn't enough — you must also license your packaging quantities with one of Germany's approved "dual systems" (Der Grüne Punkt, Interzero, Reclay, Landbell, and others). This is the mechanism that actually funds collection and recycling. Costs scale with material type and weight; most small and mid-sized online sellers pay somewhere between roughly €25 and a few hundred euros per year, depending on volume.
3. Submit your annual quantity report
Each year, you must report the actual quantities of packaging you placed on the market to your dual system and, above certain thresholds, submit a Vollständigkeitserklärung (declaration of completeness) to LUCID. This reconciles what you licensed against what you actually shipped.
What happens if you don't comply
| Violation | Consequence |
|---|---|
| No LUCID registration | Fine up to €100,000; you also cannot legally sell packaged goods in Germany |
| No dual system participation | Fine up to €200,000 |
| Incomplete or late annual report | Fine, plus risk of losing your LUCID registration |
| Any of the above, spotted by a competitor | Abmahnung (formal warning) — typically several thousand euros in legal costs, since LUCID's registry is public and searchable |
| Marketplace enforcement | Amazon, Etsy, and others actively check LUCID numbers and can suspend listings or accounts without one |
The public nature of the LUCID register is worth emphasizing: competitors, compliance services, and even private individuals can search it. Missing or incorrect registrations are found — this isn't a theoretical risk.
Common mistakes we see
- Assuming a manufacturer or fulfilment partner already handles it. In most cross-border e-commerce setups, the seller — not the factory, not the freight forwarder — is legally the "first mover" and responsible party.
- Registering in LUCID but skipping the dual system licence. These are two separate steps; LUCID registration alone does not fulfil your obligation.
- Under-reporting quantities to reduce licensing fees — this is exactly what the annual completeness declaration is designed to catch.
- Believing the law doesn't apply below a certain revenue threshold. Unlike some VAT rules, there is no general small-business exemption from the VerpackG's registration duty.
Quick self-check
Ask yourself these three questions:
- Do you ship packaged products directly to private customers in Germany (including via a marketplace)? → If yes, continue.
- Are you registered in LUCID under your own company name? → If no, this is your next step.
- Do you have an active licence with a dual system covering your actual shipped volumes? → If no or unsure, this needs checking before your next reporting deadline.
If you answered "no" or "not sure" to either of the last two, you likely have exposure right now — not a future problem.
Frequently asked questions
Does this apply if I only sell a few packages a year to Germany? Yes. There is no minimum volume threshold for the registration duty itself, though licensing costs scale with your actual volume.
I already have an EPR registration in France/another EU country — does that cover Germany too? No. Germany's system is separate from other EU countries' EPR schemes. You need a distinct LUCID registration and German dual system licence.
Can my logistics or fulfilment provider register on my behalf? Some compliance services can manage the process for you, but the legal registration itself must be under your company's name — the responsibility can be outsourced administratively, not legally transferred.
What's the difference between LUCID and the dual system? LUCID is the free, mandatory public register. The dual system is the paid licence that actually funds waste collection — you need both, and they're separate providers.
Is this changing soon? Yes — from 12 August 2026, EU-wide packaging rules (PPWR) and a German Authorised Representative requirement add further obligations. See our dedicated guide for what's changing.
Conclusion
The Packaging Act isn't optional paperwork — it's a legal prerequisite for selling packaged goods to German consumers, enforced both by regulators and by competitors watching the public register. The good news: registration and licensing are entirely online processes that most sellers can complete in under an hour once they know which steps apply to them.
If you'd like a second pair of eyes on your specific situation — what to register, which dual system fits your product category, and how to avoid the common mistakes above — book a consultation and we'll walk through it together.
About the Author
Nadezda Walz advises Amazon sellers and online retailers on packaging compliance in Germany and across Europe (LUCID, EPR, VerpackG/VerpackDG). Before consulting, she ran her own Amazon FBA business — so she understands the seller's perspective not just in legal theory, but in practice.