Detailed answers for sellers and companies working with the German market.
Yes, as soon as the Russian company delivers packaged goods directly to German end consumers. Whether the company is inside or outside the EU makes no difference — what matters is simply who first places the packaging on the German market.
The registration itself can be completed online, independent of company location. Since 12 August 2026, foreign producers without a German establishment who supply end consumers directly must also appoint an Authorised Representative in Germany.
A German business address is not required for LUCID registration. You register online in the LUCID register using your actual company details from your home country — company name, foreign trade register number and contact address are enough.
For foreign producers without a German establishment who supply end consumers directly, since 12 August 2026 there's an additional duty to appoint an Authorised Representative in Germany — that person needs a German address, your company doesn't.
It depends on who counts as the first placer on the market. If the German intermediary buys the goods and resells them under its own name, the registration duty usually sits with them.
If instead you ship directly to German end customers yourself and the intermediary only handles referral or logistics, you remain the first placer. Get the role confirmed in writing, so you have proof either way.
Yes. LUCID registration is open to companies from any country, including China — EU membership or a European company location isn't a precondition.
All you need is valid company details and a contact address. Since 12 August 2026, manufacturers without a German establishment who deliver directly to end consumers must also appoint an Authorised Representative.
Yes, without exception. The law recognises no testing phase, trial period or de minimis threshold — the registration duty arises with the very first packaged shipment to a German end consumer, whether it's a permanent market entry or a one-off test.
Plan registration before the first test sale, not after proven success. For small test volumes, licence costs are correspondingly low.
Brexit itself changed nothing about the VerpackG duty — UK companies have been treated as any other third-country company since leaving the EU and already had to register with LUCID before Brexit if they delivered to Germany.
What's new since 12 August 2026 is the duty to appoint an Authorised Representative for producers without a German establishment — that applies to UK companies just like any other third country.
No. Every EU country runs its own EPR system with its own register: LUCID for Germany, Citeo for France, CONAI for Italy, Ecoembes for Spain, and so on. There's no single EPR number covering every country.
The EU's PPWR regulation harmonises data format and procedure since 12 August 2026, but not the registration duty itself — you still register separately in each country. Details in EPR numbers in EU countries.
No. LUCID registration is uniform nationwide — there's no registration at the level of individual federal states. One registration with the Central Agency Packaging Register covers all of Germany.
That's different from federally organised countries like the US, where some states run their own registers. For the German market, a single central registration is enough, regardless of which states you ship into.
Act quickly. File the LUCID registration immediately and report the actual packaging volumes for past years as accurately as you can — estimates based on sales data are better than no report at all.
Proactive action is judged far more leniently by the ZSVR than continued inaction. For multi-year backlogs, it's worth getting specialist advice, since the correction itself needs to be set up correctly.
It depends on the contractual model. If the marketplace genuinely acts as the official seller — buying the goods and selling them under its own name — responsibility for the sales packaging sits with the marketplace.
If you're selling under your own name through the marketplace and it only acts as an intermediary, you remain the first placer with your own registration duty. Check the actual contractual arrangement, not just how it's presented.
Usually not you in genuine dropshipping — your supplier, who packs and ships directly to the German end customer, is the first placer.
You still need to submit your supplier's LUCID number and system participation proof to the marketplace, as their data, not your own. If you pack part of the orders yourself, you're independently registration-liable for that portion. More in Who really needs LUCID registration?.
Ask for proof, rather than just trusting it. Get your supplier's LUCID number and check it yourself in the public LUCID register.
For service packaging, transferring licensing to the supplier is legally allowed — but you've still had to complete the LUCID registration yourself since 1 July 2022. For other packaging types, a full transfer of the producer duty often isn't possible if you yourself are the first placer.
Yes, even for a single shipment. VerpackG has no de minimis threshold and no exception for one-off deliveries — the duty arises with the first packaged goods reaching a German end consumer.
For a single shipment, though, the effort is manageable: registration itself is free, and licence costs for a small volume are typically modest.
Wait for official allocation of your company number — LUCID needs solid, official company details such as a trade register number, which often isn't finalised yet during incorporation.
Plan the registration in parallel with incorporation so it can be completed as soon as you receive your company number — ideally before your first sale into Germany. A provisional trade register extract is sometimes enough to start the registration in certain cases.
Ukrainian companies are subject to the same rules as any other third-country company — EU membership or geographic proximity makes no difference. Once packaged goods are delivered to German end consumers, the LUCID registration duty arises.
Since 12 August 2026, companies without a German establishment must additionally appoint an Authorised Representative. Registration itself can be completed online regardless of company location.
It depends on the contractual role. Commercial agents acting in the name and on the account of the foreign company don't change that company's own registration duty — the company remains the first placer.
If the agent instead acts as a reseller, buying the goods and reselling them, packaging responsibility can shift to them. Clarify the exact contractual arrangement, since "agent" is used loosely in everyday business.
Yes. Importing from China generally makes you, as the German importer, the first placer — even if the Chinese manufacturer already produced and filled the packaging, the German registration duty falls on whoever first places the goods on the German market.
Any Chinese compliance certification has no effect under German VerpackG. Since 1 January 2025, marketplaces are also no longer allowed to list products from unregistered importers.
This changed recently. Since 12 August 2026, the VerpackDG and the EU's PPWR regulation require foreign companies without a German establishment that sell directly to German end consumers to appoint an Authorised Representative (Bevollmächtigter). Before that date, no such requirement existed.
The legal basis is Article 45(3) PPWR and section 5(2) VerpackDG. Importantly, the duty applies per member state — a company delivering to Germany, France and Italy needs three representatives. There's no single-window process.
The representative fulfils your obligations and is liable to the authorities for them. You still have to complete registration yourself, though — it can't be delegated. Details in our guide to VerpackDG 2026 and in What is an Authorised Representative?.
Don't have one yet? We're happy to help you find one.
Yes. Companies from the United Arab Emirates are subject to the LUCID duty without restriction once packaged goods reach German end consumers — being based outside the EU makes no difference.
Registration happens online and independently of country of origin. Since 12 August 2026, companies without a German establishment also need an Authorised Representative in Germany.
International marketplaces actively serving the German market count as electronic marketplaces under VerpackG and, since 1 July 2022, must check whether their third-party sellers are properly registered with LUCID.
For you as a seller on such a marketplace, the basic duty doesn't change: as soon as you deliver packaged goods to German end customers, you need your own LUCID registration, regardless of where the marketplace operator is based.
It depends on where the packaging ends up as waste. Pure B2B deliveries with commercial disposal don't trigger system participation.
The LUCID registration duty still applies, though — since 1 July 2022 it covers all packaging, including packaging not subject to system participation. If you supply both B2B and private customers, only the private portion is licence-liable, but registration itself covers both.
If you use an EU warehouse to ship into Germany — for example under Amazon Pan-EU or multi-country FBA — the warehouse location doesn't change the duty: what matters is simply that the goods arrive packaged with German end consumers.
A registration in the warehouse country doesn't replace the German registration, and vice versa. You need the relevant EPR registration for every country goods are actually delivered to, regardless of where the goods are temporarily stored.
It depends on the consignment model. If the goods stay in your ownership until sold and the German distributor merely sells them on your behalf to end customers, you generally remain the first placer.
If ownership passes to the distributor on receipt and they resell under their own name, the registration duty can sit with them. Have ownership and responsibility clearly set out in the consignment agreement.
Companies from the EAEU (Kazakhstan, Belarus and other member states) are subject to the same rules as any other third-country company — EAEU membership has no special effect under German or European law.
Once packaged goods are delivered to German end consumers, the LUCID registration duty arises, plus, since 12 August 2026, the duty to appoint an Authorised Representative for companies without a German establishment.
Yes. Companies based in special economic zones — such as free ports or free zones — are fully subject to VerpackG once they place packaged goods on the German market. The zone status in the country of origin has no bearing under German law.
What matters exclusively is who first places the packaging on the German market — independent of any tax or customs arrangements in the country of origin.
With complete and correctly prepared documentation, LUCID registration usually takes one to five business days. Delays almost always come from incomplete or incorrectly entered company details.
Communication with LUCID happens in German or English; the portal itself has an English-language interface. Prepare company name, trade register number and contact details exactly as they appear in your official register to avoid follow-up questions.
No. A German tax number or VAT ID isn't strictly required for LUCID registration. Foreign identification numbers from your home country are accepted too.
For other aspects of selling into Germany — such as VAT liability itself — a German tax number can still become relevant, but that's a separate matter from packaging registration.
With multiple company entities across different countries, each legal entity that is actually the first placer in Germany registers separately — registration follows the legal entity, not the group as a whole.
If only one particular subsidiary delivers to Germany, only that entity registers. If the delivering entity within the group changes, the registration must be updated or re-filed accordingly.
Yes. Franchise products are subject to the same duties as any other packaged goods. Who counts as first placer depends on the franchise agreement: if the franchisor delivers the goods already packaged to Germany, the duty usually sits with them.
If the individual franchisee sources and packages the goods locally, the registration duty can sit with them instead. Clarify the allocation in the franchise agreement, since both arrangements occur in practice.
Aggregators bundling several brands or sellers under one roof don't change the basic principle: whoever first places the packaging on the German market is registration-liable. Depending on the business model, that can be the aggregator itself or the individual brand.
If the aggregator resells the acquired brands' products under its own name, the duty usually sits with the aggregator. If the brands remain identifiable as independent sellers, each brand typically registers separately.
What's essentially needed: company name and legal form, an official company ID number from your home country (such as a trade register number), a contact address, and details of the brands you sell under.
A German tax number or VAT ID isn't required. Prepare the details exactly as they appear in your country's official register — mismatches are the most common cause of registration queries.
Sales at German trade fairs fall under VerpackG once packaged goods are actually handed to private end consumers on site — even a one-off trade fair stand isn't an exception.
Pure business networking without goods handed to end consumers doesn't trigger the duty. If product samples or sale goods are handed directly to fair visitors, though, that counts as placing on the market and must be registered and reported accordingly.
If a foreign company relocates to Germany, it becomes a domestic first placer for all future shipments — with full VerpackG duties from the point of relocation.
An existing registration from the country of origin doesn't automatically carry over to Germany; a new or updated LUCID registration is required regardless of previous location. Check in parallel whether ongoing contracts with foreign compliance systems need to be cancelled, to avoid paying twice.