Detailed answers for sellers and companies working with the German market.
Act quickly, but sensibly. File the LUCID registration immediately and take out a dual system contract in parallel. For past years, report the actual packaging volumes 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 and the dual systems than continued inaction. For multi-year backlogs, it's worth getting advice from a VerpackG-specialised provider, since the correction itself should be set up correctly. More on the basics in LUCID registration: step by step.
Trust alone isn't enough — ask for proof. Get your supplier's LUCID number and check it yourself in the public LUCID register. For service packaging, transferring the licensing duty under section 7(2) VerpackG to the supplier is legitimate — but you've still had to register with LUCID yourself since 1 July 2022.
For other packaging types, transferring the producer duty to the supplier usually isn't legally possible if you yourself are the first placer on the market — say, because you pack or ship the goods. A verbal assurance won't protect you if it comes to a fine.
You only need one LUCID registration — it applies across all channels. What you need to organise is bringing the volumes from every channel together into a single annual report.
What works well: determine packaging weight per item once, export sales figures monthly from Amazon Seller Central, Shopify reports and Etsy statistics, multiply by weight and add up. Report identical figures to LUCID and to your dual system — discrepancies between the two are the most common trigger for follow-up questions during checks.
It depends on who counts as the first placer on the market. If you supply goods to a German distributor who resells them under their own name, the distributor is usually responsible for the sales packaging — they place it on the German market for the first time.
Get this confirmed in writing, ideally with the distributor's LUCID number attached. If instead you sell directly to German end customers yourself and the distributor only handles logistics, you remain the first placer and must register yourself.
Damaged packaging that arrives at the customer changes nothing about the EPR duty — what matters is the material and weight of the packaging originally used, not its condition on arrival.
The damage only becomes practically relevant if it leads you to use additional packaging — for example, a replacement shipment with a new box and new filler. That extra volume counts separately. It's worth tracking returns and replacement shipments continuously so they don't get lost from the annual report.
The supplier change itself is not a reportable event — your LUCID registration and your dual system contract stay unchanged.
It only matters if the change alters the packaging's material or weight — say, switching from plastic film to paper, or a different box weight. That change affects licensing cost and should be reflected correctly in your next quantity report. Keep the new supplier's material data sheets in case your dual system asks for proof.
Voluntary self-declaration is a proactive report to the ZSVR or a dual system, made before any check or request arrives — typically used to disclose past shortfalls and establish compliance on your own initiative.
It's worth doing if you discover gaps in your registration or reporting history before the authority does. A proactively reported breach is treated more leniently in practice than one uncovered during a check. There's no guarantee against a fine, though — it remains at the authority's discretion.
It depends on where the packaging ends up as waste. Sales to commercial customers whose packaging is returned via commercial disposal don't trigger system participation.
The registration duty in LUCID still applies, though — since 1 July 2022 it covers all packaging, including transport packaging not subject to system participation. Mixed models are risky: as soon as even part of your customers are private individuals, that portion becomes licence-liable and must be tracked separately from the B2B volumes.
Subscriptions are demanding under packaging law because volumes recur — with monthly shipping, the packaging weight per customer multiplies by twelve across the year.
Everything counts: the shipping box, filler material, the individual product packaging of the included items, and paper inserts like cards or booklets. If you bundle bought-in products into your own box for the first time, you're responsible for that outer packaging too, even if the manufacturer already licensed the individual items.
Yes, the shipping route makes no difference. What matters is simply that packaged goods reach the German market commercially for the first time — whether via DHL, an international postal service or a courier is legally irrelevant.
For shipments from third countries there's an added point since 1 January 2025: fulfilment providers and marketplaces are no longer allowed to offer products from unregistered producers. Sort out registration before your first shipment, not after a complaint.
Outstanding EPR duties do not automatically disappear with insolvency. Reporting duties and licence fees already incurred are generally treated as insolvency claims and must be accounted for by the insolvency administrator.
For the period after insolvency proceedings open, what matters is whether the business continues to trade: if packaged goods keep being placed on the market, the duties continue unchanged. If the business closes, the LUCID registration should be properly deregistered to avoid later confusion.
Typical warning signs: providers presenting themselves as an "official LUCID portal", charging inflated fees for what is actually a free registration, or applying pressure with threats and tight deadlines.
Registration in the LUCID register is always free and only runs through the official domain lucid.verpackungsregister.org. Legitimate service providers charge for advice and licence brokering, not for the registration itself. When in doubt, check the sender's address and contact the ZSVR directly.
For a temporary technical outage, document the attempt — a screenshot with date and time — and register as soon as the portal is available again. Registration should still be completed before your first placement on the market.
For longer outages, the ZSVR typically announces maintenance windows on its website. A technical portal failure doesn't permanently exempt you from the registration duty, but short delays are generally not sanctioned.
Yes, generally. Business gifts sent packaged to recipients in Germany are subject to the same duties as any other packaged shipment — even though no sale takes place.
What matters isn't the sale but the placing on the market of packaged goods. For small, one-off volumes the practical effort is manageable: LUCID registration is still required, and licence costs for small quantities are usually low.
A ZSVR order isn't an informal request but a formal administrative act with a deadline. Read it carefully and respond on time — it's usually about missing registration, a missing quantity report, or a requested declaration of completeness.
Failing to respond within the deadline can lead to a fine procedure. If you're unsure what's being asked for, prompt contact with the ZSVR or a specialised adviser is worthwhile — staying silent is always the worst option.
Even unusual packaging forms — custom builds, displays, reusable prototypes or niche materials — fall under VerpackG once they're filled with goods and handed to private end consumers in Germany for the first time.
Classification by material and system-participation liability follows the same rules as standard packaging. For unusual materials it's worth checking with your dual system beforehand, since not every material sits in the standard catalogue and a separate classification may be needed.
Here two systems often apply in parallel. Shipping and sales packaging falls under VerpackG with LUCID registration and system participation.
The Single-Use Plastics Fund can additionally apply — for example to cups, takeaway containers or film packaging intended for immediate consumption. Since 3 November 2025 there's relief here: packaging containing more than 500 grams is exempt from the levy. Details in EWKFonds for food sellers.
What matters is the intended purpose. If the container itself is the product being sold — a reusable water bottle or a storage box marketed as such — it counts as goods, not packaging.
If the same container is mainly used to transport and protect a different product, it counts as packaging, even if it's reusable. In borderline cases, how the product is described and marketed in the listing is decisive.
Zero-waste and unpackaged products are not automatically exempt from VerpackG. As soon as any wrapping is used for shipping — even compostable or recycled material — it counts as packaging under the law.
The difference usually lies only in the scale: consistently avoiding packaging means correspondingly lower volumes to report and lower licence costs. A zero report is only valid if genuinely no system-participation-liable packaging is used at all.
A customer's request doesn't change your duty as first placer. As long as you ship the goods packaged — and some degree of protective packaging is practically unavoidable in shipping — the reporting duty remains.
If you genuinely forgo all packaging, for example with an in-person hand-over with no wrapping at all, system participation doesn't apply to that specific transaction. In regular shipping business, though, that's the exception, not the rule.
If a company relocates to Germany, it automatically becomes a domestic first placer for all future shipments — with full VerpackG duties from the point of relocation.
Existing registrations from the country of origin don't carry over to Germany; a new LUCID registration is required regardless of previous location. Check early whether and when existing contracts with foreign compliance systems need to be terminated, to avoid paying twice.
Yes. Goods from vending machines in Germany count as supplied to private end consumers and are fully subject to VerpackG once packaged — snacks, bottled or canned drinks, and so on.
Operators of the machines, or the businesses behind them, count as the first placer if they place the packaging on the German market for the first time. For beverage packaging up to 3.0 litres, the Single-Use Plastics Fund can additionally apply if the products are intended for immediate consumption.
In sharing models, what matters is whether disposable packaging is placed on the market with goods at all. Pure rental or use without any packaging hand-over doesn't fall under VerpackG.
If packaged products are sold or supplied as part of the sharing model — accessories, spare parts, consumables — the usual duties apply to that packaging. Reusable systems within the sharing economy can, under certain conditions, be exempt from system participation.
With box subscriptions, every layer counts together: the outer shipping box, the filler material, the individual packaging of the included products, and printed inserts. The total weight determines the licence cost.
Since subscription deliveries recur, the volumes add up substantially over the year — with monthly shipping, the weight per customer is six to twelve times that of a single shipment. Recalculate the box's composition each time it changes, since materials and weights shift frequently.
Check first whether the requirement really is unjustified — in most cases it isn't: even where the product itself falls outside VerpackG, the shipping packaging almost always triggers the duty.
A genuine exception only applies to completely unpackaged goods or pure services. If that's the case, dispute it via Account Health → Regulatory Compliance and explain specifically. In every other case, registering with LUCID is faster than contesting.
The sales format is legally irrelevant. What matters is physical delivery of packaged goods to a German end consumer — whether the purchase happens during a livestream, via direct message or through a standard checkout changes nothing about the duty.
Practically relevant for live formats: orders often arrive in bursts, which makes quantity tracking harder. Record shipments continuously rather than compiling them only at year-end, so there are no gaps by the reporting deadline.
An ongoing LUCID registration doesn't retroactively protect you from a cease-and-desist letter for the past — but it does show you're actively working on compliance, which usually helps in negotiations.
Check the letter's validity: does it refer to an actual, specifically named breach? Respond within the deadline even while registration is still in progress — staying silent weakens your position. When unsure, have a lawyer review it before signing any declaration to cease and desist.
First check via the public LUCID register whether a third party is actually using your number, or whether it's a mix-up with a similarly named company or an outdated register entry.
If misuse is confirmed, contact the ZSVR promptly and document where you found it — for example, a marketplace listing wrongly using your number. Since the number is tied to your company, third-party misconduct can damage your reputation; quick clarification is in your own interest.
Sales via B2B procurement portals follow the same principles as other commercial sales: system participation applies to packaging that typically ends up as waste with a private end consumer, not to pure B2B transport packaging.
The LUCID registration duty applies regardless, for all packaging. With mixed customer structures, check whether the portal is also used by sole traders or freelancers who may in part be treated like end consumers under packaging law.
A dual system can decline a contract, for example over unclear company details or unusual packaging materials missing from the standard catalogue. There's no general obligation for every provider to accept every applicant in this exact form.
In practice, several approved dual systems operate in Germany — if one declines, approach another. If refusal persists, contact the ZSVR, which maintains a list of all approved system operators.
Yes. German online pharmacies count as marketplaces or sales channels under VerpackG and regularly request a valid LUCID number from third-party sellers, especially for over-the-counter products outside prescription requirements.
Alongside packaging registration, health and care products often have their own product-specific rules, such as labelling requirements. The VerpackG duty applies independently, for every packaged shipment to German end consumers.
Seasonal goods aren't subject to any special rules — the VerpackG duty applies regardless of whether you sell year-round or only during certain periods. There's no de minimis threshold and no exception for short selling windows.
Practically important: if your sales concentrate into a few months, that can push your annual volumes towards the declaration-of-completeness thresholds quickly (80 t glass, 50 t paper, 30 t other materials). Plan your quantity tracking in good time before the peak season, not during it.
A company operating in two different niches generally needs one shared LUCID registration — registration is tied to the company, not to individual products.
What matters is that every brand and every sales channel you sell under is listed in the LUCID entry. If the two niches use very different packaging materials — glass in one, plastic in the other — volumes are tracked separately by material but reported under the same registration.
Yes, as soon as physical merchandise — T-shirts, posters, records, collectibles — is shipped packaged to German buyers. It makes no difference whether the sale is arranged through a music, podcast or streaming platform.
Such platforms currently vary in how strictly they check EPR data; the legal duty applies regardless. Use the same LUCID number as your other sales channels and add the volumes together.
Receiving several cease-and-desist letters from different competitors over the same breach means checking each one individually for validity — deadlines and specific demands can differ. Respond to each within its deadline, even if the underlying issue is identical.
In parallel, establish compliance immediately: LUCID registration, system participation, and correct quantity reporting. With several simultaneous letters, coordinated legal representation is often worthwhile to avoid contradictory responses to different senders.
Yes, as soon as the NFT sale is tied to physical delivery of packaged goods to a German buyer — for example, a digital collectible bundled with physical merchandise. The digital component itself doesn't trigger the VerpackG duty, but the physical one does.
What matters is the material and weight of the packaging actually shipped, regardless of the sales model. Since NFT platforms typically don't request EPR data, responsibility sits entirely with you as the shipper.
Yes. German electronics and media retailers that admit third-party sellers via their own marketplace models regularly request a LUCID number and, as marketplace operators, share responsibility for sellers' EPR compliance.
For electronics products, a WEEE registration with Stiftung EAR is often also required, and a battery registration for battery-powered items. Check separately for each product category which systems apply.
Selling used goods with new shipping packaging is subject to the standard duties unchanged — you're the first placer for that packaging regardless of whether the goods inside are new or used.
If instead you reuse already-used packaging, the duty only falls away if there's concrete proof that this specific packaging has already participated in a system. Without that proof, the duty remains — even for reused boxes.