Verpackungsgesetz (VerpackG)
Germany EPR — Verpackungsgesetz (VerpackG). The regulatory authority is Zentrale Stelle Verpackungsregister (ZSVR), operating through the LUCID Register system.
All producers, importers, online sellers, and fulfillment service providers placing packaged goods on the Germany market must register with a PRO and fulfill EPR obligations. Non-Germany sellers must appoint an Authorized Representative.
Germany operates a competitive dual system for packaging. Producers must register in the LUCID Packaging Register (operated by ZSVR — Zentrale Stelle Verpackungsregister) and contract with one of the licensed dual systems:
Central registry: lucid.verpackungsregister.org (ZSVR)
Reporting & Deadlines: Annual by May 15 (completeness declaration for >80,000 kg). Packaging data must be reported by material type and weight. Reports are submitted through LUCID / ZSVR.
Maximum Fine: €200,000. Non-compliance with Germany EPR regulations can result in fines, marketplace listing deactivation, and legal consequences. Amazon and other marketplaces may independently verify compliance and suspend non-compliant sellers.
LUCID registration number required in Amazon Seller Central. Without it, listings are deactivated.
If you sell on Amazon, eBay, or other marketplaces and ship products to Germany, you are responsible for EPR compliance in this market. The "pay on behalf" model is ending — marketplaces will no longer handle this for you. Register now to avoid listing deactivation.
Germany requires a two-part registration: first in the LUCID packaging register, then with a licensed dual system. Here's exactly how it works.
Register in LUCID
Go to lucid.verpackungsregister.org and create an account. You'll need your company name, address, VAT number (USt-IdNr.), and the brand names you use to sell packaged goods in Germany. Registration is free and usually takes 1–3 business days to be confirmed.
Contract with a Dual System
Choose one of the licensed dual systems (Der Grüne Punkt, Interseroh+, BellandVision, Reclay, Zentek, Landbell, PreZero Dual, Veolia, or Noventiz). Report your estimated annual packaging volumes by material type: paper/cardboard, plastics, glass, metals, beverage cartons, and composites. Costs depend on your volumes and material types.
Link LUCID and Your Dual System
Enter your dual system contract details into LUCID. The ZSVR cross-checks your reported volumes in LUCID against those reported to your dual system. If there's a mismatch, you'll receive a warning — and potentially a fine. This "data reconciliation" happens automatically and is one of the most common compliance issues for sellers.
Upload Your LUCID Number to Amazon
Go to Amazon Seller Central → Account Info → EPR Compliance. Enter your LUCID registration number for Germany (packaging category). Without a valid LUCID number, Amazon will deactivate your listings on amazon.de. This enforcement has been active since July 2022 — Germany was the first EU country to enforce marketplace EPR compliance.
File Annual Reports
Each year, report your actual packaging volumes to both LUCID and your dual system. The data must match. If your total packaging volume exceeds 80,000 kg per year, you must also submit a completeness declaration (Vollständigkeitserklärung) by May 15, verified by a registered auditor.
Don't want to deal with this yourself?
Order EPR Registration Online →The Packaging and Packaging Waste Regulation (EU) 2025/40 applies from August 12, 2026. It runs on top of Germany's existing VerpackG — not replacing it. Here's what this means for sellers:
VerpackG becomes VerpackDG
Germany is updating its national packaging law to align with PPWR. The new version — informally called VerpackDG (Verpackungsdurchführungsgesetz) — keeps LUCID registration and the dual system structure but adds new EU-wide requirements.
🔄 Eco-modulated Fees
Packaging that is harder to recycle will cost more. Easy-to-recycle mono-material packaging gets reduced fees.
🌍 EU Authorized Representative
Non-EU producers must appoint an Authorized Representative in every EU country where they sell — including Germany. Even EU sellers may need one in countries where they have no establishment.
♻️ Recyclability by 2030
All packaging on the EU market must meet harmonized recyclability criteria by 2030. Non-recyclable packaging faces higher fees now and potential market bans later.
📋 Recycled Content Targets
Plastic packaging must contain minimum recycled content: 10% by 2030 for contact-sensitive packaging, 35% for other plastics. Higher thresholds in 2040.
If your company manufactures products outside the EU and exports them to the European market, PPWR requires you to prove that your packaging meets EU sustainability standards — before your goods cross the border. ekoniq prepares the complete PPWR compliance package so you can export with confidence.
What we deliver (15–18 documents):
✓ Full Technical Documentation (Annex VII, Module A)
✓ EU Declaration of Conformity (Annex VIII)
✓ Recyclability assessment of all packaging
✓ Substance restriction verification (PFAS, heavy metals)
✓ Recycled content declaration
✓ Packaging minimisation statement
✓ Labeling guidance (material codes, sorting pictograms, QR)
✓ Accredited lab testing coordination (SGS, Intertek, Bureau Veritas)
✓ EPR registration in target EU countries
✓ Authorised Representative appointment (Article 45)
1. Registering in LUCID but forgetting the dual system
LUCID registration alone is not compliance. You must also contract with a dual system and report your packaging volumes there. ZSVR checks both — if you have a LUCID registration but no active dual system contract, you'll be flagged.
2. Volume mismatch between LUCID and dual system
The volumes you report to LUCID must exactly match the volumes you report to your dual system. Many sellers estimate differently or forget to update one when they update the other. This triggers automatic warnings from ZSVR.
3. Not registering all brand names
In LUCID, you must register every brand name under which you sell packaged products in Germany. If you sell under multiple brands and only register one, the others are non-compliant — even if they're all owned by the same company.
4. Thinking FBA means Amazon handles EPR
Using Fulfillment by Amazon (FBA) does not transfer your EPR obligations to Amazon. You are still the producer. You must register in LUCID, contract with a dual system, and provide your registration number to Amazon. FBA only handles logistics — not regulatory compliance.
5. Ignoring WEEE and battery EPR
If you sell electronics or products with batteries, packaging EPR is not enough. You also need WEEE registration (through stiftung EAR) and/or battery registration under the new EU Battery Regulation 2023/1542. Many Amazon sellers don't realize they need all three.
LUCID registration is free. The costs come from your dual system contract, which depends on your annual packaging volumes and material types. Contact us for a free quote.
LUCID registration is typically confirmed within 1–3 business days. Contracting with a dual system takes an additional 2–5 business days. With ekoniq, the entire process is usually completed within one week.
Yes. Using FBA does not exempt you from EPR. You are still the producer placing packaged goods on the German market. Amazon requires your LUCID number in Seller Central and will deactivate listings without it.
LUCID is the central packaging register — a government database where you register as a producer. A dual system (like Der Grüne Punkt or Interseroh+) is a private recycling operator you contract with to actually handle your packaging waste obligations. You need both: registration in LUCID and a contract with a dual system.
Yes, non-EU sellers can register directly in LUCID. However, under the PPWR (from August 2026), non-EU producers must also appoint an Authorized Representative established in Germany. ekoniq can serve as your Authorized Representative and handle the entire compliance process.
You must report all packaging by material type: glass, paper/cardboard/carton, ferrous metals (steel/tin), aluminum, plastics, beverage cartons (composite), and other composites. Each material is reported separately by weight in kilograms. This includes your product packaging, shipping boxes, fill material (bubble wrap, air pillows), tape, and labels.
Yes — from August 12, 2026 (PPWR deadline), you need packaging EPR registration in every EU country where you sell. Germany was the first to enforce this, but France, Austria, Spain, Italy and others now also require registration. ekoniq handles EPR compliance across all 27 EU countries.
ekoniq handles your complete EPR registration and compliance. We take care of registration, reporting, and ongoing obligations so you can focus on selling.
Get Free EPR Consultation