Packaging EPR · Germany
Packaging EPR in Germany — a plain guide for small cross-border sellers
Does packaging EPR in Germany apply to you?
If you send packaged products to customers in Germany — a box, filler, tape, a label — Germany treats you as a "producer" of that packaging, and you have to be registered before you sell. This is true even for a one-person webshop shipping a handful of parcels. The good news: for a small seller the process is well-defined, the government register itself is free, and the yearly cost is usually modest. This guide explains the route in plain terms.
Who counts as the "producer" in Germany?
Under the German packaging rules, the producer is the business that first puts filled packaging on the German market — typically you, the seller shipping to German consumers. You are responsible for registering your packaging and making sure it is covered by a collection system ("dual system"). Selling through a marketplace does not remove this obligation for your own packaging.
Where you register: the authority and the PRO
Two things have to happen, and they are separate:
- Register in LUCID, the public packaging register run by the Central Agency Packaging Register (ZSVR). Registration and reporting in LUCID cost nothing. You (the producer) must create this registration yourself — it can't simply be handed off.
- Join a "dual system" (the PRO) — an approved scheme that organises the collection and recycling of your packaging. Examples include Reclay Activate and Green Dot / VerpackGO. You buy participation sized to the packaging weight you forecast, by material.
Authority / register: https://www.verpackungsregister.org/en/
Do you need an authorised representative in Germany?
Yes — from 12 August 2026, a producer without a branch in Germany that sells packaged products directly to end users in Germany must appoint an authorised representative (AR): a party based in Germany that takes over your packaging obligations there. This applies whether your company is based in another EU country (Finland, Sweden, Poland, the Netherlands…) or outside the EU. According to the ZSVR, the agreement must be written in German and signed by hand or with a qualified electronic signature, you can appoint only one AR, the AR needs its own LUCID login and ID and must confirm the appointment, and you must enter it in LUCID before you first sell. The AR then handles your dual-system contract, quantity reports and declaration of completeness, but the LUCID registration itself stays your own duty. Appointing an AR is a routine step — we arrange it as part of onboarding. For the wider picture, see our authorised representative guide.
AR reference: https://www.verpackungsregister.org/en/knowledge-bases/authorising-a-representative
Status 24 October 2026: the authorised representative requirement still applies. The European Parliament (20 October) and the Council of the EU (21 October) have voted for different partial suspensions for some EU-based sellers and must now agree one text, so nothing has changed yet. Neither version covers companies based outside the EU, and neither changes LUCID registration, dual-system participation or reporting. See who would qualify and where it stands.
What it costs in Germany (indicative)
Here is how the cost breaks down — and what is already inside our price:
- The register itself: €0. LUCID registration and reporting are free.
- Dual-system + AR fees (indicative). As a market benchmark, one low-cost provider advertises an AR at around €170/year plus a dual-system base of about €35/year, plus material fees. Example 2026 material rates quoted by that provider (per kg): paper/cardboard ~€0.20, plastic ~€1.07, glass ~€0.075, aluminium ~€1.01, steel ~€0.99. As a worked example, ~20 kg of cardboard a year came to about €209/year plus VAT, including the AR and base fee. These are provider examples, not fixed prices — the real figure depends on your packaging. In our model the representative, base fee and material fees are the actual cost, itemised on your invoice separately from our service fee, at cost.
- Pakkausvastuu's price. Our service fee for Germany is €230 a year (€350 in the first year), plus the LUCID registration, authorised representative and dual-system membership's actual cost, typically around €50 a year for a small seller — both are always itemised separately on the invoice, at cost. The typical total is about €280 a year (about €400 in the first year). The service fee also covers the yearly reconciliation and deadline tracking. Selling into five or more countries takes 10% off the service fee, ten or more takes 15% off.
Fees, thresholds and deadlines for Germany change yearly. The figures here are indicative — we confirm the current numbers live before you approve anything.
Selling into more markets too? Get a country-by-country quote →
Reporting and deadlines
For a small seller, expect at least an annual quantity reconciliation: the packaging weight you actually placed on the market is reported to your dual system and matched in LUCID. We keep your registration number, dual-system agreement, AR mandate, tariff version and next deadline in one place so nothing is missed.
How Pakkausvastuu handles Germany for you
Send us your packaging details once. We build your packaging record (material and weight per component), create and guide the LUCID registration, appoint and connect your authorised representative, buy the right dual-system participation, and file the yearly reconciliation — then track the deadline so you don't have to. You get one all-in price a year, with the scheme's and representative's share itemised on the invoice.
Germany packaging EPR: frequently asked questions
Do I need to register in LUCID to sell in Germany?
Yes. If you put filled packaging on the German market, you must be registered in the LUCID packaging register before selling, and your packaging must be covered by a dual system. Registration in LUCID is free.
Do I need an authorised representative in Germany?
Yes, for now. Since 12 August 2026, a producer without a German branch that sells directly to end users in Germany must appoint an authorised representative with a LUCID ID, whether it is based in another EU country or outside the EU. We arrange it. EU proposals to suspend this for some small EU-based sellers are not law yet (status 24 October 2026).
How much does packaging EPR in Germany cost for a small seller?
Our service fee for Germany is €230 a year (€350 in the first year), plus the LUCID registration, authorised representative and dual-system membership's actual cost, typically around €50 a year for a small seller — both are always itemised separately on the invoice, at cost. The typical total is about €280 a year (about €400 in the first year). We confirm exact figures in the free obligation check.
Can Pakkausvastuu register me in Germany if I'm based in Finland?
Yes. This is exactly what we do — including appointing the German authorised representative you now need.
This guide is general information for small exporters, not legal advice. Your exact obligations depend on your packaging and sales — get a quote and we'll confirm them for you.
Get your country-by-country quote
Selling to more markets too? See our France and Sweden guides, or send your packaging once and get one clear quote covering every country you sell into. Get a country-by-country quote →
Already covered in Finland through Sumi or Rinki? Read what your Finnish PRO covers and what it doesn't once you start exporting.