Germany · Packaging EPR · Launching
Germany EPR for sellers placing packaged goods on the market
German packaging rules are a frequent search for shops that ship to German customers. The core idea is producer responsibility: the party that first makes packaging or packaged products available on the German market has duties that can include registration, local representation, scheme participation and reporting.
This page is for orientation. It is not a determination of your legal status and not legal advice.
Who this can affect
Online merchants can be in scope when they place packaged goods on the German market, including distance sellers. The shop does not need to be incorporated in Germany or even in the EU. A seller in Spain, the UK, the US or China can still have German packaging duties if German end users are supplied directly.
Since 12 August 2026, the EU Packaging and Packaging Waste Regulation (EU) 2025/40 applies, together with Germany’s Packaging Law Implementation Act (VerpackDG), as explained by the Zentrale Stelle Verpackungsregister (ZSVR).
What foreign sellers should look at first
If you are based abroad, sell packaged products directly to end users in Germany, and do not have a German branch, the ZSVR says you must appoint an authorised representative. There is no exemption from that obligation in the ZSVR’s authorised representative guidance.
The representative must be a natural or legal person with a registered office or branch in Germany, under a written German-language agreement, and must already have a separate authorised-representative login in LUCID. Authorisation takes effect only after the ZSVR has confirmed it.
Registration in LUCID
Producers register with the LUCID Packaging Register. Registration is free. The ZSVR is clear that this registration cannot be delegated: you complete it yourself and you maintain your own master data. During registration, a company without a German branch that sells directly to German end users must enter authorised-representative details or the registration cannot be completed.
System participation and ongoing duties
LUCID registration is not the whole process. Packaging that is subject to system participation also needs a system participation agreement with one or more system operators, plus regular reporting of packaging volumes. Completeness declarations can apply in the cases set out in German packaging law. Deposit obligations can apply to certain single-use beverage packaging. EPRGo does not treat those scheme or deposit charges as part of the €199 country service fee.
Role of the local partner
The local partner is the in-country operator for work that can be delegated: scheme contracts, volume reports, completeness filings and related communication, acting as authorised representative where that appointment is required and agreed.
Role of EPRGo
EPRGo connects the shop, the destination-country setup and the local partner. It keeps the merchant’s German market in the same operating model as Spain and later countries. It does not replace LUCID’s personal registration duty, and it does not claim that German packaging law is fully automated.
FAQ
Does every foreign seller need an authorised representative in Germany?
The ZSVR states that companies based abroad that sell empty packaging or packaged products directly to end users in Germany, and that do not have a branch in Germany, must appoint an authorised representative as from 12 August 2026, when the EU Packaging and Packaging Waste Regulation and the German Packaging Law Implementation Act (VerpackDG) apply. Whether a specific shop is in that situation depends on its facts.
Can a service provider complete LUCID registration for me?
No. ZSVR guidance is explicit: registration in the LUCID Packaging Register is a personal duty. You register yourself and you keep your own registration details up to date. You then name the authorised representative in LUCID. EPRGo and a local partner can prepare the process; they cannot replace that personal registration step.
Is LUCID registration the same as paying recycling fees?
No. Registration in LUCID is free of charge. Packaging that is subject to system participation still requires a system participation agreement with one or more system operators, plus volume reporting. Those scheme costs are separate from EPRGo’s country service fee.
What does the authorised representative actually do?
According to the ZSVR, the authorised representative assumes the producer’s EPR obligations except LUCID registration. That can include concluding a system participation agreement, submitting packaging volume reports and completeness declarations, and related packaging-law duties, once the authorisation is in place and confirmed.
Is this page legal advice?
No. It summarises official public sources so merchants can understand the moving parts. It does not assess a specific business model, product range or marketplace listing.