What is an EPR number and why are there several?
Each mandatory area in Germany issues its own registration number: the LUCID number for packaging, the registration number of the Umweltbundesamt (German Environment Agency) via its DIVID platform for single-use plastic products, the WEEE-Reg.-Nr. DE for electrical equipment and the Batt-Reg.-Nr. DE for batteries. Which of these your product range needs follows from product and role, not from sector or company size.
EPR number is an umbrella term taken from marketplace seller portals. The official term is registration number (Registrierungsnummer), and each one belongs to exactly one register. None of the numbers is valid EU-wide. A French or Austrian registration does not replace the German entry, and vice versa.
| Mandatory area | Number | Register | Legal basis |
|---|---|---|---|
| Packaging | LUCID number | Central Agency Packaging Register (ZSVR) | § 6 VerpackDG |
| Single-use plastic products | Umweltbundesamt registration number via DIVID | Umweltbundesamt (German Environment Agency) | § 7 EWKFondsG |
| Electrical equipment | WEEE-Reg.-Nr. DE | stiftung ear | § 6 ElektroG |
| Batteries | Batt-Reg.-Nr. DE | stiftung ear | § 5 BattDG |
In every regime, the producer role decides whether the obligation applies. In practice, the cases break down like this:
- You sell under your own brand, import yourself or sell directly to end customers in Germany: then you are probably the producer within the meaning of the respective law and need the number yourself.
- You resell goods that an upstream supplier already makes available in Germany: then that supplier's registration is usually sufficient as proof.
- Your role is unclear: then clarify it before you sell. An unclear role as the party placing goods on the market is a blocker, not a paperwork matter.
The Digital needs analysis from ClearoSystems checks each combination of product, role, sales channel and target country separately and shows which of these numbers are actually due in your case. How it works in detail is explained at the end of this article.
Which number do packaging and single-use plastics need?
Packaging and single-use plastic products have two separate registers with two separate numbers. Both obligations apply to sellers who themselves make packaging or such products available in Germany for the first time. A comparison:
| Packaging | Single-use plastic products | |
|---|---|---|
| Register | Central Agency Packaging Register (ZSVR), LUCID system | Umweltbundesamt (DIVID platform) |
| Timing | before first making available in Germany | before starting the activity |
| Scope | details per brand and on the packaging made available | details per brand and product type under Annex 1 of the EWKFondsG (Single-Use Plastics Fund Act) |
| Legal basis | § 6 VerpackDG | § 7 EWKFondsG |
The ZSVR confirms the registration, communicates the registration number and publishes registered producers with number and date in the public producer register[1]. The Umweltbundesamt follows the same pattern: it confirms the registration, communicates the number and publishes it on its website[2]. Legally, the Packaging Law Implementation Act (Verpackungsrecht-Durchführungsgesetz, VerpackDG) has applied since 12 August 2026; it replaced the former German Packaging Act (VerpackG).
Registration and system participation are two different things. The LUCID number does not replace a contract with a dual system, and vice versa. The colloquial term packaging licence refers to system participation, not to registration. The two belong together when you supply packaging subject to system participation to private end customers. How registration with the ZSVR works in detail is shown in our guide to the LUCID packaging register.
Which numbers do electrical equipment and batteries need?
Both numbers are issued by stiftung elektro-altgeräte register (stiftung ear), the German WEEE register. For electrical equipment, § 6 ElektroG, the German Electrical and Electronic Equipment Act, applies: you register per type of equipment and brand before placing equipment on the market. The application must include a guarantee, or credible evidence (Glaubhaftmachung) together with a take-back concept. Without registration, you may not offer the equipment.
For batteries, § 5 BattDG, the German battery act, applies: registration is per brand and battery category, such as portable battery or industrial battery. It is deemed granted twelve weeks after the point at which all required information has been provided, unless stiftung ear rejects it. At the applicant's request, the deemed registration must be certified in writing and a registration number issued[3].
Companies without an establishment in Germany are subject to a separate rule: they cannot register themselves but need an authorised representative based in Germany who applies for the registrations. Each producer may appoint only one authorised representative for extended producer responsibility[4].
- Electrical equipment: define type of equipment and brand, prepare the guarantee or credible evidence and the take-back concept, then apply for registration with stiftung ear.
- Batteries: state brand, battery category and chemical composition, apply for registration[5], allow for the twelve-week deemed registration.
- The two apply separately: an electrical device with a built-in battery may require both registrations, depending on the producer role.
Our guide to the WEEE number explains the WEEE registration process step by step.
Where do you state the numbers, and who checks?
Where a registration number must be stated depends on the mandatory area. For electrical equipment, § 6 ElektroG expressly requires the WEEE-Reg.-Nr. DE to be stated when offering equipment and on invoices[6]. Other registration numbers serve mainly as proof towards registers, schemes, business partners or marketplaces and do not have to appear across the board on every invoice or in every offer.
- In the offer: the WEEE-Reg.-Nr. DE belongs on every offer for electrical equipment.
- On invoices: the same number belongs on every invoice for this equipment.
- In the register: the ZSVR and the Umweltbundesamt publish registered producers with number and date; stiftung ear keeps the registers for electrical equipment and batteries.
Checks are regulated as well. Distributors may not offer packaging if the producer is not properly registered or a required system participation is missing. Fulfilment service providers may not provide certain services for producers that are not properly registered. Online platforms are subject to their own proof and checking mechanisms[7]. The ZSVR provides automated data matching for this: the digital register query (digitaler Registerabruf) returns the registration status automatically, and the public producer register serves for individual queries.
The register query has a limit: it checks only the registration status, not the system participation contract. That proof is issued by the respective scheme. Which EPR proof Amazon.de requires in detail is covered in our article on EPR proof for Amazon.de.
Which numbers does your product range actually need?
The answer follows from three questions: what do you sell, in which role, and through which channel? The following overview classifies the typical situations.
For roles, the case distinction above applies unchanged: if you bear producer responsibility, the numbers are yours to obtain; if you resell supplier goods already made available in Germany, proof via the supplier is usually sufficient, for example through the public producer register. If the assignment is unclear, the blocker described above applies.
A single product can trigger several tracks. If you are the producer of the equipment, the battery and the packaging within the meaning of the respective law, an electrical device with a built-in battery may require three separate registrations: the WEEE registration for the device, the battery registration for the battery and the packaging registration with the ZSVR. If single-use plastic products under Annex 1 of the EWKFondsG are added, such as certain packaging or bags, you also need the Umweltbundesamt registration number via DIVID.
For the meaning of the terms producer, manufacturer, importer and distributor and the mandatory areas behind them, our EPR guide provides the basics.
When your product range spans several products, channels and target countries, this assignment quickly becomes hard to keep track of. This is exactly what the Digital needs analysis from ClearoSystems is built for: it checks your products, roles, sales channels and target countries and shows you which EPR obligations and registrations apply to your company. This gives you a complete overview of your current EPR obligations, lets you spot missing registrations early and helps you avoid sales restrictions or other unpleasant surprises.
Frequently asked questions
- Is there an EPR number that is valid throughout the EU?
- No. Each member state runs its own registers and issues its own numbers. The German LUCID number, the WEEE-Reg.-Nr. DE and the Batt-Reg.-Nr. DE apply only to Germany. For other target countries, the registrations there must be checked separately.
- Can I also use the LUCID number for electrical equipment or batteries?
- No. Each regime has its own register: packaging goes through the ZSVR (LUCID), electrical equipment and batteries through stiftung ear. A product that touches several areas needs its own number for each area.
- When do I have to state the WEEE-Reg.-Nr. DE?
- Under § 6 Abs. 3 ElektroG, the registration number must be stated when offering equipment and on invoices. Marketplaces additionally require the proof in the seller portal before electrical equipment may be offered.
- How long does battery registration with stiftung ear take?
- Registration must be completed before batteries are first made available on the market. If all required information is complete and the application is not rejected, the registration is deemed granted after twelve weeks. On request, stiftung ear certifies that this deemed registration has taken effect and issues the registration number.
- Do I need my own registration if my supplier is already registered?
- Not automatically. When you resell registered supplier goods, proof via the supplier is often sufficient. Your own shipping packaging or goods under your own brand, however, create obligations of your own.
- Where can I check whether a supplier is registered?
- For packaging, use the ZSVR's public producer register; for electrical equipment, the ear directory, searchable by WEEE-Reg.-Nr. DE, brand and category. For automated checks, the ZSVR offers a digital register query.
- Do I need a separate number for single-use plastic products in addition to the LUCID number?
- Yes, if you make single-use plastic products under Annex 1 of the EWKFondsG available in Germany for the first time. You register with the Umweltbundesamt before starting the activity and receive a separate Umweltbundesamt registration number via DIVID, distinct from the LUCID number.



