Swiss producers register themselves in LUCID
A Swiss company that delivers packaging or packaged products directly to end users in Germany is a producer under German law. It must register in the LUCID packaging register, free of charge, before first making them available in Germany. This registration must be carried out by the Swiss company itself; it cannot be delegated to an external service provider or to the German authorised representative (§ 5(1) sentence 2 VerpackDG).[1]
The legal basis is the Packaging Law Implementation Act (VerpackDG) of 13 July 2026.[2] It entered into force on 12 August 2026 and replaced the previous German Packaging Act. The Central Agency Packaging Register (ZSVR) keeps the register and is the competent authority for the producer register under Article 44 of Regulation (EU) 2025/40 (§ 6(6) VerpackDG). Registration takes place online through the ZSVR's electronic system and is free of charge. Costs arise later through system participation: for packaging subject to system participation, a system participation contract must be concluded in addition to the registration.[3]
- Timing: the registration must be completed before packaging or packaged products are first made available in Germany (§ 6(1) VerpackDG).[4]
- Authorised representative: if you deliver directly to German end users without an establishment of your own in Germany, you must, since 12 August 2026, appoint an authorised representative for extended producer responsibility before first making goods available (§ 5(2) VerpackDG). The representative's mandate covers the obligations under the VerpackDG, with the exception of registration.[1]
Whether you are a producer in Germany and which EPR obligations follow from that depends on product, role, sales channel and target country. The ClearoSystems needs analysis checks these combinations for your company and shows which registration, authorised representative and other EPR obligations apply.
When is your Swiss company a producer in Germany?
For cross-border deliveries, producer status follows from the priority of the domestic market: if a company based abroad delivers directly to an end user in Germany, that is, to consumers or to commercial end users, the foreign company itself is the producer. If the packaging bears your name or your brand, you may also be the manufacturer of the packaging within the meaning of the PPWR. Your EPR producer role for Germany, by contrast, results from delivering the packaged products directly from Switzerland to end users in Germany. The manufacturer role and the producer role must therefore be determined separately. If, on the other hand, sales run through an intermediary that makes the packaging available in Germany, producer status may lie with that intermediary. This distinction is the decisive check before you create a LUCID account.[5]
| Check | What to check |
|---|---|
| Legal name and tax number | The Swiss legal name and the national or European tax number, as they will later have to be entered in the LUCID registration process[4] |
| Target group in Germany | Whether you deliver directly to private or commercial end users, without an intermediary in Germany[5] |
| Brand names | All brands under which the packaging is first made available in Germany; if there is no brand name, the company name applies[3] |
| Existing LUCID entry | Whether the ZSVR's public list of producers already contains an entry for the same legal entity[4] |
Before registering, check whether a LUCID entry already exists for your company, for example from earlier deliveries or via a sister company. What counts is the legal entity, not the shop name. The ZSVR publishes registered producers with name, address, brand names and registration number in the public register, so an existing entry can be checked there (§ 6(4) VerpackDG).[4] Use the same master data as in the system participation contract or in your cooperation with a marketplace; several tax numbers for one company are not possible in the register.[3]
The LUCID registration applies to Germany only. Obligations in other countries arise in addition and must be checked separately for each target country, as we describe in our article on EPR obligations in other EU countries.
Authorised representative and LUCID registration: how to proceed
Once producer status is clear, the process follows. The ZSVR requires the authorised representative to be stated directly in the registration process; without this entry, a foreign company without an establishment cannot complete the registration.[3]
- Prepare the LUCID fields: name, address and contact details including the European or national tax number, a natural person authorised to represent the company, national identification number and email address, brand names and the breakdown of packaging types (§ 6(2) VerpackDG).[4]
- Appoint the authorised representative: you may appoint only one authorised representative for EPR. The agreement must be concluded in writing in German and signed by both parties by hand or with a qualified electronic signature.[3]
- Complete the registration: the authorised representative is named as part of the registration and requires confirmation by the ZSVR (§ 5(5) VerpackDG). The ZSVR confirms the registration and communicates the registration number (§ 6(3) VerpackDG).[4]
- Keep records: keep the contract with the authorised representative and the registration confirmation separately and in a traceable way.[1]
One point deserves particular attention: since 12 August 2026, producers based abroad that are already registered are notified of a missing authorised representative after logging in and must add this information. Changes to registration data, such as a change of authorised representative, must be reported to the ZSVR without delay (§ 6(1) VerpackDG).[5]
The LUCID registration is only one possible EPR obligation. If, for example, you also sell electrical equipment or batteries to Germany or deliver to other countries, further registrations and authorised representatives may be required. With the ClearoSystems needs analysis, you get a complete overview of which EPR obligations apply to your products, roles, sales channels and target countries. This way you see in good time what you need to do and avoid missing registrations or other compliance gaps.
Frequently asked questions
- How does a Swiss company obtain a LUCID registration?
- Registration takes place online through the portal of the Central Agency Packaging Register (ZSVR), which also covers the appointment of the authorised representative: the authorised representative must be stated directly in the initial registration, and without this information a foreign company cannot complete the registration. Confirmation by the ZSVR and notification of the registration number complete the process.
- Can I use LUCID without a German company of my own?
- Yes. Swiss companies can and must register in LUCID without a German establishment, using their own company data (including Swiss legal form and tax number). However, if sales go directly to German end users, a German authorised representative must be appointed.
- Is the appointment of an authorised representative the same as my LUCID registration?
- No, these are two separate obligations. With the LUCID registration, you identify yourself to the ZSVR as a producer. The appointment of an authorised representative is a separate written agreement with an authorised representative established in Germany. The representative takes over the EPR obligations in its own name, for example system participation, quantity reports and, where applicable, other producer obligations. The LUCID registration itself remains with the Swiss company.
