At a glance

ItemAs of 15 October 2026
WhatLUCID packaging register of the ZSVR, the German producer register under Art. 44 PPWR (EU Packaging Regulation)[2][16]
Legal basis§ 6 VerpackDG of 13 July 2026 (BGBl. 2026 I No. 207) and Art. 44 Regulation (EU) 2025/40[2][20]
In forceVerpackDG and PPWR have applied since 12 August 2026; registrations under the old German Packaging Act (Verpackungsgesetz, VerpackG) remain valid[15]
WhoProducers within the meaning of the PPWR that make packaging available in Germany for the first time, regardless of where the company is based[21]
CostsRegistration and data reports at the ZSVR are free of charge[7]
ResultRegistration number: DE followed by 13 digits, issued by administrative decision[6]
No registered office in GermanyAn authorised representative for extended producer responsibility is mandatory for direct delivery to end users[3][4]
Without registrationSales ban (§ 13 VerpackDG); administrative offence under § 66(1) no. 1 VerpackDG[13][14]
Next deadline12 November 2026 for changes to existing registrations (§ 68(2) VerpackDG)[15]

What LUCID is and what it is not

LUCID is a public register, not a contract and not a licence. The ZSVR is the competent authority for the producer register that every EU member state must keep under Art. 44 PPWR[2][16]. The register shows who makes packaging available in Germany, under which brands and with which types of packaging[8].

LUCID does not govern the financing of collection and recycling. For that, producers conclude a contract with a compliance scheme, which many people call the "packaging licence". These obligations are often confused:

ObligationWhatWhereWho fulfils itCosts
RegistrationEntry as a producer with master data, packaging types and brandsLUCID[2]only the producer itself[3]free of charge[7]
System participationContract for the collection and recycling of the packagingone or more compliance schemes of your choiceproducer or its authorised representative[4]fee based on material type and weight[18]
Data reportQuantities from the scheme contract, transferred 1:1LUCID[11]producer or its authorised representative[4]free of charge[7]
Declaration of completeness (Vollständigkeitserklärung)Audited annual declaration covering all packaging quantitiesLUCID[12]only above the quantity thresholdsfree of charge at the ZSVR; audit by a registered auditor required[12]

How system participation, prices and quantity reconciliation work is explained in the guide to the packaging licence.

Who must register

The producer must register. The PPWR separates two roles. The manufacturer makes packaging or has it made under its own name or trademark; it is responsible for its conformity. The producer is the company that first makes the packaging available in the country where it becomes waste; it bears registration, financing and reporting[5][16].

In Germany, the domestic priority rule (Inlandsvorrang) applies: the producer is the first company in the German supply chain. If a company abroad delivers directly to end users in Germany, it is itself the producer[5]. End users are consumers and business customers who do not resell the goods[10]. § 6 VerpackDG sets no minimum quantity or turnover threshold[2]. Registration also covers packaging that is not subject to system participation, such as transport packaging in B2B business[8].

Your situationRegistration in LUCIDWhy
Online shop in Germany ships goods in its own shipping boxesyesShipping packaging is subject to system participation without exception; whoever assembles it is manufacturer and producer[10]
Retailer has products made under its own brand by a contract manufactureryesBrand priority: the client is manufacturer and producer[17]
Retailer imports packaged goods from a non-EU countryyesThe importer established in Germany is the first to make them available[17]
Retailer buys packaged third-party brands from a supplier in another EU countryyesIt is a distributor and the first to make them available in Germany[17]
Retailer buys third-party brands from a German wholesalerno for the product packaging, yes for its own shipping packagingFor the product packaging, the wholesaler is the producer; shipping material is the retailer's own packaging[5][10]
Company from NL, AT or CH delivers directly to customers in Germanyyes, plus authorised representativeA foreign direct shipper is the producer; without a German establishment, § 5(2) VerpackDG applies[3][5]
Company from NL, AT or CH supplies only a German retailer that resells the goodsas a rule noThe German retailer starts the domestic supply chain[5]
Micro-enterprise has own-brand packaging made by a German supplierno for this packagingIf the supplier is in the same member state, the supplier is manufacturer and producer (Art. 3(1)(13)(b) PPWR)[16][17]

If you store goods with a fulfilment service provider or sell through a marketplace, you remain the producer of your goods. Who is the manufacturer of the shipping packaging depends on who assembles it; the ZSVR refers to the individual case here[10].

What changed on 12 August 2026

Registration, system participation and data reporting remain. What has changed is who bears them[5]. Four points affect LUCID directly:

  • Roles: manufacturer and producer are determined under the PPWR. For own brands and imports, producer responsibility therefore lies with the retailer[5][21].
  • Authorised representative: foreign direct shippers without a German establishment must appoint an authorised representative; until now this was voluntary[5].
  • Existing registrations: if you were registered under the German Packaging Act, you count as registered. Changes must be made by 12 November 2026; the ZSVR requires you to check and update your details without delay[1][15].
  • New references: registration is now set out in § 6 VerpackDG, the appointment of an authorised representative in § 5 VerpackDG[2][3].

Which details you need

LUCID asks for the details listed in § 6(2) VerpackDG[2]. Have the following ready before you start:

  • Name, address, telephone number and email address of the legal entity, meaning the registered company, not the shop name[2].
  • VAT identification number or tax number, plus a national identification number. LUCID accepts only one tax number per company; use the same one as in your scheme contract and on the marketplace[1].
  • A natural person authorised to represent the company, such as the managing director or an authorised signatory (Prokura); for legal entities, this person must come from your own company[2][7].
  • All brand names that are recognisable on your packaging. If there is no brand, enter your company name[1].
  • The packaging types: subject to system participation, not subject to system participation, or single-use beverage packaging subject to a deposit[1][2].
  • Without a German establishment: name, address and LUCID ID of your authorised representative, plus the written appointment in German[2][3][4].

Registration step by step

Registration runs entirely online at lucid.verpackungsregister.org and costs nothing[1][7].

  • Clarify your role: check for each type of packaging whether you are the producer. The ZSVR provides guidance on distinguishing manufacturer from producer[17].
  • Create a login: start as "Hersteller" (producer) with company name, responsible person and editor. Confirm the activation link sent by email within 24 hours[6].
  • Enter master data: you then have seven days. Without a German establishment, select your authorised representative in the "Bevollmächtigter" (authorised representative) section; without this entry, the registration cannot be completed[1][6].
  • Tick the packaging types: subject to system participation or not. If you use only service packaging that has already been licensed upstream, choose the option provided for this[1].
  • Enter brand names: all brands under which you make packaging available in Germany for the first time[1].
  • Submit the declarations and send: a few minutes later you receive the ZSVR's decision with your registration number. The registration takes effect with this decision[6].
  • Continue with the scheme and reporting: complete system participation and report the quantities in LUCID before the first delivery goes out[18].

Enter a person from your company who maintains the data as an editor (Bearbeiter), not as an authorised representative[4].

The LUCID number

The LUCID number is your registration number in the packaging register: DE followed by 13 digits[6]. It appears in the ZSVR's decision, in the LUCID dashboard and in the public producer register[6][7]. It stays the same when your master data change[8].

If a marketplace asks for an "EPR number for packaging" in Germany, it means the LUCID number[6]. Before allowing sales, online platforms must obtain the registration in the consumer's country, including the number, and a self-certification on producer responsibility (Art. 45(4) PPWR)[16]. Which proof Amazon requires is shown in our article on EPR proof for Amazon.de.

The number applies only to packaging in Germany. For electrical equipment, the single-use plastics fund (Einwegkunststofffonds) or other countries, you need separate registrations; each member state keeps its own packaging register[6]. If a marketplace rejects your number, clarify this directly with the marketplace; the ZSVR has no information on it[6].

Viewing the register and checking status

The producer register is public and free of charge[8][16]. At oeffentliche-register.verpackungsregister.org you can find the registration number, registration date, address, tax number, packaging types, brands and, where applicable, the authorised representative[8]. The register is updated once a day; changes usually appear the following day[22].

The register does not show whether a company participates in a compliance scheme. That proof is the scheme's participation confirmation[8][9]. Marketplaces, fulfilment service providers, dropshipping sellers and other resellers can check the status automatically through the register query (Registerabruf), an XML file with a separate login activated by the ZSVR[9].

These checks have a legal basis. Distributors may not offer packaging from producers that are not properly registered. Fulfilment service providers may not store, pack or ship for them (§ 13(3) and (4) VerpackDG)[13].

After registration: reports

Transfer every quantity report to your compliance scheme into LUCID without delay and 1:1, under the same registration number[11][18]. If you made less than 10 tonnes of packaging subject to system participation available in the previous year, you report once a year by 1 June instead[11]. From 80 tonnes of glass, 50 tonnes of paper, paperboard and cardboard or 30 tonnes of the other materials in the previous year, an audited declaration of completeness is also due by 15 May[12]. The guide to the packaging licence describes the process in detail.

Deadlines and timeline

DateWhatStatus
11 February 2025PPWR (Regulation (EU) 2025/40) enters into force[16]adopted
13 July 2026VerpackDG signed into law, BGBl. 2026 I No. 207[20]adopted
12 August 2026PPWR applies; VerpackDG replaces the German Packaging Act; authorised representative mandatory[5][16]in force
12 September 2026Deadline for producers that only became subject to registration under the new law[15]expired
12 November 2026Changes to existing registrations[15]pending
31 December 2026Scheme contracts under the old law end at the latest; last opportunity for the initial planned-quantity report for 2027 in LUCID[15][18]pending
15 May 2027Declaration of completeness for 2026, if thresholds are reached[12]annual
1 June 2027Year-end quantity report for 2026; annual report below 10 tonnes[11][18]annual
31 December 2027End of the transition period: producers of packaging not subject to system participation need an approval from the ZSVR[5][15]adopted
openEU proposal COM(2025) 982: suspend the authorised representative obligation for EU producers until 1 January 2035[19]proposal, not adopted

Costs

Registration costs nothing. Data reports and all related activities of the ZSVR are also free of charge; the ZSVR is financed by the compliance schemes[7]. Costs arise elsewhere: for system participation based on material type and weight, for an authorised representative according to their offer, and for the audit of a declaration of completeness[4][7][12].

Consequences of missing registration

Without proper registration, you may not make packaging available in Germany. The ban applies along the supply chain:

SituationConsequenceProvision
Producer not registered or not properly registeredSales ban for the producer and for retailers that offer its goods[13]§ 13(1) and (3) VerpackDG
Goods are held by a fulfilment service providerIt may not store, pack or ship for this producer[13]§ 13(4) VerpackDG
Sales through an online platformWithout a registration number and self-certification, the platform may not allow the offer[10][16]Art. 45(4) PPWR
Registration, notification of changes, system participation, data report or declaration of completeness missingAdministrative offence; the competent authority is the federal state authority where the company is based, and the ZSVR reports suspected cases[14][21]§ 66(1) nos. 1, 2, 3, 6, 7 and 8 VerpackDG

If a step is missing, complete it before you continue delivering: registration first, then system participation and data report[18].

Common mistakes

  • A service provider registers for you. Solution: a person from your company submits the application; third parties may prepare data but not submit it[3][7].
  • Shop name instead of the legal entity, or a different tax number than on the marketplace. Solution: registered company name and the same tax number everywhere[1].
  • Brands are missing. Solution: enter all brands on the packaging; add new brands without delay[1][2].
  • Different registration number in the scheme contract. Solution: compare the numbers; if it is missing from the scheme's quantity confirmation, request it from the scheme[18].
  • Registered office abroad without an authorised representative. Solution: appoint and name an authorised representative; existing registrations show this at login[4].
  • Registration ended while goods are still being sold. Solution: end it only on a genuine market exit; an ended registration cannot be reactivated[22].

For companies from the Netherlands, Austria and Switzerland

A registration in your home country does not cover Germany. The LUCID number applies only here, and conversely you need a separate registration in every country where you deliver as a producer[6][16]. For Austria, our article on selling to Austria shows what a German licence does not cover there.

If you deliver directly to end users without an establishment in Germany, the following applies to you:

  • You register yourself in LUCID; this remains a strictly personal obligation[4].
  • Before that, you appoint exactly one authorised representative with registered office or establishment in Germany, in writing and in German, signed by hand or with a qualified electronic signature[3][4].
  • The authorised representative takes on system participation, quantity reports, the declaration of completeness and take-back obligations in its own name[3][4]. The ZSVR does not publish a list of authorised representatives[4].
  • The obligation follows from Art. 45(3) PPWR and § 5(2) VerpackDG. It applies to companies from the Netherlands or Austria just as it does to companies from Switzerland[3][10][16].

What the costs of an authorised representative depend on is shown in our article on the EPR authorised representative. It is unclear whether a warehouse at a German fulfilment service provider counts as an establishment; neither the VerpackDG nor the ZSVR defines this[3][4]. Clarify this case before the first delivery. The European Commission has proposed suspending the authorised representative obligation for EU producers until 2035; the proposal has not been adopted and does not change the obligation in force. It provides no suspension for companies from non-EU countries such as Switzerland[23]. How LUCID fits into the rest of the law is explained in the guides to the German Packaging Act and VerpackDG and to the PPWR. In a digital needs analysis for companies whose home market is the Netherlands, Austria or Switzerland, ClearoSystems clarifies which obligations apply per product, role, sales channel and country, and then supports registration, reporting and the appointment of an authorised representative.

Status and changes

As of 16 October 2026. On that day we checked §§ 3, 5, 6, 7, 9, 10, 13, 66 and 68 VerpackDG in the version on gesetze-im-internet.de, Art. 3, 44, 45 and 71 of Regulation (EU) 2025/40, the ZSVR's registration, help and topic pages, and the procedural status of the EU proposal COM(2025) 982 in the European Parliament's Legislative Observatory[2][16][19]. Changes: 15 October 2026, first version; 16 October 2026, technical clarifications after expert review (title). Translated from the German version of 16 October 2026.

Frequently asked questions

Do I have to register if I only ship a few parcels a month?
Yes. There is no minimum quantity for registration; it must be completed before the first parcel to a customer in Germany. With small quantities, only the data report is simplified: below 10 tonnes in the previous year, one report per year by 1 June is sufficient.
Can my tax adviser or my compliance scheme submit the registration for me?
No. The company submits the application itself; in a GmbH, for example, a managing director, an authorised signatory (Prokurist) or an employee from your own company who holds power of attorney. A tax adviser or compliance scheme can prepare the details. In groups of companies, one person can be responsible for several companies but needs a separate email address for each company.
I only sell to businesses. Do I still need LUCID?
As a rule, yes, if you are the first to make the packaging available in Germany. Registration also applies to packaging that is not subject to system participation. Whether system participation is also needed depends on where the packaging typically becomes waste; shipping boxes are subject to system participation even when sent to business customers.
Do I have to register again after 12 August 2026?
No. Registrations under the German Packaging Act remain valid. However, check your role, brands and packaging types against the new rules and enter changes by 12 November 2026 at the latest; if your company is based abroad, also enter your authorised representative.
Our company has changed its name or been sold. Does the LUCID number remain?
That depends on whether the registered company continues to exist. If only the company name or legal form changes, the registration continues and you update the master data. If another company becomes the producer, for example after a takeover or merger, a new registration with a new number is required, which you also notify to your compliance scheme.
We have been selling without registration so far. What do we do now?
Register immediately, complete system participation and report the quantities. Until then, you and your retailers may not make the packaging available in Germany. The registration only takes effect with the ZSVR's decision and does not apply retroactively; how to deal with quantities already sold should be clarified case by case.

Sources

  1. [1]ZSVR: So registrieren Sie sich im Verpackungsregister LUCID (accessed 15 Oct 2026)
  2. [2]§ 6 VerpackDG: Registrierung; zuständige Behörde (accessed 15 Oct 2026)
  3. [3]§ 5 VerpackDG: Beauftragung Dritter und Bevollmächtigung (accessed 15 Oct 2026)
  4. [4]ZSVR: Alles auf einen Blick: die Bevollmächtigung (accessed 15 Oct 2026)
  5. [5]ZSVR: PPWR und VerpackDG – was sich für Sie ändert (accessed 15 Oct 2026)
  6. [6]ZSVR: Hilfe – Registrierung in LUCID (accessed 15 Oct 2026)
  7. [7]ZSVR: Fragen zur Registrierung (accessed 15 Oct 2026)
  8. [8]ZSVR: Die Öffentlichen Register (accessed 15 Oct 2026)
  9. [9]ZSVR: Registrierungsstatus Ihrer Geschäftspartner digital prüfen (accessed 15 Oct 2026)
  10. [10]ZSVR: Versand- und Onlinehandel – was ändert sich durch die PPWR? (accessed 15 Oct 2026)
  11. [11]§ 9 VerpackDG: Datenmeldungen (accessed 15 Oct 2026)
  12. [12]ZSVR: Pflicht zur Vollständigkeitserklärung bei hohen Verpackungsmengen (accessed 15 Oct 2026)
  13. [13]§ 13 VerpackDG: Verbot bestimmter Tätigkeiten in Bezug auf Verpackungen (accessed 15 Oct 2026)
  14. [14]§ 66 VerpackDG: Bußgeldvorschriften (accessed 15 Oct 2026)
  15. [15]§ 68 VerpackDG: Übergangsvorschriften (accessed 15 Oct 2026)
  16. [16]Verordnung (EU) 2025/40 über Verpackungen und Verpackungsabfälle (PPWR), Art. 3, 44, 45, 71 (accessed 15 Oct 2026)
  17. [17]ZSVR: Wer ist Erzeuger, wer Hersteller? (accessed 15 Oct 2026)
  18. [18]ZSVR: Datenmeldung (accessed 15 Oct 2026)
  19. [19]Europäisches Parlament, Legislative Observatory: Verfahren 2025/0395(COD), Omnibus VIII (accessed 15 Oct 2026)
  20. [20]Verpackungsrecht-Durchführungsgesetz (VerpackDG), Gesamtausgabe mit Vollzitat (accessed 15 Oct 2026)
  21. [21]ZSVR: Verpackungsrechtliche Pflichten erfüllt? So fallen Verstöße auf (accessed 15 Oct 2026)
  22. [22]ZSVR: So ändern Sie Ihre Registrierung im Verpackungsregister LUCID (accessed 15 Oct 2026)
  23. [23]Europäisches Parlament, Legislative Observatory: Zusammenfassung des Vorschlags COM(2025) 982 (accessed 15 Oct 2026)