LUCID registration for foreign sellers

Who counts as a “producer”

German packaging law follows the EU's PPWR. You are typically in scope if you:

• ship packaged goods directly to customers in Germany (classic cross-border e-commerce);
• import packaged products into Germany for resale;
• sell on Amazon.de, eBay.de, Etsy or Kaufland and ship to German customers;
• have goods packed under your own brand, even if a third party does the packing.

Company size, revenue and shipment volume make no difference. A shop shipping two parcels a month has the same registration duty as one shipping two thousand.

What LUCID is

LUCID is the public register run by the Zentrale Stelle Verpackungsregister (ZSVR). It lets authorities, and marketplaces, check that companies placing packaged goods on the German market finance its recycling. The ZSVR publishes the names of registered companies.

Registration is free. Compliance is not.

Registering in LUCID costs nothing. The cost comes from system participation: a contract with a dual system, a licensed private scheme that collects and recycles the consumer packaging you place on the market. You pay by weight and material (cardboard, paper, plastic film…), and you report your quantities.

The authorised representative (since 12 August 2026)

If your company is based abroad, has no German branch and sells directly to end users in Germany, you must appoint an authorised representative. The ZSVR is explicit: “There is no exemption from this obligation.”

• The representative takes over your EPR duties: the dual-system contract, quantity reports, any declaration of completeness, and take-back duties.
• Registering in LUCID stays your own duty, as do any later changes to your registration data.
• The representative must be based in Germany, not affiliated with your company, and appointed by a written agreement in German. You can only have one.
• You must enter the representative in LUCID before you first sell. Without it, the registration can't be completed.

Already registered under the old rules? The ZSVR asks existing registrants to update their data and add their representative. A reminder appears when you log in.

The steps

Common mistakes

• Data that doesn't match. Use exactly the same company name, address and VAT or tax number as in your marketplace account and your dual-system contract. LUCID accepts only one VAT number and one tax reference.
• Forgetting shipping packaging. Boxes, mailers, filler and tape count.
• Relying on a partner's number. If you are the producer, the registration must be in your name.
• Registering but not licensing. A LUCID number alone isn't enough for consumer packaging.