ECOPV-EU
Sales packaging service package – without an establishment in Germany (2026)
Sales packaging service package – without an establishment in Germany (2026)
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Anyone shipping goods in sales packaging to private end consumers in Germany must register in the LUCID packaging register before the first shipment and license that packaging with a dual system. This package handles both – including the authorised representative for producers without an establishment in Germany.
What counts as packaging subject to system participation
Subject to system participation are sales and grouped packaging that typically ends up as waste at private end consumers. In distance selling this covers practically all packaging that arrives at the customer with the goods:
- shipping boxes, cushioning material, bubble wrap and adhesive tape
- product packaging: folding boxes, blisters, bags, films and labels
- grouped packaging that combines several sales units
For each of these you need a LUCID registration number and a system participation contract. Both are publicly visible – marketplaces and competitors can check them at any time.
Your authorised representative in Germany is ECOPACK GmbH
Producers without an establishment in Germany must appoint an authorised representative to assume their obligations under packaging law. That role is taken by our group company ECOPACK GmbH, which is approved for it in Germany. Your contracting party and invoicing entity is ECOPV-EU GmbH. Both companies belong to the ECOPV group; there is no outside third party in the chain.
A note on the distinction: for electrical equipment and batteries, ECOPV-EU GmbH is itself the authorised representative. Under packaging law it is ECOPACK GmbH – these are different approvals for different laws.
Scope of services
- Authorised representative under packaging law for one calendar year
- Registration in the LUCID packaging register at the Central Agency Packaging Register (ZSVR)
- System participation with a dual system
- Annual data report of the packaging volumes placed on the market, to LUCID and to the dual system
- Licensing fee for 100 kg of paper, paperboard and cardboard plus 10 kg of plastics per calendar year
- Ongoing communication with the ZSVR and the dual system
Scope and conditions
| Price | 100 € net per calendar year, plus VAT. |
|---|---|
| Included | authorised representative, LUCID registration, system participation, annual report and the licensing fee for 100 kg paper/paperboard/cardboard and 10 kg plastics |
| Not included | licensing fees for volumes above the included allowances, further material fractions and statutory VAT |
| Time to registration | 1–3 weeks |
| Reporting frequency | annually, handled by us |
Who is this package for?
- Retailers and producers without an establishment in Germany who ship to German end consumers – via their own shop, Amazon, eBay, Kaufland, OTTO or TEMU
- Companies with small to medium shipping volumes for which 100 kg of paper and 10 kg of plastics per year are sufficient
- Sellers whose listings were blocked because the LUCID number was missing
Not the right fit?
- You supply businesses rather than private end consumers – your packaging is then generally not subject to system participation, but it is subject to a separate take-back obligation: Transport packaging service package without establishment
- You have a German establishment – you then do not need an authorised representative. Contact us for a suitable offer.
- You significantly exceed the included volumes – we bill the excess according to actual volumes and tell you the rate in advance.
Frequently asked questions
Is registering with LUCID on its own enough?
No. LUCID is only the register. You additionally need a system participation contract with a dual system that finances the collection and recovery of your packaging. Both are included in this package – registration alone would not fulfil your obligations.
Does my German LUCID number also apply in other EU countries?
No. Each member state runs its own register. Since 12 August 2026, Amazon checks packaging registration in every EU country in which you sell or store. The services for the other countries are listed under Amazon EPR-mandatory countries.
What happens if I am not registered?
Packaging law provides for a ban on distribution: unregistered packaging may not be placed on the market. Marketplaces are obliged to check the LUCID number and block listings without a valid entry. Fines and competition-law warnings from competitors come on top.
How are volumes reported?
Once a year you tell us the packaging volumes placed on the German market by material fraction. We handle the report to LUCID and to the dual system. The two reports must match – discrepancies are the most common trigger for an audit.
I did not report in previous years. What now?
Volumes for completed years can be reported retrospectively. That is a separate procedure: Retrospective reporting of packaging volumes for completed years.
Related
- All packaging services (VerpackDG / PPWR)
- Transport packaging – without an establishment in Germany
- Amazon EPR-mandatory countries from 12 August 2026
- Price overview of all EPR services
Questions first? +49 6196 5835357
By completing your order you confirm that you have read and accept our Terms and Conditions, and you authorise us to perform all associated services on your behalf.