Sales packaging service package – Germany (2026)

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 under § 5 VerpackDG.

The Packaging Implementation Act (VerpackDG) has applied since 12 August 2026 and replaced the Packaging Act (VerpackG) on the same day. In parallel, the EU Packaging Regulation PPWR (EU) 2025/40 applies directly.

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.

§ 5 VerpackDG: appointing third parties and authorised representatives

§ 5 VerpackDG implements Art. 45(3) PPWR. Four points from it affect you directly:

• The authorised representative counts as the producer. With regard to the obligations to be performed it “counts as the producer within the meaning of this Act” and fulfils them in its own name – not merely as a messenger.
• Only one authorised representative per producer. “Each producer may appoint only one authorised representative for extended producer responsibility.” If you have already named one, it must be replaced first.
• Written power of attorney in German, signed by both parties by hand or with a qualified electronic signature. We provide the text.
• Effective only once confirmed in LUCID. The appointment takes effect when the authorised representative confirms it in the packaging register – not when you sign it.

That role is taken by our group company ECOPACK GmbH. Your contracting party and invoicing entity is ECOPV-EU GmbH. Both 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 – different approvals for different laws.

Scope of services

• Authorised representative under § 5 VerpackDG for one calendar year, including the power-of-attorney text and confirmation in LUCID
• Registration in the LUCID packaging register at the Central Agency Packaging Register (ZSVR)
• System participation with a dual system – this covers the take-back and recovery duties under § 39 VerpackDG
• Annual data report of the 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

§ 10 VerpackDG: when a declaration of completeness falls due

If in a calendar year you exceed any one of these volumes, you additionally need an audited declaration of completeness:

• glass: 80 t
• paper, paperboard, cardboard: 50 t
• lightweight packaging (plastics, composites, metal) combined: 30 t

The deadline is 15 May for the previous year; if it falls on a weekend the deadline moves. Only auditors registered with the ZSVR may carry out the audit – experts, auditors, tax advisers or sworn accountants. You book that service separately: Declaration of completeness under § 10 VerpackDG.

For the 2026 reference year the transitional rule of the change of law applies: form under VerpackDG, content under VerpackG.

§ 66 VerpackDG: what happens without registration

Unregistered packaging may not be placed on the market – in practice a ban on distribution. § 66 VerpackDG makes infringements an administrative offence subject to fines. On top of that:

• Marketplaces are obliged to check the LUCID number and block listings without a valid entry.
• Competition-law warnings from competitors, with legal and court costs.

Who is this package for?

• Retailers and producers 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

Whether you have an establishment in Germany does not change the price. Without one, the authorised representative under § 5 VerpackDG is mandatory; with one, we carry out the same steps for you without you needing the appointment.

Not the right fit?

• You significantly exceed the included volumes – we bill the excess according to actual volumes and tell you the rate in advance.
• You need a declaration of completeness under § 10 VerpackDG.
• You need to correct a report already submitted: Correct annual report.

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 and thereby fulfils § 39 VerpackDG. Both are included in this package – registration alone would not fulfil your obligations.

I already have another authorised representative. Can I appoint you as well?

No. § 5 VerpackDG allows only one authorised representative per producer. The existing one must be replaced first; tell us when booking and we will coordinate the switch.

When does the appointment take effect?

Only once the authorised representative has confirmed it in LUCID – not when you sign. The power of attorney must also be in German and signed by both parties by hand or with a qualified electronic signature.

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.

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)
• Amazon EPR-mandatory countries from 12 August 2026
• Price overview of all EPR services

Questions first? +49 6196 5835357

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