In force since 12 August 2026
Since 12 August 2026: no representative, no distribution in Germany.
Foreign companies that count as a producer in Germany and have no establishment there must appoint a Germany-based authorised representative and assign them in LUCID. The duty has applied since 12 August 2026. This page says who is covered, who is not, what the five steps are, and how we check your entry free of charge.
Who is covered
Not everyone needs a representative.
You sell packaged goods directly to end customers in Germany, through your own shop or a marketplace, and have no establishment here. You count as the producer.
If you sell to resellers, importers or chains established in Germany, the German buyer generally counts as the producer under domestic priority. The duty is theirs, not yours.
If you are established in Germany you need no representative; you fulfil the duties yourself. A German company or branch replaces the mandate.
What has to be done
Five steps, one of them cannot be delegated.
Registration stays with you
Registration in the LUCID packaging register is a strictly personal duty of the obligated company. No representative may do it in your place.
Choose a representative
They must be established in Germany, external to your company, and offer this service. Your own employee becomes a processor, not the representative.
Written mandate
The mandate is given in writing and submitted as part of the registration. A verbal arrangement is not enough.
Assignment via LUCID
The representative is named in the packaging register and assigned to your registration.
Confirmation by the representative
The representative must confirm the appointment in LUCID. Each producer may appoint only one representative for extended producer responsibility.
If you do not
The goods may then not be placed on the market.
Packaging may only be placed on the market if the registration duties are met. Placing it on the market without proper registration is an administrative offence, with fines of up to 100,000 euros. In practice most companies notice the problem at the marketplace first, when the listing is blocked.
This is live, not upcoming. If your LUCID entry has no representative assigned, the exposure exists today: marketplaces block listings first, the agency's fine follows. The fix is fast — once the mandate is signed, assignment and confirmation in LUCID take days.
Our own count
5,527 Turkish companies in the register. 62 have a representative.
On 25 July 2026 we read the public producer register of the Central Agency Packaging Register in full for producers established in Türkiye: 5,655 entries, 5,527 of them active. Sixty-two had an authorised representative, spread across nine German providers. The number is not an accusation but a measure: the duty is now in force and most foreign producers still have nobody assigned. The register is public for every country — we run the same lookup for yours.
Our role
We are the German side.
We check the public register for you: whether you are registered and whether a representative is assigned. Then we settle the prior question: whom do you sell to in Germany? That answer decides whether the duty is yours at all.
We set the mandate up: the written authorisation, assignment and confirmation in LUCID, and the dual-system contract in our own name. METSE+ GmbH takes the representative role from Munich and remains your single point of contact.
Volume reports, deadlines, correspondence with the agency and the dual system: in English with you, in German with the authorities. If you want to go further, the other route is your own German company — then the mandate falls away entirely.
Send us your company name. We check the register and tell you whether the duty applies to you, usually within one working day. Not legal advice: a register lookup and a clear next step.
Get a free checkFAQ
Answered briefly
01Can the representative also do my registration?
02I only sell to German retailers. Does this affect me?
03Can I appoint more than one representative?
04Am I in breach if I have no representative yet?
05Does this also cover electrical goods and batteries?
This page gives general information as of 2 September 2026 and is not legal or tax advice. A binding assessment of your case is made by a licensed lawyer or tax adviser; we coordinate that.
Direct contact
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