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Selling to Germany? Do you have a packaging obligation?

Every company shipping packaged goods to Germany can fall under the German Packaging Act (VerpackG): LUCID registration, licence fees, two reports a year and, since 12 August 2026, an authorised representative. Three questions show where you stand and the calculator shows your yearly kilograms.

METSE+ GmbH Munich — fabric swatches and documents on the desk
VERPACKG · LUCIDIN FORCE SINCE 12.08.2026

Updated for the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40): EPR provisions apply from 12 August 2026.

Three steps

See where you stand in three minutes.

01 · THREE QUESTIONS

Is the obligation yours or your buyer's?

Q1Who is your customer in Germany?
Q2Do you have a registered company or branch in Germany?
Q3Do you sell through marketplaces? (Amazon.de, eBay, Etsy, Zalando, Otto)

02 · KILOGRAM CALCULATOR

Your yearly kilograms and estimated licence fee.

Average packaging per shipment, grams

example values, weigh your own packaging

YEARLY PACKAGING, KG

Cardboard / paper
125.0
Plastic, film, tape
20.0
Other
0.0
TOTAL
145.0

You are under 10 tonnes: simplified regime, one consolidated report a year (by 1 June).

Estimated yearly licence fee: ~70–80 €

2026 market band (cardboard ≈ 0.40–0.45 €/kg, plastics ≈ 1.00–1.20 €/kg, minimum 39–79 €/year); varies by scheme and material detail. LUCID registration is free. Other materials are not included.

verpackungslizenz24.de 2026 price table · Reclay May 2026 example · Lizenzero / PreZero minimum fees

03 · WRITE TO US

You do the LUCID registration. Write to us for the rest.

LUCID registration is free and made in your own name; we do not take it on. For a company in Germany, a German website or marketplace content, message us on WhatsApp; the kilograms you calculated are added to the message.

What you need to do

If the obligation is yours, there are four tasks.

LUCID registration
FREE · YOURSELF

Registration in the LUCID portal of the central register ZSVR. Free, personal, cannot be delegated; be wary of any provider offering to “register for you”.

Licence contract
DUAL SCHEME

A contract with a recycling scheme (Lizenzero, Reclay, Landbell and others), priced per kilogram. Selling without one is prohibited; fines up to 200,000 €.

Two reports a year
31 DECEMBER · 1 JUNE

Planned kilograms for the coming year by 31 December, actual kilograms for the past year by 1 June; first to the scheme, then to LUCID, both figures identical.

Authorised representative
SINCE 12 AUGUST 2026

A producer without an establishment in Germany that sells to end consumers must appoint an authorised representative (Bevollmächtigter) based in Germany. METSE+ does not offer this service; if your own German company makes the sales, no representative is needed.

Calendar

Two dates, the same every year.

01

31 December

Planned kilograms for the coming year; if missed, an intra-year report catches up.

02

1 June

Actual kilograms of the past year; for producers under 10 tonnes this is the single consolidated report of the year.

03

When something changes

New packaging type, a jump in volume, a change of address or representative: first the scheme, then LUCID.

PPWR 2026

What changes for sellers outside Germany

One EU regulation
EPR, NOW EU-WIDE

EPR duties are set out EU-wide in a single regulation instead of one national law per country. Germany keeps LUCID as its register, so your registration and your two yearly reports still run through it.

Authorised representative
PPWR ART. 45

A producer not established in the member state where the packaging is first placed on the market needs an authorised representative in that state. For a seller shipping into Germany without a German entity, that is a German mandate.

GPSR responsible person
A DIFFERENT ROLE

The responsible person under the product safety regulation (Regulation (EU) 2023/988) is a separate mandate covering the product, not the packaging. One company may hold both, but the packaging mandate has to say so in writing.

Your own German entity
THE ROUTE WITHOUT A MANDATE

Placing the goods on the market through a German company of your own removes the representative requirement altogether: the German entity is the producer. How a GmbH is set up →

Frequently asked

Five questions, five short answers.

01Can someone else register me in LUCID?
No. Registration is personal and stays with the obligated company; it is free (verpackungsregister.org). A representative or service provider only takes over the obligations beyond registration.
02I only sell to German companies. Do I need a licence?
In most cases no: the German buyer who imports the goods and places them on the German market first counts as the “producer”, so LUCID and the licence are their job. Transport packaging between businesses is also exempt from scheme participation. Put in writing who the importer is (Incoterms); if you import under DDP, the obligation comes back to you.
03What changes if I am under 10 tonnes?
Simplified regime: one consolidated report a year, due by 1 June. You still need the licence contract; only the reporting burden is lighter.
04What is the authorised representative, and is it mandatory?
Since 12 August 2026 it is mandatory for producers without an establishment in Germany that sell directly to end consumers. The representative takes on the producer's obligations in their own name, which is why the service is expensive and rare. METSE+ does not act as a representative. If your own company founded in Germany makes the sales, no representative is needed.
05What happens if I miss a report?
Missing or late reports carry fines of up to 10,000 €, selling without a licence up to 200,000 €, and marketplaces close listings without a LUCID number. There is a catch-up report for missed deadlines, so act quickly.

Next step

Selling more in Germany, not just staying compliant.

Most EU sellers we hear from do not need a German company; they need a German front office: a returns address in Germany, customer service in German, marketplace listings and a website that read like a German brand, and someone who keeps the LUCID calendar. METSE+ GmbH does this from Munich.

Ask about the Germany front officeCompany formation in Germany

This page is for information only and is not legal advice. Sources: Verpackungsgesetz / VerpackDG, ZSVR (verpackungsregister.org), 2026 dual-scheme price lists.

Direct contact

Call us or write to us.

A thirty-minute first conversation, free. English, German or Turkish.

METSE+ GmbH

Ottobrunner Straße 1
81737 München · Germany

Phone · WhatsApp
+49 152 09008126