We ship small volumes from China. Do we still need this?

Yes. There is currently no volume exemption for foreign direct sellers in Germany; small volumes only change how often you report and whether a declaration of completeness is required. The small-producer exemption under discussion at EU level has not been adopted.

We registered in LUCID years ago. What now?

The registration stays valid, but you must add a German authorised representative in LUCID by 12 November 2026 and make sure your system contract continues under the new law.

Can the authorised representative register in LUCID for us?

No. Registration is personal to the producer; the representative handles system participation, reporting and declarations afterwards. We can guide you through registration live so the details match the mandate.

How much are take-back fees?

They depend on material and weight. For small direct sellers they are typically tens to a few hundred euros a year, plus the representative’s service fee.

PPWR and German Packaging Law 2026: VerpackDG, LUCID Registration, Authorised Representative

What changed in August 2026

The Packaging Act (VerpackG) ceased to apply on 11 August 2026 and was replaced by the Verpackungsrecht-Durchführungsgesetz (VerpackDG), which applies from 12 August 2026.
On the same day the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) began to apply. The VerpackDG is Germany’s implementing law for it.
Producers without a branch in Germany that supply German end users directly must appoint a German authorised representative (VerpackDG §5(2)).
Producers with small volumes report data once a year instead of continuously.

Does this apply to an online store outside Germany?

Yes. Under PPWR Article 3(1)(15), an operator established in another member state or outside the EU that supplies packaged products directly to end users in a member state is a producer in that member state. A store shipping from China, the UK or the US to German consumers is a producer under German packaging law.

The rules cover sales packaging, outer packaging and the shipping boxes and fillers you send to consumers (VerpackDG §3(6)).

The five obligations

Obligation	Who does it	Details
Register in LUCID	The seller	Register with the Zentrale Stelle Verpackungsregister (ZSVR) in LUCID before first supply. Free. Registration must be done by the producer personally and cannot be delegated to ordinary third parties (§5(1)).
Appoint an authorised representative	Written mandate from the seller	A written mandate in German, one representative only, confirmed by the representative in LUCID. New registrations cannot be submitted without one (§5(2)).
Join a take-back system	Representative on your behalf	A contract with a dual system, priced by packaging material and weight (§7).
Data reports	Representative on your behalf	Report system-participating packaging to the ZSVR; under 10 tonnes in the previous year, report once a year by 1 June (§9).
Declaration of completeness	Representative on your behalf	Only above thresholds: 80 t glass, 50 t paper, 30 t other materials combined; due 15 May (§10).

Within the mandate the representative is treated as the producer and fulfils system participation, reporting and declarations in its own name (§5(3)–(4)). LUCID registration itself stays with the seller.

Deadlines

Registrations made under the old law remain valid, but changes such as adding the representative must be completed by 12 November 2026. Existing accounts see a prompt to add one when they log in.
New obligated producers were due to register by 12 September 2026. If you have not registered, do it now.
System contracts signed under the old law can run until 31 December 2026 at the latest.

Fines

Breach	Maximum fine
No take-back system participation	€200,000
No registration, no declaration of completeness	€100,000
Reporting and other breaches	€10,000

Packaged products from unregistered producers may not be sold in Germany, and marketplaces and fulfilment providers ask for the registration number.

PPWR in other EU countries

The PPWR applies directly across the EU. Three points matter for direct sellers:

Register as a producer in each member state you supply directly (Article 44) and appoint an EPR authorised representative in each of those states (Article 45(3)). Until new national registers exist, existing systems such as LUCID in Germany and SYDEREP in France continue.
If you ship from an EU warehouse or 3PL, you must give the fulfilment provider your registration numbers and a self-declaration of compliance, and it may suspend service if they are missing (Article 45(7)–(8)).
Packaging must carry a type or batch identifier and the manufacturer’s name and postal address, which may be provided through a QR code (Article 15). Harmonised material labels come later (Article 12).

In December 2025 the European Commission proposed, in an omnibus simplification package, to suspend the EPR authorised representative requirement. A Council document from September 2026 shows member states now discussing only an exemption for small producers, with the threshold and its application to non-EU producers unresolved. Until something is adopted, the requirement applies.

PPWR and the German packaging law in 2026: LUCID registration and the authorised representative