Obligation to register in the LUCID packaging register
The Packaging Act has been in effect since January 1, 2019, and imposes new regulations on retailers, manufacturers, and importers. In Germany, the dual system ensures the efficient collection and recycling of retail packaging, and registration with the LUCID Packaging Register ensures that all manufacturers are properly registered and participate in this system. This mandatory participation in the system is intended to put an end to the distribution of unauthorized packaging and to promote recycling and environmental protection.
Why do you have to be registered?
The Packaging Act requires that packaging manufacturers register with LUCID and participate in one or more circular economy systems to protect the environment and ensure the responsible use of resources. The Packaging Register is publicly accessible, allowing end consumers, retailers, and government agencies alike to easily verify whether all regulations have been complied with. The register thus ensures greater transparency and facilitates the enforcement of penalties for violations. It also contributes to self-regulation of the market by enabling the use of tools such as warning letters. Non-compliant free-riders are thereby identified and their numbers minimized. In addition, the LUCID Packaging Registry provides legal certainty by specifying who is authorized to trade in packaged products based on their registration. Without registering your products, you may not place the packaging or packaged goods on the market. Violations of this prohibition may result in fines.
Who is required to register?
Manufacturers, distributors, and importers—that is, all entities placing packaging on the market that is subject to the packaging recycling system —must register with the LUCID Packaging Registry. Packaging subject to the system participation requirement is packaging intended to be filled with goods for sale to the end consumer. You are considered a manufacturer under the Packaging Act if you fill packaging with products for the first time and trade in these products for commercial purposes, as are distributors and importers who trade in products that are not yet known on the German market. The country of manufacture is irrelevant in this context.
If you import a packaged product from abroad into Germany, you—as the distributor—are also considered a manufacturer and are subject to the registration requirement in the LUCID Packaging Register. This applies even if you intend to sell the product inside the packaging in Germany, rather than the packaging itself. The sales method (online or in-store) is just as irrelevant to this requirement as the stage of distribution. The only exceptions to this rule are service packaging for prepared foods, carry bags, and disposable cups for coffee or similar beverages. In these cases, the responsibility lies not with the retailer but with the preceding stage of distribution.
You need an authorized representative as defined by the Packaging Act (VerpackG) if you are a foreign company without a German branch and wish to import packaging or packaged goods into Germany and sell them in your own name. For the duration of the authorization, the authorized representative assumes all obligations arising for your company under the Packaging Act, such as entering into a contract with a system participation partner, taking back transport packaging, reporting quantities, and more. However, you must still register with LUCID on your own, even if you appoint an authorized representative. Please note that you must enter into the contract with your authorized representative prior to registration.
Was ist für die Registrierung erforderlich?
To register, you must submit your master data to the Central Packaging Register Foundation (ZSVR). This includes your company’s name, an email address, the person in charge, and a designated employee. You will then receive a registration number and be entered into the manufacturer registry. You will need this registration number to enter into a system participation agreement, which you agreed to do when you registered.
The ZSVR is a agency under private law that fulfills the role of the Central Body provided for in §§ 24-30 VerpackG. The function of the agency and its statutes have been recognized by the German Federal Environment Agency.
LUCID-Registrierung durch CERTIFY
At CERTIFY, we offer a comprehensive range of services for retailers, manufacturers, and distributors —throughout Germany and internationally. You, too, can benefit from our experience, legal expertise, and industry knowledge. We’ll assist you with LUCID registration, handle your registration in the dual system, and ensure that everything is conducted in a legally compliant and transparent manner.
Another key aspect of our services is assisting you with the accurate reporting of your packaging volumes to ensure that all legal requirements are met. We help you ensure that the packaging volumes in circulation are properly licensed.
Get in touch with us! We will be happy to prepare an individual offer for you.
FAQ: Important questions about LUCID registration
All packaging typically generated by private end consumers (B2C) is subject to licensing. This includes:
- Retail Packaging (Product Packaging)
- Outer packaging (e.g., bulk wrap)
- Shipping packaging from online retailers, including packing material, tape, and labels
Transport packaging does not need to be registered with a dual system; therefore, it is not subject to system participation requirements, but it is subject to take-back obligations and must still be reported to LUCID. The distinction lies not in the product itself, but in the end user—anyone who resells goods without outer packaging to private customers may unwittingly fall under the B2C obligation.
Like Amazon, Otto Market verifies the LUCID number (VerpackG) and the WEEE number issued by Stiftung ear. Proof of these numbers is required during the merchant onboarding process—listings will not be approved without valid numbers.
Otto is currently focused primarily on the German market, so international requirements typically do not apply. For batteries, the BattG registration number is also verified.
Kaufland verifies compliance with LUCID and WEEE during the retailer onboarding process and in annual audits. Any non-compliance results in listing suspensions at the category level. Kaufland operates its own marketplaces in Germany, the Czech Republic, Poland, and Slovakia—separate EPR certificates are required for each of these countries.