Shipping goods to Germany?
Update your LUCID registration by 12 November.
Germany's new packaging act VerpackDG took effect on 12 August 2026, the day the EU Packaging Regulation (PPWR) began to apply. Companies that supply end users in Germany directly must be registered in the LUCID register themselves and, for household packaging, have a dual system contract. Companies with no establishment in Germany also need an authorised representative with a registered office or branch there. Producers registered under the previous act must update their registration, including the representative, by 12 November 2026.
An independent overview by Pravano MG s.r.o. based on the text of the VerpackDG and the guidance of the German packaging register (ZSVR). We are neither the ZSVR nor an authorised representative, and we do not fulfil German obligations for companies.
It depends on who you supply in Germany.
Yes: You supply end users in Germany directly
You ship from your online shop, through Amazon or another marketplace, or from a fulfilment warehouse directly to consumers, or to businesses that use the goods themselves and do not resell them. You are then an obliged producer in Germany (the German act uses the term Hersteller) with your own obligations there. According to the German packaging register ZSVR, you are at least the manufacturer and the producer of your shipping packaging.
Probably not: You only sell to a German trader
A German wholesaler or retailer buys the goods and resells them. The obligations then usually lie with that company as the first business in the German supply chain. Check who you actually supply, though: as soon as you also ship directly to customers, the obligations are yours.
Four obligations you have in Germany.
LUCID registration
You must be registered in the LUCID producer register, run by the ZSVR (Zentrale Stelle Verpackungsregister), before your first delivery, and you must register yourself. Registration cannot be delegated to anyone, not even to an authorised representative (Section 6(1), Section 5(1) and (2) VerpackDG). It includes, among other things, your brand names and packaging types. The register is public.
Authorised representative (Bevollmächtigter)
A company with no establishment in Germany must appoint an authorised representative for extended producer responsibility before its first delivery: only one, by a written power of attorney in German, notified as part of the registration (Section 5(2), (4) and (5)). According to the ZSVR, the representative can be a person with a registered office or branch in Germany who is not affiliated with your company. The ZSVR itself cannot act as one.
Dual system participation
For packaging that typically ends up in private households or comparable places such as restaurants, public offices or hospitals after use, you need a contract with a dual system (Section 3(6) and (7), Section 7(1)). What counts is where packaging of that type usually ends up, not where your particular shipment goes. According to the ZSVR, an online shop's shipping packaging always falls into this group. Participation agreed before 12 August 2026 is valid until 31 December 2026 at the latest (Section 68(1)).
Packaging for businesses
Packaging that does not end up in households, such as the transport packaging of machines delivered to a factory, must be taken back and passed on for reuse or recovery; the place and costs can be agreed with the business customer by contract (Section 39). Without authorisation from the ZSVR you may supply it until 31 December 2027 at the latest (Section 19, Section 68(9)).
Two deadlines remain this year.
- 12 Aug 2026The new German Packaging Law Implementation Act (VerpackDG) took effect and the EU Packaging Regulation (PPWR) began to apply. The previous Packaging Act (VerpackG) was repealed.
- 12 Sep 2026passedProducers obliged to register only under the new act had to register in LUCID by this date (Section 68(2)).
- 12 Nov 2026Producers registered under the previous act must update their registration data by this date, including the authorised representative (Section 68(2), Section 6(1)). The ZSVR already prompts producers to add a representative when they log in to LUCID.
- 31 Dec 2026Dual system participation agreed before 12 August 2026 ends. From 1 January 2027 you need a contract under the new act (Section 68(1)).
- 31 Dec 2027Last day on which packaging outside the dual system may be supplied without authorisation from the ZSVR (Section 19, Section 68(9)).
No registration, no sales in Germany
A producer that is not properly registered in LUCID may not supply packaging or packaged goods in Germany, and it may not supply household packaging without dual system participation either (Section 13(1) VerpackDG). Traders may not resell them (Section 13(3)), fulfilment service providers may not handle them and online platforms check the registration (Section 13(4)). The register is public, so every customer and competitor can check it.
What to do before the end of the year.
- List who you supply in Germany: end users directly (consumers and businesses that use the goods themselves), or traders who resell them.
- If you supply directly, check your registration in the public LUCID register. If you should have registered and have not, do it now: without registration you may not sell in Germany.
- Appoint an authorised representative by a written power of attorney in German and add them in LUCID. If you were registered before, make the changes by 12 November 2026.
- For household packaging (for an online shop, always the shipping packaging), make sure a dual system contract under the new act applies from 1 January 2027. Without an establishment in Germany, your authorised representative concludes it in its own name (Section 5(2) and (3)).
- Keep your other markets in mind: the obligations in your home country and in every other EU country you ship to apply alongside the German ones.
Selling into the Czech Republic or Slovakia too?
Those markets have their own packaging rules alongside the PPWR. Our free packaging check tells you what applies to you in the Czech Republic and Slovakia, including authorised representatives under the PPWR. No sign-up, no commitment.
What companies ask most often.
We sell into Germany through Amazon. Do we have to register ourselves?
Yes, if you sell on the marketplace yourself as a seller and the goods go directly to consumers in Germany. You are then the obliged producer and nobody else can register in LUCID for you (Section 5(1) and Section 6 VerpackDG). If the marketplace or another German trader buys the goods and resells them, the obligations usually lie with that company. Fulfilment service providers may not handle a producer's packaged products without proper registration, and online platforms require proof of registration under Section 13(4) and EU rules; the ZSVR provides them with an automated check. Without registration, your listings risk being removed from the marketplace.
We already pay fees to a packaging scheme in our home country. Does that cover Germany?
No. A home-country scheme covers packaging placed on that country's market. For packaging you supply to Germany you need LUCID registration and, for packaging ending up in households, a contract with a German dual system (Section 7(1) VerpackDG). Both apply in parallel.
What if we should have registered and have not?
Register now. The 12 September 2026 deadline for newly obliged producers has passed, and under Section 13(1) VerpackDG a producer without proper registration may not supply packaging in Germany, and it may not supply household packaging without dual system participation either. The same applies to traders who would resell your goods (Section 13(3)).
Who can be the authorised representative?
According to the ZSVR, any natural or legal person with a registered office or branch in Germany that is not affiliated with your company; the ZSVR itself cannot be one. The representative needs their own LUCID access and confirms the appointment. You may have only one, and the power of attorney must be written and in German (Section 5(4)). The representative takes over your obligations except registration (Section 5(2) and (3)). Pravano is not an authorised representative.
Isn't the EU scrapping the authorised representative requirement?
Not yet. The Commission proposed suspending the obligation for companies established in the EU until 2035 (COM(2025) 982). On 5 October 2026 the European Parliament's environment committee backed narrower relief limited to micro and small enterprises, on 20 October 2026 the plenary adopted Parliament's position by a large majority (616 in favour, 9 against, 39 abstentions), and on 21 October 2026 the Council adopted its negotiating mandate (relief only for EU-established producers that make less than 1 tonne of packaging available for the first time in that Member State per calendar year, until 1 January 2032); the final text still has to be agreed between the two institutions. The German act builds on the EU obligation (Section 5(2)). Until a change takes effect, the obligation applies.
We deliver machines to German factories. Does the dual system apply to us?
Usually not, since the transport packaging of machines does not end up in households. If you also send parcels with parts ordered remotely (online, by e-mail or phone), the ZSVR treats this as shipping packaging, which always requires dual system participation. The transport packaging of machines must be taken back and passed on for reuse or recovery; the place and costs can be agreed with the customer by contract (Section 39 VerpackDG). You may supply such packaging without authorisation from the ZSVR until 31 December 2027; after that you need authorisation or must transfer the obligations to an approved organisation for extended producer responsibility (Section 19, Section 68(9)). You still need LUCID registration.
Related: The EU Packaging Regulation (PPWR) · EKO-KOM fee calculator · Free packaging check.
Sources: German Packaging Law Implementation Act (VerpackDG), BGBl. 2026 I Nr. 207, Sections 3, 5, 6, 7, 13, 19, 39 and 68; Zentrale Stelle Verpackungsregister pages what changed on 12 August 2026, mail order and online retail and authorised representative; Regulation (EU) 2025/40, Article 3(1)(15) and Article 45; Commission proposal COM(2025) 982, procedure 2025/0395(COD). Checked on 16 October 2026. General information, not legal advice.