PPWR, EPR and LUCID in Germany – frequently asked questions

PPWR is EU Regulation 2025/40 on packaging and packaging waste. It gradually harmonises packaging rules in the EU, including EPR and the appointment of authorised representatives.

EPR stands for extended producer responsibility. For packaging it mainly covers LUCID registration, participation in a dual system and quantity reports.

LUCID is the public packaging register of the Central Agency Packaging Register (ZSVR). After registration the company receives a LUCID number.

No. EPR is the overall term for producer obligations. LUCID registration is only one of these obligations.

Usually yes, if it makes packaged goods available on the German market for the first time. Registration must take place before sales start.

Yes, if you ship packaged products to customers in Germany. Marketplaces check the LUCID registration; system participation and quantity reports may also be required.

Typically: LUCID registration, participation in a dual system for packaging subject to system participation, quantity reports and, in certain cases, appointing an authorised representative.

An authorised representative is required if your company has no establishment in Germany and makes packaging or packaged products available for the first time in Germany directly to end users – consumers or business end users. Companies based outside the EU always need an authorised representative before the first making available in Germany. The obligation applies since 12 August 2026 (Art. 45(3) PPWR, § 5 VerpackDG).

They take over the agreed EPR obligations, support reports and documentation and act as contact in Germany. The LUCID registration itself remains the task of the company.

No. We help prepare the details and guide you step by step through the registration.

No. For packaging subject to system participation, a contract with a dual system and quantity reports are also required.

The price includes 12 months of representation as authorised representative, preparation of the power of attorney under § 5(4) VerpackDG, support with LUCID, handling of agreed EPR obligations and ongoing support. Dual system costs are charged separately.

No. It is invoiced separately because the costs depend on the type of material and the packaging weight.

An authorised representative is the appointed representative of a foreign company in Germany and takes over the EPR obligations that can be transferred by law and contract.

You send us your company details. We prepare the contract and information, support the LUCID registration and then take over the agreed tasks.

No. However, system participation can be ordered through PPWR Partner with a partner company.

Support starts after payment, signing of the contract, submission of the required details and fulfilment of the other requirements.

No. We explain the obligations clearly, help with the details and handle the tasks we take over.

Let us know about changes. We help update the details and reports accordingly.

On the applicable EPR and packaging rules in Germany and EU Regulation 2025/40. The rules are being introduced gradually.

For purely industrial packaging and transport packaging, usually not. However, LUCID registration and – for companies without an establishment in Germany that are producers there – an authorised representative are also mandatory in B2B. In addition, take-back and documentation apply and, from 1.1.2028, approval by ZSVR or participation in a producer responsibility organisation.

Usually not. Under VerpackDG, restaurants, hotels, hospitals or public authorities are sources comparable to private households – such packaging must be registered with a dual system (or a sector-specific solution). Each case should be checked individually.