VerpackDG · LUCID

LUCID number? You must appoint an authorised representative by 12 November 2026

The German VerpackDG has introduced an obligation that many foreign companies are not yet aware of. Check whether it affects your company and which deadlines you need to know.

For months there has been a flood of information about the new packaging rules. The EU regulation PPWR, a new German law, new obligations, different deadlines. No wonder many companies are not sure where they stand.

That is why we have summarised in one place what matters most for a company selling to Germany: whether you need an authorised representative and by when.

The key deadlines

  1. 12 August 2026PPWR · VerpackDG

    PPWR applies, VerpackDG enters into force. From this day, a company without a seat in Germany must have an authorised representative (§ 5(2) VerpackDG). Fines for breaches of VerpackDG also apply from this day (§ 66(1)). A new registration in LUCID cannot be completed without appointing an authorised representative.

  2. 12 November 2026LUCID · § 68(2) VerpackDG

    Final deadline for companies already registered in LUCID: update the registration data and appoint an authorised representative. After logging in to LUCID, a reminder notice appears.

  3. 31 December 2026§ 68(1) VerpackDG

    End of the transition period. Contracts with a dual system concluded before 12 August 2026 remain valid until this day at the latest.

  4. 1 January 2027VerpackDG

    Participation in the dual system must be fully adapted to the new rules. The system contract is then held by the authorised representative.

  5. 12 February 2027§ 68(17) VerpackDG

    From this day, fines also apply for breaches of PPWR rules (§ 66(2) VerpackDG).

  6. Every year by 15 May§ 10(1) VerpackDG

    Declaration of Completeness – if packaging quantities exceed the thresholds.

PPWR is one thing, VerpackDG is another

PPWR (Regulation (EU) 2025/40) is the EU packaging regulation. It has applied in all EU countries since 12 August 2026. It sets general rules – among others, that a producer without a seat in a country must have an authorised representative there (Art. 45 PPWR).

However, PPWR does not regulate how this works in practice in each country. Where to register, to whom quantities are reported, how the system works, which deadlines and fines apply – each country decides this itself.

In Germany this is done through the VerpackDG (Packaging Law Implementation Act). This German law was introduced on the basis of PPWR and replaced the previous VerpackG. VerpackDG refers to PPWR but has its own rules and its own deadlines.

PPWR (EU)

  • EU regulation
  • applies throughout the EU from 12.08.2026
  • general rules for packaging
  • obligation to have an authorised representative – Art. 45

VerpackDG (Germany)

  • German law based on PPWR
  • applies when selling to Germany
  • registration in LUCID, dual system, reports
  • own deadlines, incl. 12.11.2026 in LUCID

Quick test: do you need an authorised representative?

  • Your company has a registration number in LUCID (e.g. DE…).
  • Your company has no seat and no establishment in Germany.
  • You ship packaged products or packaging to Germany.

All three apply? Then you need an authorised representative.

Check obligationGo to test →

A company registered in LUCID is a producer under German law. If it has no seat in Germany, it can no longer fulfil the producer obligations itself. It must do so through an authorised representative based in Germany.

Typical situations in which an authorised representative is needed

01

Online shop

You run a shop abroad and ship parcels to customers in Germany. Carton, filling material and product packaging are packaging that reaches the German market.

02

Amazon, eBay, Allegro, Kaufland

You sell to German customers via a marketplace. The marketplace checks the LUCID number. Without correct registration, listings can be blocked.

03

B2B sales

You deliver goods to companies in Germany that are their end users – e.g. offices, restaurants, businesses. You have a LUCID number, so an authorised representative is needed here too.

04

Registration from VerpackG times

You registered in LUCID some years ago and have only been reporting quantities since then. Your registration must now be updated and an authorised representative appointed.

When fines apply

VerpackDG distinguishes two types of fines (§ 66 VerpackDG), each with its own start date.

Fines for breaches of VerpackDG (§ 66(1))

  • apply since 12 August 2026
  • no transition period
  • cover, among others, LUCID registration, change notifications, system participation, quantity reports and the Declaration of Completeness

Fines for breaches of PPWR rules (§ 66(2))

  • apply from 12 February 2027 (§ 68(17) VerpackDG)
  • cover, among others, packaging requirements, technical documentation, declaration of conformity and labelling

Amount of fines under § 66(3) VerpackDG (examples):

no participation in a dual systemup to €200,000
no, incorrect, incomplete or late registrationup to €100,000
no Declaration of Completenessup to €100,000
changes to registration data not reportedup to €10,000

Fines are imposed by the competent authority of the respective federal state (§ 66(4) VerpackDG).

Besides fines:

  • Packaging and packaged products may not be made available in Germany without correct registration and system participation.
  • The marketplace can block your listings.

What the authorised representative takes over and what stays with you

Under VerpackDG, the authorised representative takes over the producer obligations and fulfils them in Germany in its own name (§ 5(2) and (3) VerpackDG). In practice, the authorised representative handles the formalities: reports, documents and contact with authorities. The company continues to provide the data and is responsible for what happens to the packaging in practice.

The authorised representative

  • Confirms the appointment as authorised representative in LUCID.
  • Handles system participation (§ 7 VerpackDG) – through its own system or through the company's existing system contract.
  • Submits quantity reports to LUCID and to the dual system (§ 9 VerpackDG) – based on the data provided by the company.
  • Monitors deadlines and sends reminders in good time.
  • Handles contact with ZSVR, the dual system and the authorities on packaging matters.
  • Handles correspondence and documentation.
  • If required: coordinates the Declaration of Completeness (§ 10 VerpackDG) with the registered expert and prepares the documentation of packaging take-back (§ 39(3) VerpackDG).

You

  • Register the company in LUCID and keep its data up to date – a non-delegable obligation (§ 6 VerpackDG).
  • Appoint the authorised representative in LUCID.
  • Provide reliable data: which packaging, made of which material and how much you ship to Germany.
  • Inform about changes, e.g. new products, new packaging or B2B sales.
  • If you ship transport or B2B packaging (e.g. pallets, film, large cartons): ensure it is taken back and recycled (§ 39 VerpackDG). This is usually done through an agreement with the German recipient, who sends the packaging for recycling themselves. The authorised representative does not physically take back any packaging.
  • Bear the external costs: dual system fees, the registered expert for the Declaration of Completeness, and take-back and recycling of B2B packaging.

Summary

If your company has a LUCID number and no seat in Germany, you need an authorised representative. The obligation has applied since 12 August 2026; the deadline for updating the LUCID registration ends on 12 November 2026. Fines for breaches of VerpackDG already apply; fines for PPWR breaches are added from 12 February 2027.

Check whether you need an authorised representative

Answer a few questions in our test and check whether your company must appoint an authorised representative in LUCID.

Go to test

Questions about this article? Write to: info@ppwr-partner.com

Legal bases and sources: Regulation (EU) 2025/40 (PPWR), Art. 45; Packaging Law Implementation Act (VerpackDG), in particular § 5, § 6, § 66 and § 68; ZSVR – verpackungsregister.org; AHK debelux. As of: October 2026. This article is for information only and is not legal advice.

Important notice

This article is for information only and presents the rules in simplified form. It is not legal advice and not an assessment of the situation of any particular company. Whether a company is a producer and which obligations apply to it must be determined by the company itself; a binding assessment can be given by ZSVR or a lawyer. The rules and their interpretation may change. PPWR Partner is not a law firm and is not liable for decisions made solely on the basis of this article. If you need a binding answer, we can contact a German lawyer and ZSVR on your behalf on request – write to us.

Legal status: October 2026 (PPWR – Regulation (EU) 2025/40; VerpackDG – Packaging Law Implementation Act, BGBl. 2026 I No. 207).

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