Germany runs the oldest and strictest packaging EPR regime in Europe. Under the Verpackungsgesetz (VerpackG) any company that places packaged goods on the German market must register in the LUCID public register before the first shipment, licence its household packaging with a dual system, and report the volumes it actually placed on the market. Registration is free and public; the licence fee is negotiated with a competing dual system, so German costs are more market-driven than in single-PRO countries.
By Kevin Kai Wong, Managing Partner, gCurv Technologies
Packgine automates Germany registration tracking, component-level data collection, fee calculation and deadline management alongside every other EU and US obligation.
Register with the Zentrale Stelle Verpackungsregister and obtain a registration number. The register is public, and marketplaces and retailers are legally required to check it before listing your goods.
Household packaging must be licensed with one of the competing dual systems. Volumes licensed must match the volumes declared in LUCID; mismatches are the most common enforcement trigger.
Report actual packaging weight by material for the completed year. Producers above the statutory volume thresholds must also file an independently audited declaration (Vollständigkeitserklärung).
Transport packaging carries a take-back obligation rather than a licence fee, and service packaging filled at the point of sale can be pre-licensed by the supplier.
Germany runs its own scheme (LUCID register (ZSVR) plus a licensed dual system), but the design rules layered on top are now EU-wide. From 12 August 2026 the Packaging and Packaging Waste Regulation applies directly in every member state, covering recyclability grades, recycled content minimums, empty space limits and harmonised labelling.
Compare per-tonne rates across schemes in the EU PRO fee schedule, review every market on the EU compliance hub, and check filing dates on the compliance calendar. If you also sell in the United States or the United Kingdom, see the US EPR hub and the UK compliance hub.
Confirm which entity places goods on the German market: a local subsidiary, the exporting entity, or the marketplace where no German establishment exists.
Register in LUCID and record the registration number in your commercial systems so retailers and marketplaces can verify it.
Resolve packaging to component level, split household from non-household, and quote the licence with more than one dual system.
Reconcile LUCID declared volumes against dual system licensed volumes before submitting either.
Track the audited declaration thresholds so an audit requirement never arrives unplanned.
No. Foreign producers register directly in LUCID and licence with a dual system. What you cannot do is trade in Germany without registering, because marketplaces and retailers are obliged to check the register.
No. LUCID registration is a free public declaration with the regulator. The fee is paid separately to a dual system under a commercial licence contract, and the two sets of volumes are cross-checked.
Yes. Germany has competing dual systems, so per-tonne licence rates are negotiated. Rates for the same tonnage can vary meaningfully between providers, which makes annual re-quoting worthwhile.
The ZSVR cross-checks the two. Discrepancies lead to enquiries, retrospective licensing and administrative fines, and because the register is public, competitors can also see the mismatch.
Content reviewed by Kevin Kai Wong, Managing Partner at gCurv Technologies
See how Packgine turns your packaging data into Germany filings, fee forecasts and audit evidence.