Germany is almost always the first EU EPR market DTC brands need to tackle. It has the largest e-commerce market in the EU, the strictest enforcement, and a dedicated packaging register — LUCID — that Amazon.de and other major marketplaces actively check.
If you sell packaged products to German consumers and you're not registered in LUCID, you're non-compliant. Here's how to fix that.
LUCID (Lizenzierungs- und Überwachungs-Datenbank) is Germany's central packaging register, operated by the Zentrale Stelle Verpackungsregister (ZSVR). It's a publicly searchable database of every brand registered to place packaging on the German market.
It was created by the German Packaging Act (Verpackungsgesetz, or VerpackG), which came into force in 2019. Under the PPWR (August 2026), the underlying obligations are harmonised at EU level, but LUCID itself continues as the national registration mechanism.
Registration in LUCID is mandatory and free. You pay fees to a PRO, not to LUCID directly.
You must register in LUCID if you:
The threshold that triggers mandatory registration: placing more than 25 kg of glass or 50 kg of any other packaging material on the German market per year.
In practice, most brands reach 50 kg of cardboard or plastic within a few hundred shipments. If you're shipping to Germany at any meaningful scale, assume you're above threshold.
Your company information:
Your packaging data:
You don't need exact numbers to register. You can estimate at first and correct in your annual report.
Go to lucid.verpackungsregister.org and create an account. You'll need your company details. The interface is available in German and English.
Once registered, you'll receive a LUCID registration number. This number is your proof of compliance and must be provided to any German PRO you join, to Amazon, and to any German marketplace requiring it.
Keep this number. You'll use it constantly.
LUCID registration alone is not enough. You must also join a PRO (Producer Responsibility Organisation) — a licensed collection and recycling scheme — and sign a contract for the licensing (Lizenzierung) of your packaging.
The PRO takes your reported packaging data, calculates your fees, and uses those fees to fund Germany's packaging collection and recycling system (the Yellow Bin / Yellow Bag system).
Major PROs operating in Germany include:
| PRO | Website | Notes |
|-----|---------|-------|
| Der Grüne Punkt | gruener-punkt.de | The original German PRO; strong name recognition |
| Landbell | landbell.de | Popular with international/e-commerce brands |
| Interseroh / Interzero | interseroh.com | Large industrial and B2C coverage |
| Zentek | zentek.de | Competitive pricing for SMEs |
| Reclay | reclay.com | International focus |
| Veolia Umweltservice | veolia.de | Large-scale operator |
How to choose: For most DTC brands, price and ease of use are the main criteria. Request quotes from two or three PROs — fee rates differ, sometimes significantly for the same packaging volume. Landbell and Zentek tend to be competitive for e-commerce SMEs.
The contract includes a licensing agreement for your specific packaging types and volumes. You pay in advance for estimated annual volumes and reconcile at year-end.
After signing with a PRO, you report your packaging data in the LUCID system. This includes:
LUCID requires you to confirm participation by submitting this initial dataset. Your PRO will usually walk you through this process or handle it on your behalf.
Every year, you must submit an annual declaration (Vollständigkeitserklärung or VE) if you place more than 80,000 kg of packaging on the German market. Below that, a simplified annual report is sufficient.
For most DTC SMEs: submit your updated volume data annually in January (covering the previous calendar year). Your PRO handles the actual declaration filing.
If you shipped more than you estimated, you pay a top-up fee. If you shipped less, you receive a credit.
Amazon Germany now requires all sellers listing on Amazon.de to provide their LUCID registration number as a condition of selling. This is enforced at the account level — non-compliant sellers are delisted.
When Amazon asks: give them your LUCID number (format: DE followed by digits). If you haven't registered yet, Amazon will prompt you to do so. Don't delay — account suspension follows quickly.
Registering too late. The German Packaging Act requires registration before the first sale. If you've already been selling to Germany without LUCID, register now. The ZSVR's enforcement team actively pursues non-registered brands.
Registering but not joining a PRO. Both are required. Registration without a PRO contract is non-compliant.
Reporting only your outer box. Every piece of packaging — tape, tissue paper, labels, inner bags — needs to be reported. See What counts as packaging under EU law? for the full list.
Using the wrong material categories. Paper and cardboard are separate from plastic. A corrugated box is paper/cardboard, not mixed. A padded mailer with bubble lining is composite — report cardboard and plastic separately.
Not updating your LUCID data when you switch packaging. If you change your box size or add biodegradable filler, update your records.
Registration in LUCID: free.
PRO fees: typically €0.10–€0.50 per kg of packaging, depending on material and PRO. For an e-commerce brand shipping 2,000 orders/year to Germany with ~200g of packaging per order, that's ~400 kg total, costing €40–€200 per year in EPR fees. Not significant.
As your Germany volume grows, so do your EPR fees — but they remain a small fraction of revenue.
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