EPR and LUCID in Germany – what to sort out before you sell

Updated: 2 November 2026 · GrowNow team

What EPR is and why Germany enforces it so closely

EPR, extended producer responsibility, means that a company placing packaging, electronics or batteries on the market finances their collection and recycling. Each country runs its own register – the Polish BDO number works only in Poland. Germany was the first to require marketplaces to check sellers’ registrations, which is why a listing without a valid EPR number on Amazon.de simply won’t appear.

EPR is national in the UK too: a German LUCID registration does not cover selling into the UK, which runs its own packaging EPR scheme.

LUCID and the dual system after 12 August 2026

From 12 August 2026, Regulation (EU) 2025/40 on packaging (PPWR) applies across the EU. In Germany, the previous VerpackG act has been replaced by the implementing act VerpackDG. The provisions are numbered differently, but the core obligations remain the same:

• Registration in LUCID, run by the Zentrale Stelle Verpackungsregister (ZSVR), before goods are first made available. Registration is free and cannot be delegated to a third party.
• Participation in a dual system (a licence agreement) for packaging that reaches end users, including shipping boxes. The fee depends on the weight and type of material.
• Reporting to LUCID the same quantities you declare to the dual system. Below 10 tonnes a year, once a year is enough, by 1 June.
• A declaration of completeness (Vollständigkeitserklärung) only above the thresholds, e.g. 30 tonnes of plastics or 50 tonnes of paper a year, filed by 15 May.

What changed for companies outside Germany

The most important change for Polish companies: a producer without a registered office in Germany must, before the first delivery, appoint a single authorised representative (Bevollmächtigter) with a written mandate in German and name them in LUCID. The registration itself remains the producer’s responsibility. Existing registrations remain valid, but changes – including adding the representative – must be made by 12 November 2026. Contracts with dual systems concluded under the old rules run until 31 December 2026 at the latest.

The PPWR also changes the definition of a producer. For distance sales to consumers in another country, the packaging producer in that country is the company that ships the parcels. An EPR registration is therefore needed in every EU country the goods go to, not just in Germany. Work is under way at EU level to suspend the representative requirement for small producers from the EU – check the current status before launching.

Electronics and batteries: stiftung ear

Packaging isn’t everything. Electrical and electronic equipment falls under the ElektroG act, and batteries – including those built into devices – under the BattDG act, which replaced BattG in October 2025. Both registrations are run by stiftung ear (Elektro-Altgeräte Register). A company without a registered office in Germany registers through an authorised representative based in Germany. From 1 January 2026, battery producers must also belong to an approved producer responsibility organisation (OfH) separately for each battery category. Registrations not updated by 15 January 2026 have lost their validity.

How marketplaces check EPR

Online marketplaces in Germany must check that a seller has the required registrations. Amazon requires the LUCID number in the account settings and, for electronics and batteries, the stiftung ear numbers too – without them it blocks listings. VerpackDG goes further: distributors may not offer packaging from unregistered producers, and fulfilment service providers may not serve such companies. Fines reach €100,000 for failing to register and €200,000 for not participating in a dual system, on top of a sales ban.

How it works with GrowNow

GrowNow buys the goods on a B2B invoice and is the seller in the market. EPR registrations and packaging fees in the countries where we sell are on our side. From the manufacturer we need packaging data (material and weight) and, for electronics and batteries, the product category and technical data, so that the reports are correct from the first delivery.

See how we take over GPSR and EPR ›

Frequently asked questions