Packaging Act (VerpackG / LUCID)
Germany’s Packaging Act (VerpackG) requires anyone who first places filled packaging on the market to register in the LUCID packaging register and license their packaging with a dual system.
The Packaging Act (LUCID) is the German law governing the placing on the market, take-back and high-quality recovery of packaging (VerpackG). It requires every "first distributor" – that is, any manufacturer, importer or online retailer who commercially places goods-filled packaging on the German market for the first time – to register in the central LUCID packaging register run by the Central Agency Packaging Register foundation (ZSVR) before the first sale, and to license the packaging with a dual system.
LUCID is the public reporting and registration platform through which market participants obtain their registration number and transparently record the packaging volumes they report. Without a valid LUCID registration there is a statutory ban on distribution: goods may not be sold, and marketplaces such as Amazon may block unregistered sellers. The law replaced the old Packaging Ordinance in 2019 and was extended to nearly all types of packaging in 2022.
At a glance
- Mandatory for anyone commercially placing filled packaging on the German market for the first time.
- Two separate steps: registration in LUCID (free of charge) + system participation/licensing with a dual system (paid).
- The LUCID registration number is publicly visible and a prerequisite for selling on marketplaces.
- Applies to sales, secondary and shipping packaging – since 2022 effectively to all packaging.
- Violations: fines of up to €200,000 and a distribution ban.
How the Packaging Act (LUCID) works
The Packaging Act is based on the principle of extended producer responsibility: whoever puts packaging into circulation bears the costs of its later collection, sorting and recovery. This is implemented through two clearly separated duties, both of which must be fulfilled before the first goods are sold.
First, registration in the LUCID register: every obligated party creates an account, enters company data and brand names, and receives a unique registration number (EPR number). This number is searchable in the public register. Second, system participation: the expected packaging volumes – broken down by material such as paper, plastic, glass or tinplate – are declared and licensed with a dual system (e.g. a private waste-disposal provider). The volumes reported there must match the data reports in LUCID (data reconciliation).
Registration, data reporting and declaration of completeness
In addition to the initial registration, there are ongoing data reports: the volumes licensed with the dual system are mirrored in LUCID. Anyone exceeding certain thresholds (including 80,000 kg of glass, 50,000 kg of paper/cardboard or 30,000 kg of lightweight packaging per year) must additionally submit a declaration of completeness certified by a registered expert or auditor. This annual volume audit ensures that all packaging placed on the market has actually been licensed.
Who is affected and which packaging counts
The party affected is the first distributor – not the end consumer and generally not a pure reseller of already-licensed goods. In practice, the obligation applies above all to manufacturers, importers and online retailers. Especially relevant: anyone who imports goods from abroad and sells them in Germany counts as a first distributor and must register and license the packaging themselves.
Covered are packaging subject to system participation that typically arises as waste at private end consumers: sales packaging (product packaging), secondary packaging as well as shipping packaging including filling and cushioning material, boxes and adhesive tape. Since the 2022 amendment, additional types of packaging are also subject to registration, such as transport, reusable and certain service packaging. The shipping material an online retailer uses to send its parcels is therefore also subject to licensing.
Why the Packaging Act (LUCID) matters
The Packaging Act is not a purely environmental issue but a hard prerequisite for distribution. Without LUCID registration and system participation, goods may not legally be placed on the market. Online marketplaces are legally obliged to check the registration of their sellers and block listings without a valid EPR number. For a retailer, a missing entry therefore means not only a fine risk but, in the worst case, an immediate stop to revenue on the most important channel.
On top of this comes the warning-letter risk: missing or incomplete registrations can be challenged by competitors and associations. Depending on the violation, fines reach up to €200,000. Clean, documented volume tracking therefore protects both against official sanctions and against competition-law attacks.
The Packaging Act in the ERP system
For compliance, the core question is: how much packaging material of which material was actually placed on the market? This is exactly the data basis the ERP or inventory management system provides. Using the packaging unit per item and the shipping data, the volumes placed on the market per material fraction (paper, plastic, glass …) can be derived for the data report to LUCID and the dual system.
In practice, packaging weights per material are stored in the item master, the sold quantities are summed from goods issue and shipping documents, and periodic volume reports are generated from them. Some systems or connected fulfillment providers offer prepared evaluations for this. This makes the annual volume report reproducible and audit-proof instead of relying on manual estimates.
Keep the data basis clean
For the evaluation to be correct, packaging weights and material types must be maintained consistently in the master-data module – incomplete data maintenance leads to incorrect volume reports and thus to a compliance risk. Clean data quality in the item and shipping master is therefore the actual foundation of VerpackG conformity, not the law itself.
Distinction: VerpackG vs. EPR and packaging unit
The Packaging Act is the German embodiment of the European "Extended Producer Responsibility" (EPR). Other EU countries have their own EPR systems with their own registers; anyone selling across borders must register separately in each target country. LUCID applies exclusively to Germany.
The legal concept of packaging should not be confused with the logistical packaging unit: the latter describes the quantities in which an item is bundled for storage and shipping, and is a master-data term with no legal reporting obligation. The two are nonetheless connected, because the packaging unit provides the basis for calculating the packaging material placed on the market. The Packaging Act must also be distinguished from other product EPR obligations such as the Electrical (WEEE) or Battery Act, which follow their own registers.
Anyone selling internationally should therefore clarify early in which countries separate registrations are required and set out responsibility cleanly by contract: if a retailer sells via a fulfillment provider or a marketplace program, they generally still remain the first distributor with the reporting obligation. Simply outsourcing logistics does not release them from the registration and licensing duty.
Example
Online retailer imports goods from Asia
A mid-sized e-commerce retailer imports household items from Asia and sells them through its own shop and Amazon. Because it places the goods on the German market for the first time, it is the first distributor: it registers in LUCID, receives its EPR number and reports the estimated annual volumes of cardboard, plastic film and filling material to a dual system.
It draws the volumes from its ERP system: packaging weight and material are stored for each item, and the quantity sold follows from the previous year’s shipping documents. At year-end it reconciles the volumes actually reported with the licensing. Amazon checks the EPR number automatically – without a valid entry the marketplace would deactivate its listings.
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