EPR Obligations EU → 🇩🇪 Germany
EPR in Germany 2026: Packaging, WEEE & Batteries
Anyone who sells packaged goods, electrical equipment or batteries to customers in Germany is a producer and must register before selling: packaging in the free LUCID register of the ZSVR, electrical equipment and batteries with stiftung ear. Since 12 August 2026 the VerpackDG and the EU Packaging Regulation (PPWR) apply.
Last reviewed: · Sources linked below
Short answer: EPR in Germany means up to three separate registrations. Packaging goes into LUCID, the packaging register of the Zentrale Stelle Verpackungsregister (ZSVR), plus participation in a dual system. Electrical and electronic equipment (WEEE) and batteries are registered with stiftung ear. Amazon.de asks for the 13-digit LUCID number before you can sell packaged goods there.
EPR Germany at a glance
- Packaging register / scheme(s)
- LUCID register of the ZSVR (registration free of charge; it stays with the producer) plus system participation with a dual system. Legal basis: VerpackDG since 12 August 2026, together with the PPWR (EU 2025/40).
- Authorized representative
- Packaging (§ 5 VerpackDG): only for producers without a German branch who sell directly to end users in Germany. WEEE and batteries: producers without a German establishment register via an authorized representative (Bevollmächtigter).
- WEEE
- Registration with stiftung ear per brand and device type before placing on the market; insolvency-proof guarantee for B2C equipment. Official fee: €9.50 per device type (net).
- Batteries
- Registration with stiftung ear (delegated by the UBA) under the EU Battery Regulation and the BattDG; joining a producer responsibility organisation (PRO) is mandatory since 1 January 2026.
- Thresholds
- Completeness declaration (Vollständigkeitserklärung) required above 80 t glass, 50 t paper/board or 30 t lightweight packaging. These thresholds concern the declaration, not the LUCID registration.
- Penalties
- § 66 VerpackDG: up to €200,000, €100,000 or €10,000 depending on the offence; PPWR-related fines apply from 12 February 2027.
- Marketplace checks
- Amazon.de requires the 13-digit LUCID number and, for electrical equipment, the stiftung ear registration; non-compliant offers may be deactivated. eBay may hide listings without the packaging EPR number.
- What changed in 2026
- VerpackDG replaced the VerpackG on 12 August 2026; new § 5 representative duty; LUCID data updates due by 12 November 2026; old dual-system contracts end by 31 December 2026 at the latest; battery PRO duty since 1 January 2026.
What changed in 2026
On 12 August 2026 Germany switched from the Packaging Act (VerpackG) to the Verpackungsrecht-Durchführungsgesetz (VerpackDG). The VerpackDG (BGBl. 2026 I Nr. 207) implements the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40), which applies directly in all member states from the same day. LUCID remains the register and the ZSVR remains the authority, but several rules are new.
- Existing LUCID registrations remain valid. Changes to your registration data must be made by 12 November 2026 (§ 68 VerpackDG).
- Dual-system contracts: participations concluded before 12 August 2026 continue at most until 31 December 2026, unless the contract ends earlier. From 1 January 2027 dual systems must prove that they meet the additional requirements.
- New representative duty (§ 5 VerpackDG): producers without a German branch who sell directly to end users in Germany must authorise a representative. Details below.
- One completeness declaration for 2026 under § 10 VerpackDG, due 17 May 2027; the 2026 data is broken down according to the old VerpackG rules.
- Fines: the PPWR-related fines in § 66(2) VerpackDG apply from 12 February 2027.
- Fee modulation is not new: German dual systems already modulate fees under § 26 VerpackDG. EU-harmonised modulation by recyclability grade follows later (expected around 2028–2030).
- Batteries: the BattDG has been in force since 7 October 2025; joining a producer responsibility organisation is mandatory since 1 January 2026.
Proposal – not yet law The EU Environmental Omnibus (COM(2025) 982, 10 December 2025) proposes to suspend the authorized-representative duty for EU-established producers. The Council's position of 21 October 2026 would exempt EU-established producers placing under 1 tonne of packaging per year in another member state until 2032; the European Parliament voted on 20 October 2026 for an exemption for EU micro and small enterprises until 2035. Trilogue negotiations follow. None of this is in force, and none of it helps sellers established outside the EU. Track it on our PPWR 2026 update page.
Packaging obligations: LUCID and the VerpackDG
LUCID is the German packaging register run by the Zentrale Stelle Verpackungsregister (ZSVR). Registration is free of charge and gives you the 13-digit registration number that marketplaces ask for. The registration always stays with the producer — also when a representative is appointed.
Who is a producer?
A producer is the business that makes packaged goods available on the German market for the first time. Under the PPWR this expressly includes distance sellers: companies established in another EU member state or outside the EU that sell packaged products directly to end users in Germany, for example via Amazon.de, eBay or their own web shop. If you ship from abroad to German consumers, assume that you are the producer until you have checked otherwise.
Step by step
- Register in LUCID with your company data, brand names and packaging types. You receive the 13-digit registration number that you give to marketplaces.
- Check § 5 VerpackDG: if you have no German branch and sell directly to German end users, authorise exactly one representative and enter it in LUCID.
- Conclude system participation with a dual system for your packaging. If your contract dates from before 12 August 2026, it runs until 31 December 2026 at the latest — arrange the follow-up contract in time.
- Report your quantities (data reporting) consistently to your dual system and in LUCID, as described by the ZSVR.
- File the completeness declaration for 2026 by 17 May 2027 if you exceed 80 t glass, 50 t paper/board or 30 t lightweight packaging.
Need hands-on help with the registration itself? Our sister site covers the process in detail: LUCID registration guide on register-epr.com.
Already registered before 12 August 2026? Your LUCID number stays valid. Log in, check your data and producer role against the new rules, and make any changes by 12 November 2026.
WEEE obligations: stiftung ear registration (ElektroG)
WEEE compliance in Germany starts with registration at stiftung ear (Elektro-Altgeräte Register). Producers register per brand and device type before placing electrical or electronic equipment on the German market. For equipment that can be used in private households (B2C), an insolvency-proof guarantee is required. Producers without a German establishment need an authorized representative (Bevollmächtigter), who registers on their behalf.
Official stiftung ear fees (net)
| Fee item | Amount (net) |
|---|---|
| ElektroG registration | €9.50 per device type |
| Quarterly fee item | €32.80 per quarter |
| Check of a collective guarantee | €3.80 |
| Check of an individual guarantee | €156.90 |
| Confirmation of an authorized representative | €50.60 |
Official fees only, as published by stiftung ear. The costs of the guarantee itself, of take-back and of service providers come on top.
How long does it take? Processing times vary. Plan several weeks for the financial guarantee, and do not list new electrical products before the registration number is issued.
Step-by-step instructions for device types, guarantees and the representative: WEEE registration in Germany on register-epr.com.
Battery obligations: BattDG and the EU Battery Regulation
Battery producers in Germany register with stiftung ear, which runs the register on behalf of the Federal Environment Agency (UBA). The EPR regime of the EU Battery Regulation (EU) 2023/1542 has applied since 18 August 2025; the German Batterierecht-Durchführungsgesetz (BattDG) has been in force since 7 October 2025. Batteries built into devices count too — a seller of a cordless product usually needs both a WEEE and a battery registration.
- Registration with stiftung ear: €16.40 per battery category and €3.80 per quarter (official fees, net).
- Producer responsibility organisation: joining a PRO has been mandatory since 1 January 2026.
- Foreign producers: producers without a German establishment register via an authorized representative.
- EU next steps: from 18 February 2027 the EU rules on QR codes for all batteries, removability/replaceability and the battery passport (EV, LMT and industrial batteries above 2 kWh) are expected to apply; due-diligence obligations were postponed to 18 August 2027.
Proposal – not yet law The Environmental Omnibus would also suspend the authorized-representative duty for batteries. The European Parliament voted on 20 October 2026; the Council position is pending.
Practical registration guide: battery registration in Germany on register-epr.com.
Amazon.de and eBay: what marketplaces check
Amazon.de requires a valid 13-digit LUCID registration number for packaged products sold to Germany, and a stiftung ear registration for electrical and electronic equipment. For non-compliant offers, Amazon says it may deactivate the listings or may fulfil the obligations on the seller's behalf.
- In a global notice of 25 March 2026, Amazon announced packaging EPR checks across the EU from 12 August 2026 and named Germany among the countries concerned. Amazon may need to stop selling non-compliant products.
- Pay on Behalf-type services are a fallback: they settle fees but do not replace your own registration or your legal responsibility as a producer.
- eBay requires packaging EPR numbers from 12 August 2026 for each country where the seller is the producer; listings may be hidden from buyers in that country.
Which number goes where in Seller Central? See Amazon EPR number guide and the overview EPR number by country.
Authorized representative in Germany
An authorized representative is a Germany-based person or company that fulfils EPR duties on behalf of a producer without a German establishment. Whether you need one depends on the product stream. Decision table by seller type: authorized representative in Germany.
| Stream | When is a representative required? | How it works |
|---|---|---|
| Packaging (§ 5 VerpackDG) | Since 12 August 2026, only for producers without a German branch who sell directly to end users in Germany | Only one representative; contract in German; the producer enters the representative in LUCID; effective once the representative confirms. The LUCID registration stays with the producer. |
| WEEE (ElektroG) | Producers without a German establishment | The representative (Bevollmächtigter) registers with stiftung ear; confirmation fee €50.60 (net) |
| Batteries (BattDG) | Producers without a German establishment | Registration with stiftung ear via the representative |
How Certify helps
- Free obligation check: you describe your products, sales channels and company seat; we tell you which German registrations and which representative roles apply.
- Registration: Certify GmbH prepares the LUCID, stiftung ear and battery registrations with you and, where the law requires it, acts as your authorized representative.
- Ongoing compliance: data reports, the 2026 completeness declaration and the 2027 deadlines are tracked together with you — alongside your other EU countries.
EPR deadlines for Germany 2026–2027
The table lists the German and EU dates that matter for sellers between now and mid-2027. All EU dates are on our deadline calendar.
| Date | Scope | What happens |
|---|---|---|
| 12 Aug 2026 | EU / DE | PPWR applies; VerpackDG replaces VerpackG; § 5 representative duty starts |
| 12 Nov 2026 | DE | Deadline to update LUCID registration data (§ 68 VerpackDG) |
| 31 Dec 2026 | DE | Dual-system participations concluded before 12 Aug 2026 end at the latest |
| 1 Jan 2027 | DE | Dual systems must prove the additional requirements |
| 12 Feb 2027 | EU / DE | Member-state PPWR penalty rules due; PPWR-related fines under § 66(2) VerpackDG apply |
| 18 Feb 2027 | EU batteries | QR code, removability rules and battery passport (EV, LMT, industrial >2 kWh) |
| 17 May 2027 | DE | Completeness declaration for 2026 (15 May 2027 is a Saturday) |
| 18 Aug 2027 | EU batteries | Battery due-diligence obligations (postponed) |
| Pending | EU | Proposal – not yet law Authorized-representative exemption for EU-established producers (trilogue) |
Penalties for packaging non-compliance in Germany
Under § 66 VerpackDG, administrative fines reach up to €200,000, €100,000 or €10,000 depending on the offence. The PPWR-related offences in § 66(2) can be fined from 12 February 2027.
| Consequence | Detail | Source |
|---|---|---|
| Fine, highest tier | Up to €200,000 depending on the offence | § 66 VerpackDG |
| Fine, middle tier | Up to €100,000 depending on the offence | § 66 VerpackDG |
| Fine, lowest tier | Up to €10,000 depending on the offence | § 66 VerpackDG |
| PPWR-related fines | Apply from 12 February 2027 | § 66(2) VerpackDG |
| Marketplace | Amazon may deactivate offers; eBay may hide listings | Amazon, eBay seller information |
The ElektroG and the BattDG contain their own fine provisions; check the current statute or ask us for the figures relevant to your products.
Frequently asked questions — EPR in Germany
How do I get an EPR number in Germany?
There is no single German EPR number. For packaging you register in LUCID, the free register of the Zentrale Stelle Verpackungsregister (ZSVR), and receive a 13-digit registration number. For electrical and electronic equipment you register with stiftung ear per brand and device type, and batteries are also registered with stiftung ear. Marketplaces such as Amazon.de check these numbers separately.
Do I need an authorized representative for packaging in Germany?
Only in one case: since 12 August 2026, § 5 VerpackDG requires producers without a German branch who sell directly to end users in Germany to authorise a representative. Only one representative is allowed, the contract must be in German, the producer enters the representative in LUCID and the authorisation takes effect once the representative confirms. The LUCID registration itself stays with the producer.
I registered in LUCID before 12 August 2026. What do I have to do now?
Your LUCID registration remains valid. Changes to your registration data must be made by 12 November 2026. Dual-system participations concluded before 12 August 2026 end on 31 December 2026 at the latest, so arrange a follow-up contract. For 2026 you file one completeness declaration under § 10 VerpackDG, due 17 May 2027, if you exceed the thresholds.
When is the completeness declaration for 2026 due?
The completeness declaration is due on 15 May of the following year. Because 15 May 2027 is a Saturday, the deadline for 2026 is effectively Monday 17 May 2027. It is required above 80 tonnes of glass, 50 tonnes of paper and board or 30 tonnes of lightweight packaging, and the 2026 data is broken down according to the old VerpackG rules.
How much does WEEE registration with stiftung ear cost?
The official stiftung ear fees (net) are €9.50 per device type for ElektroG registration, €32.80 per quarter, €3.80 for checking a collective guarantee, €156.90 for checking an individual guarantee and €50.60 for confirming an authorized representative. Costs for the guarantee itself and for take-back come on top. Processing times vary, so plan several weeks for the financial guarantee.
Do battery producers have to join a producer responsibility organisation in Germany?
Yes. Under the BattDG, in force since 7 October 2025, joining a producer responsibility organisation has been mandatory since 1 January 2026. Producers also register with stiftung ear, which runs the battery register on behalf of the Federal Environment Agency. Producers without a German establishment register via an authorized representative.
What happens if I sell on Amazon.de without a LUCID number?
Amazon.de requires a valid 13-digit LUCID number for packaged products and may deactivate non-compliant offers or fulfil the obligations on the seller's behalf. Such a fallback does not replace your own registration. In addition, § 66 VerpackDG provides for fines of up to €200,000, €100,000 or €10,000 depending on the offence.
- VerpackDG – Verpackungsrecht-Durchführungsgesetz (gesetze-im-internet.de)
- § 68 VerpackDG – transitional provisions
- § 66 VerpackDG – administrative fines
- ZSVR – What changed on 12 August 2026
- ZSVR – Authorising a representative
- ZSVR – Declaration of completeness
- stiftung ear – Costs and fees
- stiftung ear – press release on battery registration (18 Aug 2025)
- IHK Köln – BattDG overview
- Amazon.de – Extended producer responsibility
- Council of the EU – negotiating position of 21 October 2026
This page is general information, not legal advice. Last reviewed 27 October 2026.
Other country guides
EPR obligations are national: registers, schemes and representative rules differ from country to country.
Free EPR check for Germany: LUCID, WEEE and batteries
Tell us what you sell to German customers and through which channels. We check which registrations you need (LUCID, stiftung ear for WEEE and batteries), whether § 5 VerpackDG requires an authorized representative, and which 2026/2027 deadlines apply to you. Your message is delivered directly to Certify — specialists in EU-wide producer responsibility compliance. Free first consultation, no obligation. Response within 24 hours.