Germany EPR 2026: LUCID, EAR and BattDG

By Operator One Editorial — 2026-06-14

Key takeaways

Germany's Verpackungsgesetz (VerpackG) ceased to have effect at the end of 11 August 2026. Since 12 August 2026, packaging EPR in Germany runs under the EU Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) and the German Verpackungsrecht-Durchführungsgesetz (VerpackDG), and LUCID at the Zentrale Stelle Verpackungsregister (ZSVR) remains the register.
Under section 5(2) VerpackDG, producers with no establishment in Germany must appoint one German authorised representative for extended producer responsibility before first making packaging available, but the LUCID registration under section 6 VerpackDG stays with the producer. Producers already registered in LUCID must record the change by 12 November 2026.
Germany's Batteriegesetz (BattG) was replaced by the Batterierecht-Durchführungsgesetz (BattDG) on 7 October 2025. Under section 64 BattDG, BattG registrations granted before 18 August 2025 were carried over only until the end of 15 January 2026; where participation in an approved Organisation für Herstellerverantwortung (OfH) had not been proven by then, they are treated as revoked retroactively from 1 January 2026, and registrations of producers not established in Germany were not carried over at all.
Under Germany's ElektroG, stiftung ear registers producers per brand and device category, quantities are reported monthly by the 15th of the following month (section 27 ElektroG), and section 6(2) ElektroG bars electronic marketplaces and fulfilment providers from handling devices of unregistered producers.
German EPR fines reach EUR 200,000 for failing to participate in a dual system and EUR 100,000 for failing to register in LUCID (section 66 VerpackDG), EUR 100,000 under section 45 ElektroG, and EUR 100,000 for making batteries available without registration (section 60 BattDG).
Under section 10 VerpackDG, the declaration of completeness is due in LUCID by 15 May each year for producers that placed 80 tonnes or more of glass, 50 tonnes or more of paper, paperboard and cardboard, or 30 tonnes or more of other packaging materials on the German market in the previous calendar year.

Updated 13 September 2026. Germany runs one of the most enforced Extended Producer Responsibility (EPR) regimes in the European Union. Three separate German legal tracks sit in front of any product that reaches a German shopper: one for packaging, one for electrical and electronic equipment, one for batteries. Each is enforced by the competent authority, and German law also restricts what marketplaces, distributors and fulfilment providers may do for unregistered producers. Two of the three laws changed since this guide first appeared: the BattDG replaced the BattG on 7 October 2025, and the VerpackDG replaced the VerpackG on 12 August 2026, the day Regulation (EU) 2025/40 (PPWR) started to apply.

This piece walks through what each German register covers, what triggers the obligation, how the platform and fulfilment restrictions operate, and when a producer without a German establishment must appoint an authorised representative.

The three German EPR registers at a glance

Germany did not bundle EPR into a single national scheme. Three distinct German laws, each with its own register, apply in parallel:

VerpackDG with PPWR (EU) 2025/40 (packaging): the register is LUCID, operated by Stiftung Zentrale Stelle Verpackungsregister (ZSVR). The VerpackDG replaced the VerpackG from 12 August 2026.
ElektroG (electrical and electronic equipment): registration with stiftung ear (Elektro-Altgeräte Register).
BattDG with the EU Battery Regulation (EU) 2023/1542 (batteries): also registered with stiftung ear, on a separate track from ElektroG. The BattDG replaced the BattG on 7 October 2025.

A brand that ships, for example, a cordless beauty device in a printed cardboard box with a lithium-ion cell inside it touches all three German regimes at once. None of them can be skipped, and none of them substitutes for the others.

VerpackDG and LUCID: the packaging baseline

Since 12 August 2026, German packaging EPR follows the producer definition in Article 3(1)(15) of PPWR (EU) 2025/40, implemented by the VerpackDG. ZSVR notes that, depending on the supply chain, the packaging producer can be the manufacturer, the importer or the distributor, and that there is no de minimis threshold for commercial activity. ZSVR also states that shipping packaging used in online sales is subject to dual-system participation without exception. Distance sellers shipping into Germany from abroad are in scope.

Two things are mandatory under the VerpackDG and must both be in place before packaging is first made available in Germany:

LUCID registration with ZSVR under section 6 VerpackDG, including brand names and the packaging types placed on the German market. Section 5(1) VerpackDG states that third parties cannot be engaged to carry out this registration.
Participation in a dual system (Duales System) under section 7 VerpackDG for packaging that typically ends up as waste in private households. Systems listed by ZSVR include Der Grüne Punkt, INTERSEROH+, Reclay, Landbell, Zentek, BellandVision, EKO-PUNKT, Noventiz, PreZero Dual, Recycling Dual and Veolia Umweltservice Dual.

The LUCID registration alone is not compliance. Producers must also report the system participation data to LUCID under section 9 VerpackDG, and section 5(1) VerpackDG excludes these data reports from delegation to ordinary third parties. Two 2026 transition points matter under section 68 VerpackDG: system participations concluded under the old VerpackG before 12 August 2026 continue at most until 31 December 2026, and producers that became obliged to register for the first time under the VerpackDG had to register by 12 September 2026.

Under section 10 VerpackDG, producers at or above 80 tonnes of glass, 50 tonnes of paper, paperboard and cardboard, or 30 tonnes of other materials in the previous calendar year must file a declaration of completeness in LUCID by 15 May, checked by a registered expert or a registered auditor, tax adviser or sworn accountant. ZSVR or the competent state authority can demand a declaration below those thresholds at any time.

ElektroG and stiftung ear: electronics

Germany's ElektroG transposes the EU WEEE Directive and applies to producers placing electrical or electronic equipment (EEE) on the German market. The test is functional: if the product depends on electric current or electromagnetic fields to work as intended, it is in scope. That covers consumer electronics and small kitchen appliances, but also USB-powered novelties, illuminated furniture, electric toothbrushes and cables sold separately.

Compliance under the ElektroG requires:

Registration with stiftung ear per brand and per device category, resulting in a WEEE registration number (WEEE-Reg.-Nr. DE).
A financial guarantee under section 7 ElektroG for devices that can be used in private households.
Monthly volume reporting of devices placed on the market per device type, due by the 15th of the following month under section 27 ElektroG.

A stiftung ear registration is tied to a specific legal entity, brand name and device category. Selling a further brand or a new category in Germany without registering it counts as placing unregistered equipment on the market, and section 45 ElektroG sets fines of up to EUR 100,000 for the most serious breaches.

BattDG: batteries on their own track

Batteries are not a sub-case of the ElektroG. The Batterierecht-Durchführungsgesetz (BattDG) entered into force on 7 October 2025, replacing the Batteriegesetz (BattG) and implementing the EU Battery Regulation (EU) 2023/1542 in Germany. The Umweltbundesamt again entrusted stiftung ear with registration under the BattDG. Regulation (EU) 2023/1542 distinguishes portable batteries, light means of transport (LMT) batteries, starting, lighting and ignition (SLI) batteries, industrial batteries and electric vehicle batteries, and batteries incorporated into products are covered. A lithium cell inside a wireless speaker therefore triggers the BattDG even though the speaker itself triggers the ElektroG.

Under section 5 BattDG, a producer must register with the competent authority with its brand and each battery category before first making batteries available in Germany. According to the Umweltbundesamt, producers must now take on extended producer responsibility for all battery categories, not only portable batteries, and section 7(1) BattDG requires them to participate in an approved Organisation für Herstellerverantwortung (OfH) for each battery category or to fulfil that responsibility individually. Under section 64 BattDG, BattG registrations granted before 18 August 2025 were carried over only until the end of 15 January 2026, and those for which OfH participation had not been proven by then are treated as revoked retroactively from 1 January 2026. Section 64 excludes registrations of persons not established in Germany from that carry-over.

Section 4(3) BattDG bars dealers from making available, and fulfilment providers from storing, packing, addressing or shipping, batteries of a producer that is not properly registered. Section 60 BattDG sets fines of up to EUR 100,000 for making batteries available without registration and for those fulfilment breaches.

The marketplace verification mandate

German and EU law now places checks on the intermediaries between a producer and a German shopper, so a marketplace or fulfilment provider cannot simply take the seller's word for it. The rules differ per stream:

Packaging (PPWR and VerpackDG): under Article 45(4) of Regulation (EU) 2025/40, read with Article 30(1)(d) and (e) of the Digital Services Act (EU) 2022/2065, online platforms that let consumers conclude distance contracts must obtain the producer's registration information and registration number for the consumer's member state, plus a self-certification, before allowing the producer to use the service. Section 13(4) VerpackDG bars fulfilment providers from handling packaging of producers not properly registered in LUCID, and ZSVR provides an automated data match for this.
Electronics (ElektroG): since 1 July 2023, section 6(2) ElektroG bars operators of electronic marketplaces from enabling offers of devices from unregistered producers, and bars fulfilment providers from storing, packing, addressing or shipping them.
Batteries (BattDG): section 4(3) BattDG bars dealers and fulfilment providers from handling batteries of unregistered producers.

Amazon.de, eBay.de, Kaufland.de, Otto.de and Zalando.de all fall under these German and EU rules where they act as online platforms for German consumers. A listing that cannot show the required registration can be blocked.

Brands without a German establishment and the authorised representative requirement

All three German laws now require a producer with no establishment in Germany to appoint a German authorised representative (Bevollmächtigter). Each law treats the role slightly differently:

VerpackDG: since 12 August 2026, section 5(2) VerpackDG, read with Article 45(3) of PPWR (EU) 2025/40, requires producers with no German establishment to appoint one authorised representative for extended producer responsibility before first making packaging available, by written mandate in German. The representative acts in its own name and is treated as the producer for the delegated obligations (section 5(3) VerpackDG), covering system participation, data reports and declarations of completeness, but not the LUCID registration, which ZSVR describes as a personal duty the producer must fulfil itself. The producer names the representative in LUCID and ZSVR confirms it. ZSVR states the representative must have a registered office or branch in Germany and cannot be an employee or affiliate of the producer. Producers already registered before 12 August 2026 must record the change by 12 November 2026 (section 68(2) VerpackDG).
ElektroG: under section 8 ElektroG, a producer without an establishment in Germany must appoint an authorised representative, may appoint only one, and must do so in writing in German.
BattDG: under section 40 BattDG, a producer without an establishment in Germany must appoint an authorised representative for extended producer responsibility, only one, in writing and in German.

The German authorised representative is not a forwarder or a brand-protection agent. It is a regulated legal role that performs the producer's obligations in its own name.

What this means operationally in 2026

For a brand selling into Germany in 2026, the practical checklist looks like this:

Confirm whether the product, its packaging and any embedded battery each trigger their own German regime: most consumer electronics trigger VerpackDG, ElektroG and BattDG at once.
Hold a LUCID registration in the producer's own name and dual-system participation, and renew any participation concluded under the old VerpackG before it ends on 31 December 2026 at the latest.
Hold a WEEE-Reg.-Nr. DE per brand per device category, with monthly volume reports filed by the 15th of the following month.
Hold a BattDG registration per brand and battery category, with participation in an approved OfH for each battery category or individual fulfilment under section 7(1) BattDG.
For producers without a German establishment, appoint one German authorised representative under each of VerpackDG, ElektroG and BattDG, and record the packaging representative in LUCID by 12 November 2026 if already registered.
Diarise 15 May for the VerpackDG declaration of completeness if above the 80, 50 or 30 tonne thresholds.

In Operator One's experience, the first consequence of a gap is usually a blocked listing on a German marketplace rather than a fine, and restoring it takes time because the registration has to be completed before the listing can return.

How to register, step by step

Map each product to the three German regimes. Check whether the packaging (VerpackDG and PPWR), the device (ElektroG) and any battery, including built-in cells (BattDG), each trigger an obligation, and identify which legal entity first makes the goods available in Germany.
Appoint German authorised representatives where required. If the producer has no establishment in Germany, appoint one representative per law by written mandate in German under section 5 VerpackDG, section 8 ElektroG and section 40 BattDG.
Register in LUCID and join a dual system. The producer registers itself with ZSVR under section 6 VerpackDG before first making packaging available, names any authorised representative, and concludes dual-system participation under section 7 VerpackDG.
Register with stiftung ear under the ElektroG. Register per brand and device category, provide the section 7 ElektroG guarantee for household devices, and obtain the WEEE-Reg.-Nr. DE.
Register batteries under the BattDG and join an OfH. Register with stiftung ear per brand and battery category under section 5 BattDG and prove participation in an approved Organisation für Herstellerverantwortung.
Report on the German calendar. File ElektroG quantities monthly by the 15th, LUCID data reports under section 9 VerpackDG, and the declaration of completeness by 15 May where the section 10 VerpackDG thresholds are met.

Frequently asked questions

Do I need a LUCID number to sell on Amazon Germany?

Yes. Under Germany's VerpackDG, every producer that first makes packaged goods available in Germany must register in LUCID with the Zentrale Stelle Verpackungsregister (ZSVR) before the first sale, and ZSVR states there is no de minimis threshold for commercial activity. Under PPWR Article 45(4), online platforms such as Amazon.de must obtain the registration number before letting the producer use their service. A LUCID registration without dual-system participation is still non-compliant.

Is the German BattG still valid in 2026?

No. Germany's Batteriegesetz (BattG) was replaced on 7 October 2025 by the Batterierecht-Durchführungsgesetz (BattDG), which implements EU Battery Regulation (EU) 2023/1542. Registration still runs through stiftung ear, per brand and battery category. Under section 64 BattDG, BattG registrations were carried over only until the end of 15 January 2026; where participation in an approved Organisation für Herstellerverantwortung (OfH) had not been proven by then, they are treated as revoked retroactively from 1 January 2026, and registrations of producers not established in Germany were not carried over at all.

What happens if I sell into Germany without EPR registration?

Fines apply under each German law. Section 66 VerpackDG allows up to EUR 200,000 for failing to participate in a dual system and up to EUR 100,000 for failing to register in LUCID. Section 45 ElektroG allows up to EUR 100,000, and section 60 BattDG up to EUR 100,000 for making batteries available unregistered. Marketplaces and fulfilment providers are also barred from handling such goods. In Operator One's experience, the listing block is felt before any fine.

Who carries the German EPR obligation when a Merchant of Record is the seller?

Each German law attaches the obligation to the legal entity that meets its producer definition, typically the entity that first makes the goods available in Germany; ZSVR notes this can be the manufacturer, importer or distributor. Where a Merchant of Record imports the stock and sells as the legal seller, it commonly registers under VerpackDG, ElektroG and BattDG in its own name. Registrations do not transfer between legal entities, and where a brand ships from its own stock, the obligation can stay with the brand.

Do brands without a German establishment need an authorised representative for packaging?

Yes, since 12 August 2026. Section 5(2) of Germany's VerpackDG, read with PPWR Article 45(3), requires producers with no establishment in Germany to appoint one authorised representative for extended producer responsibility by written German-language mandate before first making packaging available. The representative handles system participation, data reports and declarations in its own name, but not the LUCID registration, which ZSVR calls a personal duty. Already-registered producers must record the change by 12 November 2026.

What is the WEEE-Reg.-Nr. DE and when do I need one?

It is the registration number stiftung ear issues under Germany's ElektroG to a producer for a brand and device category. Products that depend on electric current or electromagnetic fields to work are in scope, including USB-powered novelties and separately sold cables. Quantities are reported monthly by the 15th of the following month under section 27 ElektroG, and since 1 July 2023 section 6(2) ElektroG bars marketplaces and fulfilment providers from handling devices of unregistered producers.

Does a battery inside a product need its own German registration?

Yes. A cell built into an appliance is covered by EU Battery Regulation (EU) 2023/1542 and Germany's BattDG, and is registered with stiftung ear separately from the ElektroG registration for the appliance. A cordless speaker therefore touches three German regimes: VerpackDG for the box, ElektroG for the speaker and BattDG for the cell. Under section 7(1) BattDG, the producer must participate in an approved Organisation für Herstellerverantwortung (OfH) for each battery category or fulfil its extended producer responsibility individually.

When is the German declaration of completeness due?

Under section 10 of Germany's VerpackDG, the declaration of completeness is due in LUCID by 15 May for the previous calendar year, checked by a registered expert, auditor, tax adviser or sworn accountant. Producers are exempt below 80 tonnes of glass, 50 tonnes of paper, paperboard and cardboard, and 30 tonnes of other materials, but ZSVR or the state authority can demand one at any time. A missing or late declaration is an offence under section 66 VerpackDG.

Where a Merchant of Record carries the German EPR obligation

German EPR obligations under the VerpackDG, ElektroG and BattDG attach to a specific legal entity and do not transfer between entities. Where a Merchant of Record such as Operator One imports the goods into the EU and sells them as the legal seller, it is commonly that entity which first makes the goods available in Germany, and the registrations are then held and reported in its own name for the streams it places on the German market. Where a brand ships to German consumers from its own stock, the brand's own German registrations remain relevant. Product conformity, CE marking and the EU Declaration of Conformity stay with the manufacturer; EPR registration is a separate, per-country and per-stream obligation. Listings remain Brand = the client, Sold by = the legal seller. See the compliance glossary for the underlying definitions.

Sources: Verpackungsrecht-Durchführungsgesetz (VerpackDG), BGBl. 2026 I Nr. 207; Regulation (EU) 2025/40 (PPWR), EUR-Lex; ZSVR: authorising a representative; ZSVR: roles and duties under PPWR and VerpackDG; ZSVR: overview of system operators; ElektroG section 6; ElektroG section 45; stiftung ear: BattDG in force on 7 October 2025; BattDG section 64; BattDG section 7; Umweltbundesamt: BattDG in force, stiftung ear entrusted again; BattDG section 60; stiftung ear: first OfH approvals; Regulation (EU) 2023/1542 (Battery Regulation), EUR-Lex.

Germany EPR 2026: LUCID, EAR and BattG explained