By Operator One Editorial — 15 January 2026
Germany's packaging EPR registry — LUCID, operated by Stiftung Zentrale Stelle Verpackungsregister (verpackungsregister.org) — is one of the most mature marketplace-verification regimes in the EU. It has been operational since 2019 and was extended on 1 July 2022 by the second amendment to VerpackG, the Verpackungsgesetz (Packaging Act), to make marketplace verification of LUCID registration legally compulsory before listing.
This piece covers what changed at the start of 2026 and what brands selling on German marketplaces need to confirm in their compliance file.
What is unchanged
The core obligation is unchanged. Any producer placing packaged goods on the German market must:
- Register with LUCID and obtain a LUCID number
- Contract with a dual-system provider (such as Der Grüne Punkt, Interseroh+, Reclay, BellandVision, or others) for licensing of packaging volumes
- Report packaging quantities to LUCID matching what is licensed with the dual system
- Display the LUCID number to marketplaces that require it
Marketplaces (Amazon DE, Otto, Kaufland, eBay DE, bol shipping to DE, Zalando DE) are required under VerpackG §7a to verify the LUCID number before allowing a listing.
What tightened in 2026
Three changes have come into operational effect at the start of this year:
1. Battery EPR enforcement is now matched against LUCID by marketplaces
The Batteriegesetz (BattG, German Battery Act) and the upcoming national transposition of the EU Battery Regulation (Regulation 2023/1542) require any producer placing batteries on the German market to register with the Stiftung EAR (Stiftung Elektro-Altgeräte Register) for battery WEEE-type registration. Until 2025, marketplaces tended to check this separately from packaging. In 2026, the major marketplaces have begun cross-checking battery EPR registration alongside LUCID at upload — products that need a battery EPR registration but only present a LUCID number are now flagged.
2. WEEE / ElektroG checks consolidated
For electrical and electronic equipment, the ElektroG (Elektro- und Elektronikgerätegesetz) requires registration with Stiftung EAR before placing product on the market. Marketplaces have been verifying WAEG registration numbers since 2022, but in 2026 the verification frequency has been increased from annual to quarterly for active sellers, with re-confirmation requests sent automatically.
3. Single-use plastics and EPR for SUP products
The Einwegkunststofffondsgesetz (EWKFondsG, Single-Use Plastics Fund Act, in force since 1 January 2024) requires producers of single-use plastic products listed in Annex 1 (wet wipes, balloons, food containers, etc.) to register with Umweltbundesamt and pay into the SUP fund. Starting January 2026, this registration number is being added to marketplace verification fields for products in the affected categories.
Operational checklist for brands
If you are selling on Amazon DE or any of the major German marketplaces in 2026, the compliance file needs to contain — per product category — the following identifiers as relevant:
- LUCID number (packaging, mandatory if any packaging is involved — which is almost always)
- Dual-system contract reference for the licensed packaging volume
- WAEG/EAR registration number for ElektroG categories
- BattG / Stiftung EAR registration for any product containing or being a battery
- EWKFondsG / Umweltbundesamt registration for single-use plastic products
What the marketplace check looks like in 2026
The verification pattern across Amazon DE, Otto, Kaufland, and eBay DE is now consistent: on upload, the seller account's registered LUCID and EAR numbers are matched against the product category. If the product category requires a registration the account does not have, the listing is held in a pending state and the seller is asked to provide the missing identifier. Listings are no longer published in "grace mode" while registration is being completed.
The Operator One position
For brands where we are Merchant of Record on German marketplaces, the LUCID, EAR, dual-system, and SUP registrations are held in O1's name as the entity placing the goods on the market. The marketplace check passes on our compliance file, and the eco-contribution costs are reported to the brand in O1's monthly settlement.
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