• LUCID Registration Support for Packaging Compliance in Germany
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EaseCert | GPSR Compliance

LUCID Registration Support for Packaging Compliance in Germany

LUCID Registration Support for Packaging Compliance in Germany

€400,00 EUR
€400,00 EUR
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One-time fee. No subscription. Taxes included. A Setup & Documentation Fee may apply depending on service scope. It covers onboarding, review of existing compliance materials, document verification, and technical documentation checks for EU GPSR compliance.

If your company sells packaged products or supplies packaging in Germany, you may have registration, system participation, reporting and other Extended Producer Responsibility (EPR) obligations under the EU Packaging and Packaging Waste Regulation (PPWR) and the German Packaging Law Implementation Act (VerpackDG). From 12 August 2026, these rules replaced the previous German Packaging Act (VerpackG) framework and changed how responsibility is allocated between manufacturers, producers, retailers, importers and foreign sellers.

Before starting Packaging EPR work, EaseCert first confirms whether your GPSR or other applicable EU product-safety status has been addressed. GPSR and Packaging EPR are separate legal systems: GPSR concerns product safety, technical documentation, risk assessment, labeling, traceability and market surveillance, while Packaging EPR concerns producer registration, reporting, recycling financing and packaging waste obligations.

EaseCert follows the compliance sequence: GPSR / Product Safety → EPR / WEEE / Batteries → PPWR.

EaseCert provides Germany Packaging EPR and LUCID support only for products that have first been certified by EaseCert for the applicable EU product-safety requirements.

Our Germany LUCID Registration & Authorised Representative Support Service helps determine whether your company is the responsible producer under the applicable German packaging rules, reviews new or existing LUCID registrations, assesses system participation obligations and supports eligible foreign producers with the formal appointment of EaseCert as their German Packaging EPR Authorised Representative.

Learn more about EU Packaging EPR compliance in 2026.

Important: The EaseCert fee for this service is €400 EUR one time only. There is no annual or recurring EaseCert fee for the standard Authorised Representative appointment covered by this service.

Before EaseCert can provide its LUCID Authorised Representative ID or accept an appointment, the customer must first provide proof of a valid German dual-system / Producer Responsibility Organisation (PRO) contract covering the relevant packaging.

EaseCert is not a recycling company, waste collector, Producer Responsibility Organisation (PRO), dual-system operator or government authority. The customer concludes and pays for the German dual-system / PRO contract directly with the relevant system operator. PRO fees, recycling fees, system-participation fees, declarations, reporting charges, authority fees and other third-party costs are separate from the EaseCert service fee.

What Changed from 12 August 2026?

The PPWR reorganised responsibility for packaging in Germany. Key obligations for packaging subject to system participation — including LUCID registration, system participation and packaging-volume reporting — continue, but the rules determining who must fulfil those obligations may have changed.

This makes it especially important to determine the correct responsible producer before completing or updating a LUCID registration or Authorised Representative appointment.

  • Own-brand products: responsibility may sit with the company under whose name or trademark the product is designed or manufactured.
  • Imported third-party brands: a German retailer or importer may become responsible where products are sourced from abroad without an intermediary retailer in Germany.
  • Foreign direct sellers: companies established outside Germany that sell packaged products or empty packaging directly to German end users may be required to appoint a German Authorised Representative.
  • Existing LUCID registrations: existing producers do not automatically need a new registration number, but their registration details may need to be reviewed and updated.
  • Brand names: companies must reassess which brands relate to packaging for which they are legally considered the producer.
  • Packaging volumes: quantities reported to LUCID must correspond with the quantities reported to the relevant system operator.

What’s Included

This service covers:

  • 1 legal entity (company / producer)
  • 1 product line or sales channel
  • Germany only (LUCID / ZSVR / German Packaging EPR)
  • Authorised Representative setup support where applicable and accepted by EaseCert

1. GPSR / Product-Safety Status Check

Before proceeding with Packaging EPR, we confirm whether the relevant products have already been certified by EaseCert for the applicable EU product-safety requirements.

Packaging EPR does not replace GPSR or other applicable product-safety obligations. Completing a LUCID registration or appointing an Authorised Representative does not make an otherwise non-compliant product compliant for EU market access.

2. Producer Status Assessment

We assess whether your company is considered the responsible producer for the relevant packaging under the PPWR and German VerpackDG framework.

The review may include:

  • Legal entity and establishment location
  • Brand ownership
  • Private-label and own-brand arrangements
  • Manufacturer relationships
  • Importer relationships
  • German distributors and intermediary retailers
  • Direct-to-consumer sales
  • Marketplace sales
  • Distance-selling arrangements
  • Where products enter the German supply chain
  • Where the packaging is expected to become waste

This producer-status review is important because the manufacturer, seller, importer, brand owner, retailer and Packaging EPR producer are not necessarily the same economic operator.

3. LUCID Registration Guidance

We provide step-by-step support while you create, complete or review your producer account in the official LUCID Packaging Register.

Support may include guidance on:

  • Company master data
  • Producer information
  • Packaging categories
  • Brand information
  • System participation information
  • Authorised Representative information where applicable
  • Review of information before submission

The customer remains responsible for completing any LUCID actions that must legally be performed by the producer itself.

4. Existing LUCID Registration Review

Already registered? You do not normally need to create a second LUCID registration solely because the PPWR and VerpackDG now apply.

Instead, we review whether your existing registration needs to be amended or supplemented.

The review may cover:

  • Producer status under the PPWR
  • Legal entity information
  • Packaging categories
  • Brand names
  • Private-label products
  • Imported third-party brands
  • Authorised Representative requirements
  • System participation status
  • Existing packaging-volume reporting setup

5. Packaging Obligation Assessment

We assess the packaging used in your German sales model and help determine which Packaging EPR obligations apply.

Depending on your business, this may include review of:

  • Sales packaging
  • Grouped packaging
  • Shipment / e-commerce packaging
  • Transport packaging
  • Reusable packaging
  • Packaging subject to system participation
  • Packaging not subject to system participation

The applicable requirements depend on both the packaging type and your role in the supply chain.

6. Brand & Packaging Mapping

We help identify which brand names are associated with packaging for which your company is considered the producer.

This may include guidance for:

  • Own brands
  • Private-label products
  • Imported third-party brands
  • Unbranded packaging
  • Existing LUCID brand entries
  • New brands that need to be added
  • Obsolete or incorrect entries that may need review

7. Dual-System / PRO Contract Requirement

If your packaging is subject to system participation, the customer must conclude a valid agreement directly with an appropriate German dual-system operator or Producer Responsibility Organisation.

A valid German dual-system / PRO contract is a prerequisite for EaseCert's Authorised Representative setup.

Before EaseCert provides its LUCID Authorised Representative ID, the customer must provide evidence showing that an appropriate system participation agreement is already in place.

The evidence should normally identify:

  • The contracting legal entity
  • The relevant German dual-system operator or PRO
  • The applicable contract or participation reference
  • The relevant packaging scope
  • The validity or effective period of the contract

EaseCert does not issue or replace the system participation contract. The customer concludes that agreement directly with the system operator.

Dual-system fees, PRO fees, recycling fees and system-participation charges are not included in the €400 EaseCert fee.

8. Packaging Data & Reporting Setup

We help you establish a practical packaging-data structure for German EPR reporting.

Typical data fields include:

  • SKU or product family
  • Packaging component
  • Packaging material
  • Weight per packaging component
  • Units placed on the German market
  • Total packaging weight by material
  • Relevant brand
  • Responsible producer
  • Relevant system operator

We also provide guidance on aligning the packaging quantities reported to the system operator with the corresponding quantities reported in LUCID.

9. Reporting Templates & Internal Documentation

We provide templates and practical instructions that can be used for internal Packaging EPR administration.

These may include:

  • Packaging material breakdown template
  • Packaging weight calculation template
  • Annual volume tracking structure
  • Planned / forecast volume worksheet
  • Actual volume reporting structure
  • Supplier packaging-data request structure
  • Internal compliance record template

10. Marketplace Readiness Support

We provide practical guidance regarding German Packaging EPR information commonly requested by online marketplaces.

This can include:

  • LUCID registration number readiness
  • Producer identification
  • System participation status
  • Internal records for marketplace verification requests
  • Guidance for Amazon, eBay and other marketplace compliance workflows

A LUCID registration number alone does not necessarily establish complete German Packaging EPR compliance. System participation, reporting and Authorised Representative obligations may also apply.

Authorised Representative Support

From 12 August 2026, certain foreign producers that are not established in Germany may be required to appoint a German Authorised Representative for Packaging EPR purposes.

This may affect foreign companies that sell packaged products or empty packaging directly to German end users, including certain direct-to-consumer and distance-selling businesses.

EaseCert can support eligible customers with the formal Authorised Representative appointment as part of this €400 one-time service, subject to EaseCert's compliance review and acceptance of the case.

There is no annual or recurring EaseCert fee for the standard appointment covered by this service.

Authorised Representative Prerequisite

Before EaseCert can provide its LUCID Authorised Representative ID or accept an appointment:

  • The applicable EaseCert product-safety certification must already be in place
  • The customer's producer status and German Packaging EPR obligations must be assessed
  • The customer must already have a valid German dual-system / PRO contract where system participation applies
  • The customer must provide EaseCert with satisfactory proof of that contract
  • EaseCert must review and accept the case

EaseCert's LUCID Authorised Representative ID is not provided before the required dual-system / PRO evidence has been received and the case has been accepted.

What EaseCert Provides After Acceptance

Once the prerequisite documentation has been received and the case is accepted, EaseCert can:

  • Provide the relevant EaseCert LUCID Authorised Representative ID
  • Support preparation of the written Authorised Representative appointment
  • Guide the customer through the relevant designation process in LUCID
  • Review the appointment information for consistency
  • Accept the Authorised Representative appointment in LUCID where applicable
  • Provide practical implementation guidance relating to the appointment

The precise responsibilities transferred to an Authorised Representative depend on the applicable legal framework and the scope of the written authorisation.

Who Is Likely to Need a German Authorised Representative?

You should specifically request an Authorised Representative assessment if:

  • Your company is established outside Germany
  • You do not have a German establishment or branch that affects your producer status
  • You sell packaged products directly to German end users
  • You sell empty packaging directly to German end users
  • You operate a direct-to-consumer e-commerce model
  • You ship directly from another EU country to German customers
  • You ship directly from a non-EU country to German customers

The precise result depends on the legal entity, supply chain, branding and sales model. EaseCert assesses these facts before accepting an Authorised Representative appointment.

Retailers, Importers & Private-Label Brands – 2026 Responsibilities

The PPWR can change responsibility for certain retailers, importers and brand owners.

Own-Brand / Private-Label Products

If products are designed or manufactured under your company's own name or trademark, your company may bear Packaging EPR responsibility for the associated packaging.

Businesses that previously relied on a supplier, contract manufacturer or packager to handle German packaging obligations should review these arrangements.

Imported Third-Party Brands

If your business sources third-party branded products from outside Germany and makes them available in Germany, your company may become the responsible producer depending on the supply chain and sales model.

Why This Matters

Affected companies may need to:

  • Request packaging weight and material information from suppliers
  • Add additional brands to LUCID
  • Expand an existing system participation agreement
  • Participate additional packaging volumes
  • Update planned or forecast volume reports
  • Maintain supporting packaging records

Who This Service Is For

  • Non-German companies selling packaged goods in Germany
  • Foreign direct-to-consumer brands shipping to German customers
  • Amazon FBA and marketplace sellers targeting Germany
  • eBay, Etsy, Shopify and D2C sellers
  • EU companies selling cross-border into Germany
  • Non-EU manufacturers and brands selling directly into Germany
  • German and foreign importers
  • Private-label and own-brand businesses
  • Retailers affected by PPWR producer rules
  • Companies already registered in LUCID that need a 2026 compliance review
  • Businesses unsure whether they are considered the producer
  • Foreign producers that may require a German Authorised Representative

Price

€400 EUR – one-time fee only

The €400 EaseCert service fee covers the standard Germany LUCID and Packaging EPR support described on this page for one legal entity and one product line or sales channel, including the producer-status assessment, LUCID guidance, packaging obligation review, system participation review and Authorised Representative setup support where applicable and accepted by EaseCert.

No annual EaseCert fee.

No recurring EaseCert subscription.

No separate recurring EaseCert Authorised Representative fee under the standard scope described on this page.

Before EaseCert's LUCID Authorised Representative ID can be provided, the customer must first provide proof of a valid German dual-system / PRO contract where system participation applies.

The following remain separate from the €400 EaseCert fee:

  • Dual-system / PRO contract fees
  • Recycling fees
  • System-participation fees
  • Packaging-volume fees
  • Government or authority fees
  • Periodic or annual declarations
  • Packaging-volume reporting obligations
  • Declaration of Completeness requirements, where applicable
  • Other PRO, recycling-system or third-party charges

Processing Time

Typically 3–5 business days after receipt of the information required for the standard one-entity assessment.

For Authorised Representative cases, processing also depends on receipt and review of satisfactory proof of the customer's German dual-system / PRO contract and completion of the required written appointment documentation.

Complex supply chains, multiple brands, multiple import routes or large packaging portfolios may require additional review.

Service Scope

  • Initial GPSR / applicable product-safety status confirmation
  • PPWR / VerpackDG producer-status assessment
  • Guidance for new or existing LUCID registrations
  • Assessment of packaging categories
  • Brand-name review
  • Private-label and importer responsibility review
  • Assessment of system participation obligations
  • Review of German dual-system / PRO evidence
  • Packaging-material and volume calculation guidance
  • Reporting templates
  • Internal documentation templates
  • Marketplace readiness guidance
  • Authorised Representative requirement assessment
  • Provision of EaseCert's LUCID Authorised Representative ID after case acceptance
  • Support with preparation of the written Authorised Representative appointment
  • Support with the LUCID appointment and acceptance process
  • Identification of additional WEEE or battery EPR questions where relevant
  • Identification of separate PPWR packaging-conformity work where relevant

What’s Not Included

  • German dual-system / PRO membership fees
  • Recycling or system-participation fees
  • Payment of authority or third-party charges
  • Packaging-volume fees
  • Preparation or submission of recurring declarations unless separately agreed
  • Ongoing packaging-volume reporting unless separately agreed
  • Declaration of Completeness preparation or submission unless separately commissioned
  • Automatic monitoring or management of changes to the customer's packaging volumes
  • Full GPSR technical documentation or product-safety assessment unless separately commissioned
  • WEEE registration
  • Battery EPR registration
  • Full PPWR packaging conformity assessment
  • PPWR technical documentation or EU Declaration of Conformity

Customer Responsibilities

EaseCert provides compliance assessment, implementation support, document preparation, registration guidance and Authorised Representative coordination within the agreed service scope.

The customer remains responsible for:

  • Providing correct and complete company information
  • Providing accurate packaging data
  • Maintaining a valid German dual-system / PRO contract where required
  • Paying dual-system, PRO, recycling and system-participation fees directly
  • Providing EaseCert with proof of the applicable system participation agreement
  • Reviewing and approving information prepared with EaseCert support
  • Completing LUCID actions that must legally remain with the producer
  • Submitting required packaging-volume reports and declarations unless a separate service has been agreed
  • Maintaining accurate and current LUCID information
  • Maintaining supporting packaging records
  • Informing EaseCert of material changes affecting the Authorised Representative appointment or producer status

EaseCert is not a recycling company, waste collector, Producer Responsibility Organisation (PRO), dual-system operator or government authority.

Registration & Authorised Representative Process – Step by Step

Step 1: Confirm Product-Safety Status

We first confirm whether the relevant products have already been certified by EaseCert for the applicable EU product-safety requirements.

Product-safety compliance and Packaging EPR compliance are separate. Completing German EPR requirements does not establish GPSR compliance.

Step 2: Determine the Responsible Producer

We review the company structure, brands, sales model, importer relationships and supply chain to determine whether your legal entity is the responsible producer for the relevant packaging.

Step 3: Determine Whether an Authorised Representative Is Required

If your company is established outside Germany, we review whether the German Authorised Representative requirement applies to your sales model.

Step 4: Gather Company & Packaging Information

You provide the relevant information, which may include:

  • Legal company name
  • Registered address
  • Company registration details
  • VAT information
  • Existing LUCID number, if applicable
  • Brand names
  • Product list
  • Sales-channel information
  • Importer / distributor information
  • Packaging materials
  • Packaging component weights
  • Estimated German sales volumes

Step 5: Obtain a Valid German Dual-System / PRO Contract

Where the relevant packaging is subject to system participation, you must conclude a valid agreement directly with an appropriate German dual-system operator or PRO.

This must be completed before EaseCert provides its LUCID Authorised Representative ID.

Step 6: Provide Proof of System Participation to EaseCert

You send EaseCert satisfactory evidence of the valid German dual-system / PRO contract.

EaseCert reviews the evidence together with the producer-status and packaging assessment.

Step 7: EaseCert Case Acceptance

EaseCert reviews the complete case and determines whether the Authorised Representative appointment can be accepted.

Providing documentation does not automatically guarantee acceptance.

Step 8: EaseCert Provides the LUCID Authorised Representative ID

Once the required proof has been received and the case has been accepted, EaseCert provides the relevant LUCID Authorised Representative ID.

Step 9: Prepare the Written Authorisation

EaseCert supports preparation of the written documentation required to establish the Authorised Representative relationship.

The written authorisation should clearly define the applicable responsibilities and appointment scope.

Step 10: Complete the LUCID Appointment

The relevant Authorised Representative information is entered into LUCID in accordance with the applicable procedure.

EaseCert provides implementation guidance and supports the appointment process.

Step 11: EaseCert Accepts the Appointment

Where applicable, EaseCert completes the required acceptance step within LUCID after the appointment information has been properly established.

Step 12: Maintain System Participation & Reporting

The customer must maintain the required German dual-system / PRO contract and ensure that packaging volumes and other required data are reported correctly.

Any PRO fees, system-participation fees, declarations or third-party charges remain separate from EaseCert's €400 one-time fee.

Existing LUCID Registration?

If your company already has a valid LUCID registration, the introduction of the PPWR and VerpackDG does not automatically mean that you need a new registration.

However, you should review whether any information needs to change.

Typical review points include:

  • Has your company become the producer for additional packaging?
  • Has responsibility shifted for private-label products?
  • Are you now responsible for imported third-party brands?
  • Do additional brands need to be added?
  • Have your packaging categories changed?
  • Do you now require an Authorised Representative?
  • Does your system participation agreement cover all relevant packaging?
  • Do packaging quantities reported in LUCID correspond with your system operator data?

Our €400 service can also be used for a structured existing LUCID registration review and Authorised Representative assessment within the stated one-entity / one-product-line scope.

Packaging Information We May Request

To complete the assessment efficiently, please prepare where available:

  • Company legal information
  • Existing LUCID registration number
  • Existing LUCID registration details
  • Brand list
  • Product list
  • Marketplace or website links
  • Product photos
  • Packaging photos
  • Packaging artwork
  • Packaging component breakdown
  • Material information
  • Weight per packaging component
  • Supplier packaging specifications
  • Importer details
  • Distributor details
  • Annual German sales estimates
  • Valid German dual-system / PRO contract
  • Previous packaging reports where available

Electrical Products and Batteries

Packaging EPR is separate from WEEE and battery producer responsibility.

If your products are electrical or electronic, EaseCert can assess whether separate WEEE obligations may apply after the applicable product-safety status has been confirmed.

Read our WEEE Registration Compliance Guide.

EaseCert also offers the WEEE Registration Service for EU Compliance (€500,00 EUR).

Products containing batteries may additionally trigger separate battery EPR obligations.

LUCID Registration Is Not Full PPWR Compliance

LUCID registration and German Packaging EPR address producer responsibility for packaging waste. They should not be confused with complete packaging conformity under the PPWR.

The PPWR separately addresses matters such as:

  • Packaging design
  • Packaging minimisation
  • Recyclability
  • Recycled content
  • Reuse
  • Packaging labeling
  • Technical documentation
  • Declarations of conformity
  • Other packaging sustainability requirements

These packaging conformity requirements are outside the standard €400 LUCID / Authorised Representative service scope.

For businesses requiring a wider packaging assessment, EaseCert offers the PPWR Compliance Service (€500,00 EUR).

You can also read our PPWR compliance guide.

GPSR, EPR and PPWR Are Separate Legal Systems

It is important to distinguish between:

  • GPSR / Product Safety: product safety, risk assessment, technical documentation, testing where applicable, labeling, traceability, Responsible Person requirements, market surveillance, recalls, withdrawals and marketplace compliance.
  • Packaging EPR / LUCID: producer registration, system participation, recycling financing, reporting, environmental fees and waste-management obligations.
  • PPWR Packaging Conformity: packaging design, recyclability, recycled content, minimisation, reuse, labeling, technical documentation, declarations of conformity and other packaging sustainability requirements.

A company can be correctly registered in LUCID and have a valid dual-system contract while still being non-compliant with product-safety or PPWR packaging-conformity requirements.

Why Work With EaseCert?

  • Safety-first compliance approach: product safety is addressed before environmental registration services.
  • Practical implementation support: we translate legal requirements into concrete registration and appointment steps.
  • Producer-status assessment: we review who actually bears Packaging EPR responsibility.
  • Authorised Representative support: eligible foreign producers can receive support with written authorisation and LUCID appointment after the required PRO contract has been verified.
  • Clear pricing: €400 one-time EaseCert fee with no annual or recurring EaseCert fee under the standard scope.
  • Clear division of responsibility: PRO fees, recycling charges, declarations and other third-party costs remain separate.
  • Integrated compliance approach: GPSR / product safety first, followed by EPR / WEEE / Batteries where applicable, and PPWR packaging conformity last.

EaseCert is a compliance assessment and implementation partner. We are not a recycling company, waste collector, Producer Responsibility Organisation (PRO), dual-system operator or government authority.

Important Compliance Notice

EaseCert assists with compliance assessment, document preparation, registration guidance, Authorised Representative setup and implementation support within the agreed service scope.

EaseCert's €400 EUR fee is a one-time fee only. There is no annual or recurring EaseCert fee under the standard scope described on this page.

Where system participation applies, the customer must first enter into and maintain a valid German dual-system / PRO contract and provide proof of that contract before EaseCert's LUCID Authorised Representative ID is issued.

PRO membership fees, recycling fees, system-participation fees, declarations, reporting obligations, packaging-volume charges, government fees and other third-party costs remain separate and are paid or completed directly by the customer where applicable.

EaseCert reserves the right to decline an Authorised Representative appointment where the compliance documentation, product-safety status, system participation, company information or supply-chain structure is not satisfactory.

Official Resources

Need Help With Germany Packaging EPR?

If you are selling packaged products in Germany, importing products into Germany, operating a private-label brand, selling through Amazon or another marketplace, or need a German Packaging EPR Authorised Representative, EaseCert can help assess your producer status and guide you through the applicable LUCID and Packaging EPR requirements.

Price: €400 EUR one time only.

No annual or recurring EaseCert fee.

Important: Where an Authorised Representative appointment is required, you must first provide proof of a valid German dual-system / PRO contract. Once that evidence has been received and the case has been accepted, EaseCert can provide its LUCID Authorised Representative ID and support the written authorisation and LUCID appointment process.

For a wider European overview, see our EU Packaging EPR Compliance in 2026 guidance.

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