Missed the LUCID registration? What to do now

Germany’s Packaging Law Implementation Act (VerpackDG) has changed who counts as a producer. Anyone who became subject to registration for the first time as a result had to register in the LUCID packaging register by 12 September 2026. Anyone already registered stays registered but must bring their details up to date by 12 November 2026. This article explains what the transitional rule in Section 68(2) VerpackDG requires, how registration works and what to do if the deadline has already passed.

Legal basis

Sections 6 and 68(2) VerpackDG

Competent body

Central Agency Packaging Register (ZSVR), register LUCID

Newly obliged

Deadline 12 September 2026, now passed

Already registered

Check and update details by 12 November 2026

Cost

Free of charge, but only by the producer itself

Without registration

Sales ban and fines of up to €100,000

What the transitional rule requires

Since 12 August 2026 the VerpackDG has replaced the former Packaging Act. The register is the same, but who must register now follows the PPWR definition of producer. Section 68(2) VerpackDG governs the transition for three groups. Which deadline applies to you depends on whether you were already obliged to register under the old law.

Who is newly obliged to register

Under the former Packaging Act, the producer was whoever filled packaging with goods and first placed it on the market. The VerpackDG instead follows Art. 3(1)(15) PPWR: the producer is whoever first makes packaging or packaged products available in Germany. The ZSVR sums this up as: the producer is usually the first company in the domestic supply chain. This shifts the group in both directions. According to the explanatory memorandum, newly obliged are in particular:

• Companies that first make packaging available in Germany without filling it themselves. What counts is no longer filling, but first making available.
• Companies that unpack packaged products without being the end user, where there is no other producer. The memorandum gives the example of an importer taking goods out of transport packaging and disposing of it.
• Foreign companies supplying transport, service or primary production packaging directly to end users in Germany. They also need an authorised representative.

Conversely, some previously registered companies are no longer producers, for example retailers buying packaged goods from a German supplier. The ZSVR can revoke such registrations. If in doubt, check your role for each packaging item and supply route before registering or deregistering. The ZSVR provides guidance on distinguishing manufacturer and producer.

How to meet the registration duty

Registration takes place online in LUCID on the ZSVR website and must be completed before first making packaging available, or before unpacking where that applies. It is free of charge. You may not hand it to a service provider: registration and data reports are done by the producer itself (Section 5(1), second sentence, VerpackDG). Under Section 6(2) you must provide:

• Name, address and contact details as well as the European or national tax number.
• A natural person authorised to represent the company, the national identification number and an email address.
• The brand names under which you first make packaging available in Germany.
• The packaging types, split into packaging subject to system participation, other packaging and single-use beverage packaging subject to deposit.
• Declarations on how you meet your producer responsibility, for example via a compliance scheme or sector solution, and that all details are correct.
• Without an establishment in Germany: name and contact details of the authorised representative and the written mandate in German (Section 5(2) and (4)).

Once confirmed, the ZSVR issues a registration number and publishes your entry in the public producer register. You use this number to join a compliance scheme for packaging subject to system participation (Section 7(1)) and then also report the volumes to the ZSVR (Section 9).

Missed the deadline: what to do now

The deadline cannot be extended after the fact, but registration can be completed at any time. The sooner you do it, the shorter the breach lasts. The steps in this order:

• Clarify your role. Check for each packaging item whether you are a producer under Art. 3(1)(15) PPWR. With clear supply routes this takes a few minutes and avoids a registration that is not needed at all.
• Register immediately. Registration in LUCID is free and can be done in one go, provided company data, brand names and packaging types are to hand.
• Supply nothing until confirmed. Without registration you may not make packaging available or unpack it in Germany (Section 13(1)). Distributors and fulfilment service providers may not sell or handle your goods either (Section 13(3) and (4)).
• Catch up on scheme membership and reports. Register packaging subject to system participation with a compliance scheme using your registration number and report the volumes to the ZSVR. Many schemes also accept volumes already supplied. That does not undo the breach, but it removes the economic benefit on which a fine is based.
• Document it. Record when you noticed the gap and when you completed each step. This helps if the authority asks.

Already registered: check by 12 November

Anyone registered under the former Packaging Act does not need to register again. Changes normally have to be reported without delay, but Section 68(2) allows three months for the switch to the new law. By 12 November 2026, check in particular:

• Are you still a producer under the new definition, and for which packaging?
• Do the packaging types you declared match the new breakdown?
• Are brand names, authorised person, tax number and email address up to date?
• Without an establishment in Germany: has an authorised representative been named? LUCID alerts foreign producers to a missing mandate after login.
• Is your declaration on producer responsibility still correct, for example after switching from a scheme to a sector solution?