Packaging EPR for Merchandise: Who Registers in LUCID?
Extended producer responsibility for packaging means the company that first makes packaged goods available in a country pays for collecting and recycling that packaging, and in Germany it must register in LUCID first.
This guide explains who that company is when clubs, federations and brands sell merchandise, what registration and system participation involve, and which dates matter before the end of 2026. It is based on the German implementing law, the guidance of the German packaging register and the European Commission, and it is an explainer, not legal advice.
Key Takeaways
- Germany’s Verpackungsrecht-Durchführungsgesetz (VerpackDG) entered into force on 12 August 2026, the day the EU packaging regulation PPWR started to apply, and replaced the old Verpackungsgesetz.
- The company that must register is the producer. For merchandise made to a club’s own design under its crest, that is likely the club. For a German licensee’s own licensed products, it is the licensee. Clarify it for every range and record the result in writing.
- Registration in LUCID is free and must be done by the producer itself. Packaging that ends up with households, including every carton used to ship orders to end customers, also needs participation in a dual system.
- Shops, webshops and fulfilment providers may not sell or handle packaged goods from an unregistered producer. Fines go up to 100,000 euros, and up to 200,000 euros for missing system participation.
- Existing registrations stay valid, but changes must be reported by 12 November 2026, and system participations made under the old law expire on 31 December 2026 at the latest.
In This Article
- Key Takeaways
- How Does Packaging EPR Work in Germany?
- Who Counts as the Producer of Merchandise Packaging?
- What Must the Producer Do in Germany?
- What Happens If a Supplier Is Not Registered?
- What Changes for Merchandise Sold Into Other EU Countries?
- Which Deadlines Matter Before the End of 2026?
- What Should Clubs and Brands Ask Their Suppliers?
How Does Packaging EPR Work in Germany?
What Is Extended Producer Responsibility for Packaging?
Extended producer responsibility, or EPR, makes the business that first makes packaged goods available pay for collecting and recycling the packaging once it becomes waste. The European Commission’s guide to packaging EPR for small businesses describes it in similar terms and points out that businesses must keep following the national registration rules of each country where their packaging is likely to become waste.
The German producer register is LUCID, run by the Zentrale Stelle Verpackungsregister (ZSVR), the foundation that the VerpackDG names as the competent authority for the producer register under Article 44 of the PPWR. Since 12 August 2026 the German rules sit in the VerpackDG, and the old Verpackungsgesetz only applies to the period before it.
Who Counts as the Producer of Merchandise Packaging?
The PPWR uses two roles that are easy to confuse. The manufacturer is the company that makes packaging, or has it made, under its own name or brand. It handles the declaration of conformity and the labelling, which our guide to who the packaging manufacturer is under PPWR covers. The producer is the role that carries EPR: registration, system participation and reporting.
The ZSVR’s page on who is manufacturer and who is producer describes the producer as the manufacturer, importer or distributor that first makes packaging available in the country where it becomes waste. It adds two rules that matter for merchandise: a manufacturer based in that country is also the producer, and licensees can be manufacturers too. If the manufacturer is based abroad, the first company in the domestic supply chain is the producer. This applies to every sales method, including distance selling.
For licensed merchandise, that gives four common cases:
The second case is the one to settle early. When an agency imports goods made to a club’s design in its own name, it can be argued that the agency first makes them available in Germany, while the ZSVR’s rule points to the club as a German manufacturer. Neither the PPWR text nor the ZSVR guidance settles that exact case, so the result should be clarified and recorded in the order confirmation.
Shipping packaging needs its own check. The ZSVR’s page on mail order and online retail states that packaging used for shipping is always subject to system participation, including cartons, mailer bags and fill material such as tissue paper, and it distinguishes these main cases:
- Cartons printed with the club’s brand make the club both manufacturer and producer.
- For complete, unbranded cartons that are ready to use when they reach the club, the producer is the company that first makes them available in Germany, such as their maker, importer or wholesaler.
- A club that combines carton, tape and fill material into the shipping packaging itself becomes manufacturer and producer of that packaging.
- A club that adds tape or fill material to a complete carton must check whether this can affect recyclability; if so, it becomes manufacturer and producer.
What Must the Producer Do in Germany?
1. Register in LUCID before the first sale. Section 6 of the VerpackDG requires registration before packaging is first made available. The data includes the company details and tax number, a person authorised to represent it, the brand names it sells under, and the types of packaging it places on the market. The ZSVR says registration costs nothing. Under section 5, a producer may commission a third party to carry out most of its duties, but it stays responsible, and it may not hand over the registration itself or its data reports.
2. Join a dual system for household packaging. Section 7 obliges producers of packaging that typically ends up with private households to take part in a system before selling it. Section 3 treats comparable places like households, and the law lists sports stadiums among them. Gift boxes, blister cards and polybags that fans take home are typical examples, and so is shipping packaging sent to end customers.
3. Report the same data to the system and to LUCID. Material and weight go to the system and, with the registration number, to the ZSVR. A producer that placed less than 10 tonnes of such packaging on the German market in the previous year reports to LUCID once a year instead, by 1 June of the following year. The figures still go to the system.
4. Check whether a declaration of completeness is due. From 80 tonnes of glass, 50 tonnes of paper and board or 30 tonnes of other materials a year, section 10 requires an audited declaration by 15 May. Check the figures every year. The ZSVR can also demand a declaration below the thresholds.
For buyers, the useful part is public: the ZSVR publishes every registered producer with its brand names in the public LUCID register, so a club can look up a supplier in a few minutes.
What Happens If a Supplier Is Not Registered?
Section 13 of the VerpackDG turns registration into a condition for selling. A producer may not make packaging available in Germany unless it is properly registered, and may not make household packaging available without system participation. The same section forbids distributors to make available packaged goods from a producer that is not registered or has no system participation, and forbids fulfilment providers to store, pack or ship goods from an unregistered producer. In Germany, the ZSVR adds, online platforms must obtain the producer’s registration details before offering its products.
Under section 66, failing to register or selling despite the ban can be fined up to 100,000 euros, and missing system participation up to 200,000 euros. For a club, the practical risk is less the fine than a stopped product line: a shop or a fulfilment partner that finds no registration has to stop handling the goods.
What Changes for Merchandise Sold Into Other EU Countries?
The PPWR makes a seller that ships directly to end users in another member state the producer in that country, whether it is based in the EU or not. A German club selling its webshop range to fans in Austria or the Netherlands is therefore treated as a producer there and has to follow that country’s registration rules.
The Commission’s small-business guide says that since August 2026 every member state requires an authorised representative for EPR from producers without an establishment there. It has proposed suspending this requirement for small businesses, and while the European Parliament and the Council examine the proposal, it has asked member states not to sanction operators. The same guide says that, at EU level, online platforms are not yet required to ask for an EPR registration number; that follows once uniform EU rules for registration and reporting are in place, and member states then have 18 months to adapt their registers. Germany already requires the check. Until then, each country’s own register applies.
Germany applies the same logic in the other direction. A seller based abroad that ships packed products directly to end users in Germany must appoint an authorised representative for EPR in Germany, with a written mandate in German, but must still register in LUCID itself.
Which Deadlines Matter Before the End of 2026?
The transitional rules in section 68 of the VerpackDG set three dates:
An existing LUCID number can look as if nothing needs doing, so the November date deserves a calendar entry. With the role split under the PPWR, the brand names, packaging types and declarations in a registration may no longer match who is now the producer.
What Should Clubs and Brands Ask Their Suppliers?
These questions settle most cases before a product line goes on sale:
- Who is manufacturer and who is producer in Germany for each packaging item, and is that written into the order?
- What is the LUCID registration number, and does the public register list the brand names on the products?
- Which dual system covers the household packaging, and for which period?
- Who registers the shipping cartons and fill material for webshop orders with a dual system?
- If the range is sold to fans in other EU countries, who registers there and who acts as authorised representative?
Am Ball, for example, is registered in LUCID and holds a Der Grüne Punkt licence for the packaging it places on the market as producer; a supplier should be able to say this clearly for each item. The same questions are worth asking any supplier, alongside the points in our guide on how to choose a merchandise manufacturing partner.
Frequently Asked Questions
Does a club have to register if its crest is on the packaging?
It depends on whose name or brand the product carries and who first makes it available in Germany. If the product and packaging are made to the club’s order, the club is likely the manufacturer, and a German manufacturer is also the producer. If a licensee based in Germany sells its own licensed product, the licensee is usually the producer. A club that imports directly, or ships in its own branded cartons, is the producer for that packaging.
Is LUCID registration enough on its own?
No. Packaging that typically ends up with households, which includes most merchandise packaging and all packaging used to ship orders to end customers, also needs participation in a dual system and regular quantity reports. Registration is only the first step.
Can an agency register in LUCID on our behalf?
No. The VerpackDG lets producers commission third parties to carry out most EPR tasks, but registration and data reports stay with the producer. Producers based abroad need an authorised representative in Germany, who reports in its own name, but they still register themselves.
What if we sell only a few hundred items a year?
The German duties still apply, because the VerpackDG has no general exemption for small quantities. The relief is in the reporting: below 10 tonnes a year in Germany, the report to LUCID is made once a year by 1 June, and a declaration of completeness is only needed once a material threshold is reached.
Are online marketplaces checking registration?
In Germany, yes. The ZSVR says online platforms must obtain the producer’s registration details before offering its packaged products, and fulfilment providers must first ask for missing or wrong details to be corrected and then suspend their services if nothing changes. Elsewhere in the EU, the harmonised requirement follows once the new registers are in place.
Conclusion
Packaging EPR depends on whose name or brand the packaging carries and who first makes it available in a country. For a German licensee’s own products that is the licensee. For products made to a club’s order under its crest, it is likely the club, which is why the role should be clarified for every range. For direct imports it is the club itself, for webshop shipping packaging it depends on the cartons, and the 12 November 2026 check and the expiry of old system participations on 31 December 2026 are the dates to plan around.
If you are preparing a merchandise range and want to go through these questions for your packaging, write to eg@amball.com.
