EPR in Germany runs through four separate registers rather than one. By the end of this guide you will know which of them your products trigger, who may file with each, and what falls due across a German year.
It is written for a producer or importer selling into Germany that wants the whole picture rather than one register at a time. Germany replaced its packaging law on 12 August 2026, so some of what you set up before that date now needs a second look.
What you need before you start
Five things decide almost every answer below, and gathering them first saves you from redoing a registration.
- A product list broken down to materials and weights. Every register asks for mass, not units, and the packaging register asks for it in kilogrammes to three decimal places.
- The brand names you sell under in Germany. Both the packaging register and the electronics register are organised by brand, and a brand you leave out is a brand you are not registered for.
- Your European or national tax number. It is a required field in the packaging registration.
- Whether you have an establishment in Germany. This single fact changes who is allowed to file, and it changes differently for each register.
- How your goods reach the German buyer. Shipping to a German business that resells is a different position from shipping direct to a German household.
Why Germany splits into four registers
Most countries run extended producer responsibility (EPR) through one register with one annual filing. Germany runs four, under four separate laws. Only three bodies collect them, because one of those bodies runs two of the four registers.
They do not talk to each other. A company selling a boxed electrical appliance with a battery inside sits in three of them at once, files three times, and gets no warning from any of the three that the other two exist.
The table below lines up all four registers in one view, with what triggers each duty, the law it comes from and the body that collects it.
| What you place on the German market | The German law | Where you register |
|---|---|---|
| Packaging and packaged goods | VerpackDG, in force since 12 August 2026 | LUCID, run by the Zentrale Stelle Verpackungsregister |
| Electrical and electronic equipment | ElektroG | stiftung ear |
| Batteries | BattDG, in force since 7 October 2025 | stiftung ear |
| Single-use plastic products | EWKFondsG | DIVID, run by the Umweltbundesamt |
The four sections under it then take one register at a time in the same order, covering who runs it, how it wants you registered and what it expects from you once you are in.
1. LUCID for packaging
LUCID is the German packaging register, run by the Zentrale Stelle Verpackungsregister, the public authority that supervises packaging law. Registering is free and you do it yourself, before the first packaged product reaches a German buyer.
It is a public register rather than an internal one. Your company name, your brand names and your registration number are published where anyone can look them up, which is how marketplaces check you.
LUCID also does something the other three do not. It receives your packaging volumes a second time, after you have already reported them to your dual system, and compares the two figures against each other.
2. stiftung ear for electrical equipment
stiftung ear is the authority that runs Germany's WEEE register under the ElektroG, on behalf of the Umweltbundesamt. You register brand by brand and device type by device type, not company by company.
What you get back is a WEEE-Reg.-Nr. DE, and it is not just a filing reference. You have to quote it whenever you offer equipment for sale and on your invoices.
If your equipment can end up in a private household, stiftung ear also holds an insolvency-proof guarantee from you, sized to cover a year of what you put on the market. Equipment sold only to businesses does not need one.
3. A second stiftung ear register for batteries
Batteries run through the same body and a completely separate registration. The BattDG replaced the old battery act on 7 October 2025 to implement the EU battery regulation, and the Umweltbundesamt again put stiftung ear in charge.
You register per brand and per battery category. Registering is not the whole duty here either, because you must also join an approved producer responsibility organisation for every battery category you sell.
Being registered for electronics does nothing for your batteries, and the reverse is equally true. Two registrations, one body.
4. DIVID for single-use plastics
DIVID is the odd one out, because it is not a recycling scheme at all. It is a fund, run by the Umweltbundesamt under the single-use plastics fund act, and what you owe it is a levy rather than a recycling fee.
You register on the platform before you start selling, then report once a year and pay according to what you reported. The money is paid back out to public waste bodies, which claim the costs those products cause them.
What Germany now means by manufacturer and producer
Two words changed meaning on 12 August 2026 and the German authority now uses them precisely, so it is worth being sure which one you are.
A manufacturer is responsible for the packaging itself meeting the EU rules, through technical documentation and a declaration of conformity.
A producer carries extended producer responsibility in the country where the packaging becomes waste, which means registering, paying for recycling and reporting.
The same company is often both. In a cross-border supply chain it may be only one, and the four registers above are a producer's duty.
Textiles are the gap
The EU has made producer responsibility for textiles mandatory and Germany is drafting its own act, but there is no German textile register to join yet.
So a clothing brand selling into Germany deals with the packaging around the garment and not the garment itself. Our page on textiles in Germany tracks where that has got to.
How to manage EPR in Germany step by step
The order below matters. Each step tells you what to gather, what the register does with it, and how you can tell the step actually landed.
Step 1. Work out which of the four duties your products trigger
Go through your catalogue once and tag every product against the four laws above. Be literal about it. A cordless drill sold in a printed box with a lithium battery inside triggers packaging, electronics and batteries, and each of those is a separate registration under a separate law.
The trap here is treating a product as belonging to one stream. The German registers do not divide products between them, they divide duties, and one product can carry three.
Two questions settle the packaging side. Are you the first company to make this packaging available in Germany, and does the packaging typically end up as waste with a private household? The second question decides whether you also need a dual system, which is Step 2.
Step 2. Register for packaging and join a dual system
Registration with LUCID comes before anything else reaches a German shelf. The law requires it before you first make packaging available, it is free, and you do it yourself in the register's own portal.
You enter your company details, your tax number, a person authorised to represent you, your brand names and the packaging types you place on the market.
If your packaging typically ends up with private households, registering is only half the job. You must also join one or more dual systems before the packaging is made available, and the system will confirm your participation in writing.
Then the same numbers go in twice. Whatever volume you report to your system operator has to be reported again to LUCID under your registration number, and the register compares the two.
Producers who made available under 10 tonnes in the previous year get a lighter version and can bundle everything into one year-end report by 1 June instead.
For the mechanics of the registration screen itself, our guide to registering with the LUCID packaging register walks the form field by field.
When the register entry appears in the public producer register, which updates once a day, that half is done.
Step 3. Register electronics and batteries with stiftung ear
Both electronics and batteries are handled by stiftung ear, and both work the same way. You register per brand and per type before you offer anything, and you get a number back.
For electronics that number is the WEEE-Reg.-Nr. DE, and you have to state it when you offer equipment and on your invoices. Batteries are registered per brand and battery category, and you must also join an approved producer responsibility organisation for each category you sell.
Here is the part that catches almost everyone, and it is the reason this page exists. Who is allowed to file is different for each German register.
If you have no establishment in Germany, packaging law now obliges you to appoint an authorised representative, but registration in LUCID is carved out of what that representative may do. You register personally, and no exemption is possible.
Electronics law does the exact opposite. A foreign company cannot register itself at all, and the German-based representative registers on its behalf. Batteries follow the electronics pattern, with the representative named in the statute.
So the same company can end up filing one German registration with its own hands while being legally barred from filing the next one.
Our guide to appointing an EPR authorised representative covers what the mandate has to say, and the stiftung ear register page sets out what each of its two registers wants, and the authority publishes its own guidance in English for both.
One more thing separates electronics from everything else. If your equipment can be used in private households, you have to show an insolvency-proof guarantee when you register, sized to cover a full calendar year of what you place on the market. Equipment sold only to businesses does not carry it.
Step 4. Register for the single-use plastics fund if it applies
Germany charges a separate levy on single-use plastic products, and it sits outside the packaging system entirely. The register is DIVID, run by the Umweltbundesamt, and you register before you start the activity rather than before a deadline.
It catches more companies than expected because it follows the product, not the industry. Food containers, beverage containers and cups, lightweight carrier bags, wet wipes, balloons and tobacco filters all fall in. A café chain, a cosmetics brand shipping wipes and a drinks producer can all be caught by the same law.
Once you are in, you report annually by 15 May, broken down by product type and mass in kilogrammes for the previous calendar year, and the levy follows from those figures.
The report normally has to be checked and confirmed by a registered expert or a qualified auditor before you file it. Producers placing under 100 kg a year on the market are excused that check, though the agency can still ask for it.
The DIVID register page covers what the platform asks for, and single-use plastics in Germany sets out the scope in more detail. Registration itself happens on the Umweltbundesamt's own platform.
Step 5. Put the German year on one calendar
Four registers means four rhythms, and they do not line up. Electronics is the demanding one, because quantities placed on the market are reported per device type every month, by the 15th of the following month, and a month with no sales is still reported as zero. Equipment sold only to businesses reports once a year instead, by 30 April.
Packaging runs on three dates. A planned volume report for next year can only be filed up to 31 December of this year.
The actual volumes for last year go in as a year-end report up to 1 June, and companies over the volume thresholds file an audited declaration of completeness by 15 May. Those thresholds are 80 tonnes of glass, 50 tonnes of paper and cardboard, or 30 tonnes across the other materials.
Single-use plastics shares the 15 May date. Batteries are the odd one out, because the annual figures go to your producer responsibility organisation rather than straight to the authority, and the organisation and you notify the authority of the same numbers at the same time.
Put every one of those on a single calendar with an owner against each. Nothing in the German system reminds you, and the monthly electronics report is the one that quietly lapses first.
What changed on 12 August 2026 and the dates that follow
The PPWR and the German VerpackDG together replaced the old Verpackungsgesetz on that date, and the register has set out what that means for producers.
Registration, system participation and data reporting all survived, but the rules about who has to do them changed, and two new duties arrived with dated transition periods.
| Date | What has to happen by then |
|---|---|
| 12 September 2026 | Producers newly caught by the registration duty, who were not obliged to register under the old law, register with LUCID |
| 12 November 2026 | Producers already registered under the old law make any changes their entry now needs |
| 31 December 2026 | System participation agreements entered into before 12 August 2026 stop running |
| 31 October 2027 | Other producer responsibility organisations need authorisation from the ZSVR |
| 31 December 2027 | Producers of packaging not subject to system participation need their own authorisation from the ZSVR |
If the September date has already passed and you were newly caught by it, register now rather than waiting for the next milestone. The German register treats a late registration as a live registration, and the alternative is a distribution ban on your goods.
The two authorisation dates in 2027 are the genuinely new obligation. Producers of packaging that is not subject to system participation, transport packaging being the common case, will need the ZSVR to authorise them before they can keep making that packaging available.
That authorisation carries conditions and a fee. It is far enough out to plan for and close enough to put in next year's budget.
Where Repax fits in a German filing year
Run through what Steps 1 to 5 actually cost you in a year. The same product data gets cut four different ways for four different bodies, in four different shapes, on dates that never coincide. Most companies rebuild those cuts by hand each time, out of a spreadsheet that one person maintains.
That rebuilding is the part software removes. Repax Core holds one structured spec per product, broken down to materials, components and weights, with sales volumes pulled in from your commerce integrations or order imports.
From that single record it generates the report in the shape each filing wants. Documentation attaches to the product it belongs to, which is what an auditor asks for when a declaration of completeness gets checked.
Try Repax Core for free - no card required Describe your products once and Core builds the report each market and scheme expects. Try it freeBe clear about the boundary, because German law draws it anyway. Core prepares the numbers, it does not submit them and it will not obtain your registration numbers.
For packaging that is not a product limitation but the law, since registration and data reports cannot be handed to a third party at all. For electronics and batteries, the submission stays with you or your appointed representative.
Common mistakes when managing EPR in Germany
Below are the six that come up most often, and every one of them starts with a rule that is correct for one German register being applied to the next.
- Assuming one authorised representative covers everything. A packaging representative cannot register you with LUCID, and an electronics representative has no standing at DIVID. The appointments are separate and so are the mandates.
- Registering the company but not every brand. Both the packaging and the electronics registers work brand by brand. A brand missing from the entry is unregistered, whatever the company status says.
- Reporting to the dual system and stopping there. The same volumes have to reach LUCID separately, and the register reconciles the two figures.
- Skipping the monthly electronics report in a quiet month. A zero month is reported as zero, not left blank.
- Treating the single-use plastics levy as a packaging matter. It is a different law, a different register and a different authority, and being fully compliant on packaging tells you nothing about it.
- Leaving a pre-August 2026 registration untouched. The law changed what has to be in the entry, and the duty to bring it up to date sits with the producer.
Frequently asked questions about managing EPR in Germany
A few questions come up on almost every German setup.
How long does this take?
Plan for a few weeks rather than a few days. The packaging registration itself is same-day, but a battery registration counts as granted twelve weeks after complete information is filed, and appointing a representative adds a contracting step before anything else can start.
Do I need a German company to sell into Germany?
No. German EPR duties apply wherever your company is based. Having no establishment in Germany does change who files, though, because it makes an authorised representative mandatory for packaging, electronics and batteries.
Can one authorised representative cover all four German registers?
Only if you appoint them separately for each. Packaging allows just one representative per producer and still bars them from the registration itself, while electronics and batteries need a representative based in Germany who registers on your behalf.
What happens if I sell in Germany without registering?
The goods stop moving. An unregistered producer may not place the goods on the market, and distributors, marketplaces and fulfilment providers are separately barred from selling, storing or shipping them for you.
Can Repax file with the German registers for me?
No, and for packaging nobody can. Core builds the product record and generates the reports each German filing expects, then you or your appointed representative submit them through the register's own portal.
