How to register for EPR in Germany in 2026

By the end of this guide your company will hold every registration Germany requires under extended producer responsibility (EPR) for packaging, electronics and batteries, with the right party filing each one, whether you are established in Germany or sell into it from abroad.

How do I register for EPR in Germany?

Germany has three separate EPR registrations, one each for packaging, electronics and batteries, and they sit with two different bodies.

• Packaging is registered in LUCID, run by the Zentrale Stelle Verpackungsregister (ZSVR), and you file that one yourself.
• Electronics and batteries are two separate registrations with stiftung ear. A company with no German establishment files both of those through a German authorised representative.

Every registration must exist before the first product is made available in Germany, and each one ends in a registration number you show to marketplaces or state on your invoices. The six steps below take the three registrations in the order their waiting times set.

What to gather first

Before you open any of the registers, gather these five company details and documents.

1. A tax number the registers accept

   LUCID takes a VAT identification number, a business tax number or a personal tax number.

2. A natural person authorised to represent the company

   Every German register asks for one.

3. Your brand names

   Every brand name you place products under in Germany. Packaging and electronics are registered brand by brand.

4. A product list sorted by stream

   Count the batteries built into your devices as batteries.

5. A mandate for a German representative

   A written German-language mandate for an authorised representative, signed by both sides, if you have no German establishment.

The one question that decides your whole route

From abroad, the answer differs per register:

• LUCID, packaging. You register yourself, and nobody else may do it for you.
• stiftung ear, electronics and batteries. Your German authorised representative registers.

Three registers and three different answers to who files

EPR registration is national everywhere in the EU, and how to register for EPR in Europe sets out that frame. Germany then splits it further.

Across EPR in Germany the duties most producers trigger sit in three registrations, and a webshop selling a packaged device with a battery inside touches all three. What catches producers is not the number of registers but who is allowed to file each one from abroad.

Below are Germany's three registrations side by side, with fees as published in September 2026.

Both laws behind the packaging and battery rules are recent. The VerpackDG replaced the VerpackG on 12 August 2026 and made a representative mandatory for packaging producers without a German establishment, while keeping the LUCID entry itself personal to the producer.

The BattDG came into force on 7 October 2025 and requires every battery producer to join an Organisation für Herstellerverantwortung for each battery category, and the registration asks for that organisation's number.

A 6-step guide to EPR registration in Germany

This guide takes you from the first check, whether Germany counts you as the producer, to holding every registration number you need. The steps run in the order the waiting times set, and each one ends with what you should have in hand before you move on.

Step 1. Confirm Germany counts you as the producer

All three German laws point at whoever first makes a product available in Germany, per stream, with no volume threshold. For packaging that is the PPWR definition applied by § 6 of the VerpackDG.

You are the producer if you are established in Germany and place packaged products there for the first time, or established anywhere else and ship them directly to German end users.

For electronics it is the first offer per brand and type of equipment (§ 6 ElektroG). For batteries it is the first time a battery is made available per brand and category (§ 5 BattDG), the battery inside your device included.

You are done when every product line has a yes or no against each stream. A packaged laptop with a lithium cell is three yeses. A T-shirt in a polybag is one.

Step 2. Work out which registers you owe

Each yes maps to one registration. Packaging goes to LUCID, run by the ZSVR, before the first packaged product is made available.

Electronics go to stiftung ear, one registration per brand and type, before the first unit is offered. Batteries go to stiftung ear as a second, separate registration per brand and category, and joining a producer responsibility organisation does not replace it.

You are done with the list of registrations you owe. The laptop owes three, in two portals, under three laws. Any other stream you sell into is in the table further down this page.

Step 3. Decide who files each one

Established in Germany. You register all three in your own name and need no representative.

Selling from abroad. You file LUCID yourself and your German authorised representative files both stiftung ear registrations. The representative is appointed in writing, in German, and named inside your LUCID registration.

You are done when each registration has a name against it, yours or your representative's. If you are still choosing a representative, how to appoint an EPR authorised representative walks the appointment.

Step 4. Gather what each register asks for

Each portal opens an application only when the data is complete, so collect it register by register.

1. LUCID asks for your company details and tax number, the representative and its mandate where you must have one, a natural person who represents you, every brand name you place packaging under, and your packaging split into the three groups § 6(2) of the VerpackDG names.
2. stiftung ear, electronics asks for an ear-Portal account, the brand and type of each piece of equipment, and proof of an insolvency-safe guarantee for anything that can end up in a private household.
3. stiftung ear, batteries asks for the brand and battery category, the chemical composition of every battery, and the OfH number from the Organisation für Herstellerverantwortung you have joined for that category.

Two of those have to exist before you apply. Arrange the guarantee and join the organisation first.

Step 5. Register in the order the waiting times set

The three registrations take minutes, weeks and up to twelve weeks (the table near the top has each one), so start with the slow ones.

1. Appoint the representative if you need one. Both stiftung ear registrations wait on it.
2. Join an Organisation für Herstellerverantwortung for each battery category and collect the OfH number.
3. Apply in the ear-Portal for electronics and batteries. The registration order arrives by email with your WEEE-Reg.-Nr. DE and Batt-Reg.-Nr. DE, and nothing ships until then. Recurring fees follow the one-off registration fee.
4. Register in LUCID yourself at lucid.verpackungsregister.org. Your number, DE followed by 13 digits, arrives by email within minutes. The LUCID guide walks the form.
5. Sign the dual-system contract for your household packaging. It needs the LUCID number and must exist before the first parcel.

You are done with three registration numbers, each held by the party the law names.

Step 6. Do what each registration makes due next

Each number starts a clock, and the three clocks run at different speeds.

1. Packaging. Report the same volumes to LUCID as to your dual system, straight after each system report or by 1 June of the following year under ten tonnes, and file the audited declaration of completeness by 15 May once you pass 80 tonnes of glass, 50 of paper and board or 30 of other materials.
2. Electronics. Report quantities per type monthly by the 15th and annually by 30 April, renew the guarantee proof each year, and put your WEEE-Reg.-Nr. DE on offers and invoices.
3. Batteries. Report the battery category and mass placed to your organisation each year, and it notifies the authority together with you.

The German year that follows is its own guide. How to manage EPR in Germany runs it register by register, the reports included.

The other streams Germany regulates

Beyond packaging, electronics and batteries, Germany runs producer duties for five more streams.

Below is the register each one runs through, so you can rule them in or out in one pass.

One product record behind three registrations

There are two ways through the work above, and both rest on the same product data.

Run the filings yourself

Every step above is data work before it is filing work. The packaging split by type and material, the equipment by brand and type, the batteries by brand, category and chemistry, and then the same figures again in the shape each register wants them reported.

Repax Core holds one structured record per product, broken down to its materials and components, takes your sales data in through integrations or order imports, and builds the per-register cut from it.

The LUCID volume report, the monthly stiftung ear quantities and the battery masses your organisation asks for come out of the same record.

Or hand the filings over

If you would rather not run them yourself, Repax Comply is the managed route, linked at the top of this guide. Producers register and report through Repax market by market, with an authorised representative appointed where the country requires one.

One honest edge survives that, and it is a German one. § 5 of the VerpackDG keeps the LUCID registration personal to the producer, so that entry stays yours whoever you work with. Comply carries everything around it, and both stiftung ear registrations in full.

For the tools that hold German register data side by side today, the best German EPR software in 2026 ranks them.

6 common mistakes when registering for EPR in Germany

Below are the six mistakes producers make most often when they register in Germany.

1. Handing LUCID to a provider

   Letting a service provider create the LUCID entry. Under § 5 of the VerpackDG a service provider can take over neither the registration nor the data reports. An authorised representative can take over the data reports and everything else, but never the registration.

2. Stopping at the LUCID number

   Treating the LUCID number as the end of the packaging duty. The dual-system contract and the matching data reports follow from it, and marketplaces check the number because the law makes them.

3. Reading the deposit as packaging EPR

   Treating the bottle deposit as your packaging registration. Deposit-bearing single-use beverage packaging is declared inside the LUCID registration under § 6(2) of the VerpackDG, and the deposit is a separate return system.

4. Skipping the battery organisation

   Applying for a battery registration before joining an Organisation für Herstellerverantwortung. The portal asks for the OfH number, and the organisation has to confirm it before the decision issues.

5. Counting a device as one registration

   Treating a device with a built-in battery as one registration. It is two, per brand and type for the equipment and per brand and category for the battery.

6. Working from the old law

   Still working from the VerpackG. Since 12 August 2026 the representative is mandatory for producers without a German establishment, producers deemed registered have until 12 November 2026 to update their entry, and the old section numbers no longer exist. The ZSVR's own summary of what changed on 12 August 2026 is the place to reset from.

Frequently asked questions about registering for EPR in Germany

Below are the five questions producers ask most often about registering for EPR in Germany.

How long does this take?

LUCID emails its number a few minutes after you submit. stiftung ear normally takes three to four weeks on a complete electronics application, and about a week on a battery application, with a twelve-week statutory backstop. Start with stiftung ear.

Do I need a company or an address in Germany?

No, but without an establishment in Germany you need an authorised representative there, appointed in writing and in German. The representative registers your electronics and batteries, carries your packaging duties, and is named inside the LUCID registration you file yourself.

Which register do I start with?

The slow one. Appoint the representative and join a battery organisation first, apply to stiftung ear next, and register in LUCID last. LUCID takes minutes, and the dual-system contract you sign afterwards needs the LUCID number.

Can Repax register for me?

Two of the three, yes. Repax Comply runs the filings through an authorised representative where the country requires one, so both stiftung ear registrations can sit with Repax. German packaging is the exception, because § 5 of the VerpackDG makes the LUCID entry personal.

What happens if I sell in Germany without registering?

Each law bans selling the goods until the registration exists, and failing to register can cost a fine of up to 100,000 euros under each of the three. Marketplaces must check your LUCID number before listing packaged goods.