Packaging EPR in Germany for cosmetics sellers

Q: What are Germany EPR requirements for cosmetics packaging?

Cosmetics packaging that reaches consumers (bottles, jars, tubes, pumps, boxes, the shipping box) is packaging that typically ends up in private households, so it must be licensed with a dual system. You register in LUCID yourself and, if your company has no establishment in Germany, appoint a German authorised representative. There is no cosmetics exemption and no minimum volume. License every material separately: glass, plastics, paper, aluminium, composites.

What are Germany EPR requirements for cosmetics packaging?

Cosmetics packaging sold to consumers is household packaging: LUCID registration, a dual-system licence for every material, and a German representative if you have no establishment there.

Since 12 August 2026, § 5 VerpackDG, implementing Article 45(3) of Regulation (EU) 2025/40, requires a producer with no establishment in Germany to appoint an authorised representative before it first makes packaging available in Germany. Read § 5

By Razvan Toma · Founder · Last checked 8 November 2026 · Sources linked below

Quick answer

The full household-packaging rules, with no sector exemption.

Register in LUCID yourself, free.
License every material that reaches the customer with a dual system: glass jars, plastic tubes and pumps, folding boxes, the shipping box and filling.
No establishment in Germany: appoint an authorised representative (§ 5(2) VerpackDG).
Report the same weights in LUCID.

Samples and gift sets count too. If you also sell devices such as hair dryers, that is a separate WEEE registration (WEEE). See household or B2B packaging.

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What are Germany EPR requirements for cosmetics packaging?

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