By Razvan Toma · Founder · Last checked 8 November 2026 · Sources linked below
Quick answer
Yes, it must, but not without a representative. Registration in LUCID is a höchstpersönliche Pflicht (a strictly personal duty): you do it yourself, free (§ 5(1) and (2) VerpackDG). Since 12 August 2026 a producer with no German establishment that sells to end users in Germany must also appoint an authorised representative, and ZSVR states that you cannot complete your registration without naming it. Sign the mandate first, then register. See registering without a representative and who may register you. Sources (3)
VerpackDG § 5VerpackDG § 5
ZSVR helpZSVR help — Authorising a representativeZSVRZSVR — Bevollmächtigung
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