What does German packaging EPR mean for a large manufacturer based abroad?

It depends on where your packaging ends up. Registration in LUCID is your own duty (§ 5(2) VerpackDG), and a company without a German establishment also appoints an authorised representative. Packaging that reaches private final consumers is licensed with a dual system and reported in LUCID. Packaging that ends up with business end users, such as pallets, big bags and stretch film delivered to a factory or building site, is outside system participation: no LUCID data report, but free take-back, recovery and annual documentation under § 39. If your system-participation packaging reached 80 t of glass, 50 t of paper and cardboard or 30 t of lightweight packaging in the previous year, an audited declaration of completeness is due by 15 May (§ 10). Large volumes and mixed B2C and B2B flows are quoted on scope. VerpackDG § 5+3