Can my packaging supplier license my service packaging for me?

Q: Can my packaging supplier license my service packaging for me?

Yes, for service packaging only, such as bags, cups or wrapping filled at the point of sale. § 7(2) VerpackDG lets you require your upstream suppliers to license the unfilled service packaging they deliver, and to confirm it. The duties to report then pass to that supplier for that packaging, but you remain obliged to register in LUCID yourself and declare that you only supply pre-licensed service packaging (§ 6(2)).

Yes, for service packaging. § 7(2) VerpackDG lets you ask upstream suppliers to license the unfilled service packaging; you still register in LUCID.

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 7 November 2026 · Sources linked below

Quick answer

Yes, for service packaging only: packaging filled at the point of sale, like bags, cups or wrapping. § 7(2) VerpackDG lets you require your upstream suppliers to license the unfilled service packaging they deliver, and to confirm it. The reporting duties for that packaging pass to them, but you still register in LUCID yourself and declare that you only supply pre-licensed service packaging (§ 6(2)). Shipping boxes for online orders are not covered by this.

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