Checked: 9 November 2026 — the date every statement on this page was checked against the sources below.
If you were registered under the old Packaging Act, you stay registered, but changes to your registration under the new VerpackDG, including naming an authorised representative, must be entered by 12 November 2026 (§ 68(2) sentence 2 VerpackDG). A producer with no establishment in Germany needs a representative for this. We confirm the appointment in LUCID the same day, for €149 a year. Sources (2)
VerpackDG § 68VerpackDG § 68VerpackDG § 6VerpackDG § 6
What the law says
- § 68(2) sentence 1 VerpackDG: a producer registered under § 9 of the Packaging Act (version in force until 11 August 2026) counts as registered under § 6 VerpackDG. VerpackDG § 68 VerpackDG § 6
- § 68(2) sentence 2: changes under § 6(1) sentence 2 must be made by 12 November 2026.
- § 6(1) sentence 3: this expressly includes changes to the appointment of the authorised representative.
ZSVR - § 6(2) no. 2: a producer that must appoint a representative under § 5(2) enters the representative's name, address and contact details, and the written mandate.
- Newly obliged producers (not registrable before) had to register by 12 September 2026 (§ 68(2) sentence 3).
12 November 2026 is the date for updating existing registrations. It does not move the representative duty itself, which has applied since 12 August 2026.
Who it affects
| Your situation | To do by 12 November 2026 |
|---|---|
| No establishment in Germany, already registered in LUCID | Appoint a representative and name it in LUCID |
| Established in Germany | Check and complete your registration data, for example brand names and packaging types |
| Newly obliged, not registered yet | Registration was due by 12 September 2026: do it now |
Done in one day
- Order the mandate: checkout.
- Sign the mandate by hand or with a qualified electronic signature.
- In LUCID, open the Authorised representative tile, click Edit, then Appoint an authorised representative, and enter our ID DE8516653799349. Tick the declarations and submit.
- We confirm the appointment the same day.
Your LUCID number stays the same: nothing is registered again. Your existing system participation remains valid until 31 December 2026 at the latest (§ 68(1) VerpackDG). From 2027 the representative of a producer with no German establishment arranges the system participation (§ 5(3) VerpackDG). VerpackDG § 5
After 12 November
A producer that has not entered the change is in breach of the registration duty in § 6 VerpackDG. Fines are set in § 66 VerpackDG. Marketplaces check LUCID data, and a missing representative can lead to blocked listings. See also do I have to register again? and LUCID step by step. VerpackDG § 66
Razvan Toma is the founder of EPR Germany Rep and of EPR France Rep, the French sister service. He has worked in waste management and recycling since 2009, running waste-separation programmes inside large B2B organisations in France for clients including Chanel, Microsoft, Decathlon, Pirelli, IKEA, Vinci, Capgemini and E.Leclerc. He reads the statutes and the regulator's own guidance directly, and publishes what they say — including when it means telling a visitor they do not need to buy anything.
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