Checked: 7 November 2026 — the date every statement on this page was checked against the sources below.
Nothing is registered again: the LUCID number stays. What changes since 12 August 2026 is that a producer with no German establishment names a German authorised representative in its LUCID entry, and the dual-system participation moves into the representative's name. Quantities already licensed for the year are carried over, not paid twice. Sources (2)
VerpackDG § 5VerpackDG § 5
ZSVRZSVR — LUCID registration
Illustrative example. This is not one of our clients: the business is invented, while the law and our published prices are real.
The situation
A cosmetics brand in Poland has sold to German consumers since 2021. It registered in LUCID, licenses its packaging with a dual system and files its reports. In 2026 LUCID started showing a notice asking it to name an authorised representative.
What stays and what changes
| Item | What happens |
|---|---|
| LUCID number | Stays. No new registration (details) |
| Representative | Added in the master data after a written mandate in German |
| Dual-system contract | Moves into the representative's name, with the same operator if you like (keep your system) |
| Quantities already licensed this year | Carried over, not licensed again |
Why the notice appears
LUCID shows it to every company whose registered office is outside Germany. See why LUCID asks for a representative.
What it costs
Our fee for packaging is €149 a year, with no setup fee. The dual-system licence follows your kilograms and is paid at the system's price, with no markup from us. See pricing.
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.
Razvan on LinkedIn ↗