Checked: 7 November 2026 — the date every statement on this page was checked against the sources below.
The store the German customer buys from is usually the producer, even when the supplier packs and ships every parcel. Who physically handles the goods does not decide it; who makes the packaged goods available to the German end user does. With no establishment in Germany, the store also needs a German representative. Sources (2)
VerpackDG § 5VerpackDG § 5VerpackDG § 7VerpackDG § 7
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 two-person company in Ireland runs a Shopify store for phone stands. Orders from Germany go straight to a supplier in China, which packs each stand in its own box and posts it to the German customer. The company has never touched the stock.
Who is the producer
The Irish company: it sells to the German customer. The supplier is a service provider in the chain, not the seller. See dropshipping: who is the producer?
What applies
- LUCID registration in the Irish company's name.
- A dual-system licence for the box, the bag and any filling that reach the German customer.
- A German authorised representative, because being in the EU does not exempt it (EU companies).
- The weights come from the supplier: ask for the packaging per unit by material before the first report.
What to do
- Register in LUCID yourself. Registration is free and stays with the producer; nobody can do it for you.
- Sign the mandate with your German representative, in writing and in German, before the first sale.
- Name the representative in LUCID. With us, the confirmation follows the same day once you have named us and signed.
- License your packaging with a dual system. Your representative concludes the contract in its own name, by material and weight.
- Enter your LUCID number on each marketplace you sell on, and report your volumes as the year goes on.
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 ↗