Germany EPR Regulations for Manufacturers, Importers and Ecommerce

Germany’s Extended Producer Responsibility (EPR) for packaging requires all businesses placing packaged goods on the German market to register with the LUCID Packaging Register. This regulation, enforced since 1 July 2022, mandates producers to ensure packaging is designed sustainably and waste is avoided, reused, or recycled. Obligations apply to manufacturers, importers, and ecommerce retailers—whether located inside or outside Germany—who first place packaging on the market. This includes online retailers shipping to Germany. There are no exemptions; all packaging types must be registered.

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Covered and Exempted Packaging under Germany EPR

Packaging is categorized as either subject or not subject to system participation. Subject packaging includes:

• Retail Packaging
• Service Packaging
• Group Packaging
• Shipment Packaging

Exempted packaging includes:

• Transport Packaging
• Reusable Packaging
• Single-use Beverage Packaging (subject to deposit)
• Retail packaging for hazardous contents

All types must be registered, but only subject packaging requires a system participation agreement and volume reporting.

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Who Must Register under Germany EPR

Registration is mandatory for any party that:

• First fills packaging with goods and places it on the German market (initial distributor)
• Imports packaged goods into Germany
• Acts as a mail-order business filling shipment packaging

Both foreign and domestic entities must comply. There are no exemptions based on company size or quantity.

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Germany EPR Data Reporting

Producers must report data both to their system operator and to the LUCID Packaging Register. Required data includes:

• Registration number
• Material type (e.g., cardboard, glass, plastics, metals, composites)
• Weight of individual packaging and total weight
• System operator details and participation period

Declaration of completeness must be submitted annually if packaging thresholds are exceeded (e.g., 80,000 kg glass, 50,000 kg paper/cardboard, 30,000 kg lightweight materials).

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Germany EPR Schedule and Deadlines

Important reporting deadlines include:

• Initial planned volume report: by 31 December of the current year
• Year-end volume report: by 15 May of the following year
• Declaration of completeness: by 15 May (extended to next business day if it falls on a holiday/weekend)

Reports must be submitted electronically via the LUCID system.

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Germany EPR Fees and Penalties

Fees are paid to system operators based on packaging material and volume. Failing to comply with EPR regulations may lead to:

• Distribution ban for non-compliant products
• Fines of up to €200,000

There are no thresholds exempting producers from registration or participation requirements.

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Common EPR Compliance Challenges In Germany

Businesses often face challenges such as:

• Understanding system participation requirements
• Collecting and categorizing data accurately
• Meeting deadlines for volume reporting and declarations
• Navigating German-language platforms and documentation

International producers may appoint a local representative to assist with compliance obligations.

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Why choose RegSurance as your Germany EPR Compliance Partner

RegSurance is a trusted EPR compliance service provider for international businesses needing to comply with Germany packaging EPR rules. We support manufacturers, importers, and e-commerce sellers with complete EPR solutions — including EPR registration, packaging compliance assessments, ongoing regulatory updates, and accurate EPR data reporting for Germany. With our in-depth knowledge of German EPR requirements, we ensure your business stays fully compliant and up to date with changing legislation.

Get expert help with EPR registration for Germany with compliance assessment and data reporting

• Get a free EPR compliance Assessment
• Receive a personalized registration roadmap
• Book a 1:1 consultation with our experts
• Register or Sign-in for our comprehensive EPR Compliance Guide