Germany: Verpackungsgesetz and the LUCID register

The three obligations

• Register in LUCID before the first packaging reaches the market
• Contract with a dual system for household-type packaging
• Report volumes, matching what was declared to the dual system

Who is obliged

The obligation falls on whoever first places the packaging on the German market. For a foreign manufacturer shipping to a German buyer, it is usually the buyer who imports; where the foreign party sells directly to end customers in Germany, the obligation can fall on them. Getting this wrong means goods are on the market without a registration behind them.

Why it cannot be delegated

Registration is tied to the obliged party's own identity and is publicly visible. A service provider can assist with the filing, but the registration remains in the name of the obliged party. A supplier saying 'we are registered' does not cover its customer.

Transport packaging is treated differently

Household-type packaging and transport packaging carry different duties. Cartons and pallets moving between businesses are not treated the same as packaging that ends up with a consumer, and the distinction changes what has to be reported.

How it connects to everything else

LUCID is a national registration duty and sits alongside, not instead of, the EU packaging regulation. Meeting one does not discharge the other, and both rest on knowing the composition and weight of the packaging.