Supplying Germany from Türkiye
Germany is where most European buyers of printed hospitality products start, and where most of them get caught out. Not by the product — by the registration. Anyone who first places packaging on the German market carries the producer obligation, and for an importer that party is the importer, not the manufacturer abroad. Everything else about supplying Germany from Türkiye is straightforward: goods move by road, and under the Customs Union they arrive duty-free.
| Customs duty | 0% with an A.TR certificate — Türkiye and the EU are in a customs union |
|---|---|
| Transit | Road freight from İstanbul, typically under a week |
| Applicable rules | PPWR (EU) 2025/40 and the Single-Use Plastics Directive 2019/904 |
| Wet wipe marking | Must be in German where the product is sold in Germany |
| Registration | LUCID packaging register, before the first shipment arrives |
The LUCID registration catches importers out
Germany runs a public packaging register called LUCID. Whoever first places packaging on the German market must be registered in it and must have a contract with a dual system before that packaging arrives. Since July 2022 this has covered service packaging too, which is what individually wrapped wet wipes are. Fines run to six figures. The point that surprises buyers: registration is the importer's duty, not the foreign manufacturer's, so it cannot be delegated to us by contract. Register first, then order.
German packaging law was rewritten in August 2026
The Packaging Act (VerpackG) was replaced by the Packaging Law Implementation Act (VerpackDG) on 12 August 2026, the same day the EU regulation took effect. LUCID continues in broadly its established form but its provisions were aligned with the EU regulation, and reporting and recyclability duties widened. If your compliance file was assembled before August 2026, it is describing a law that no longer exists.
What this means for what you order
Bamboo and wooden cutlery, bamboo straws and paper napkins sit outside the single-use plastics bans altogether — they are not plastic products and, in the case of napkins and cutlery, not packaging either. The item that carries obligations is the wet wipe: its sachet is packaging, and if the cloth inside contains plastic the pack must carry the plastic-in-product marking in German. Our alcohol-free and standard wipes are both available with the cloth composition stated, so the marking question can be settled before artwork is approved.
Ordering rhythm
German buyers usually place a single annual or half-yearly order against a fixed design, then call it off in batches. That suits our production: the plate charge falls once, on the first order, and does not repeat while the artwork is unchanged. Allow production time plus road transit when you plan the first delivery — the two together, not either one alone.
We ship from İstanbul on A.TR, which makes the goods duty-free on arrival. What we cannot do for you is the LUCID registration; that has to sit with the party placing the packaging on the German market. Tell us the market at quotation stage and we will set up the artwork with the right marking from the start.
Most ordered for this market
Tell us the market at quotation stage. It changes the marking language on the artwork and, on wet wipes, sometimes the specification itself.
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