Frequently asked questions on German packaging law
Answers to the most common questions about registration in the German packaging register, authorised representation and the costs involved — grouped by topic.
Costs & payment
Is the €55 fee the total cost?
No. €55 net is the annual authorised representative fee for a small standard mandate. The recycling fee comes on top — it is the actual cost of licensing your packaging and depends on materials, weights and the operator selected. You get the exact figure in writing before you sign anything.
Are there any set-up, reporting or signature fees?
No. There is no set-up fee, no charge per report and no cost for the electronic signature. Contract, appointment, taking over the transferred obligations, the system participation, the quantity reports and the annual closing report are all covered by the annual fee.
Is the fee calculated pro rata if I start during the year?
No. Setting up and administering a mandate takes the same work whichever month you start, so the annual fee for that calendar year is payable in full. There is no separate set-up fee either. System and recycling costs arise separately for each calendar year and can include the operator’s minimum charge.
Is the service charged per calendar year?
Yes. Each calendar year is treated separately — 2026 and 2027 are two distinct years with their own fee, their own quantity forecast and their own reports.
What will the service cost next year?
The authorised representative fee currently stays at €55 net. The recycling fee is recalculated from your new quantity forecast and the operator’s tariff for that year, so it can move in either direction.
What happens if prices increase?
Any change is communicated to you in advance and in plain terms. If the increase is material, you have a special right to end the appointment rather than accept it.
Do businesses in the EU pay German VAT?
With a valid EU VAT ID outside Germany the invoice is issued net under the reverse charge procedure. Businesses outside the EU are invoiced without German VAT once business status is evidenced.
LUCID & appointment
Do I have to register in LUCID myself?
Yes. Registration in the packaging register stays a personal duty of the company and cannot be taken over in full by a representative. It is free of charge, and you only have to submit it — everything after that is mine.
Can you help me with the LUCID registration?
Yes. I go through it with you step by step: which entries are required, what belongs in each field, and how German Packaging is named as your representative. You press submit, that is all.
Where do I register?
At the packaging register run by the Central Agency Packaging Register (ZSVR), at lucid.verpackungsregister.org. The account and the registration are free.
What information do I need for the registration?
Your company name exactly as it appears in your commercial or trade register, the registered address, your national company or tax number, and the brand names under which you sell to Germany. Nothing that needs preparing for days.
Do I have to enter a packaging forecast during registration?
No, not during the company registration itself. The quantity forecast is a separate step and comes later, once the recycling participation is set up.
How do I appoint German Packaging in LUCID?
Inside your register entry you select an authorised representative and search for Fuchswild Design. You get the exact identifier from me together with the contract, so there is nothing to look up in advance.
When does the appointment become effective?
Only once you have confirmed the request in your own LUCID account. Until you do that, nothing changes on your entry.
I already have a LUCID account. Do I need a new registration?
No. An existing registration stays exactly as it is, together with your number. Only the representative is added to it.
Do I need a new registration if I change representative?
No. The registration belongs to your company; the representative is an entry inside it and can be changed. Only one may be recorded at a time, so the previous appointment ends when the new one is entered.
Where do I find my LUCID registration number?
In your LUCID account, on your company’s registration overview. You do not need to send it to me — once you appoint me, it comes through with the request.
When can I start selling or shipping to Germany?
Once the contract, the payment, the LUCID registration, the appointment, the recycling participation and the quantity report are all in place. I tell you explicitly when that point is reached, so you never have to guess.
Packaging quantities
Do I need exact packaging weights before signing up?
No. A realistic estimate per material is enough to start, and it can be corrected later. Weighing one empty parcel on kitchen scales usually gets you close enough.
Which packaging materials do I have to include?
Everything that reaches the customer with the goods: product packaging, shipping boxes and mailers, plastic packaging, filling material, tape, labels and any other packaging component. The product itself does not count.
Do product packaging and shipping packaging both count?
Yes, both. A boxed candle in a shipping carton means the box, the carton, the filler and the tape all go into the calculation.
Does reused packaging still count?
Reused packaging is not automatically exempt. What matters is whether that packaging has already been properly licensed for Germany. If it has not, it counts.
What if the packaging varies between parcels?
A realistic split across materials is fine. The actual quantities are reconciled later, so an estimate now does not lock anything in.
What if I have already shipped orders to Germany this year?
Those parcels have to be included in the quantities for the relevant period. It is normal, it is not a problem, and it is better raised at the start than found later.
Can I update my quantities later?
Yes. The forecast can be adjusted during the year and is then reconciled against the actual quantities.
Do the same quantities go to the recycling operator and to LUCID?
Yes. Both reports have to match — that is exactly the kind of thing the mandate takes off your desk.
What happens if I sell more than expected?
The number of parcels alone triggers nothing. What counts is the actual weight per material. Only if that leads to higher recycling costs is the difference charged, and you see it before it is invoiced.
When are the reports due?
The annual closing report for a calendar year is due by 1 June of the following year. Below ten tonnes a simplified annual report applies. Watching both deadlines is my job, not yours.
Contract and QES signature
Which documents do you need from me?
A current commercial or trade register extract, your company details, your VAT or tax number, your shop link, what you sell, your packaging quantities and how you ship. Sole traders included.
Why do you need a register extract?
To check the legal company name and who is authorised to sign. The appointment has to be made by someone who may represent the company, and the register is what shows that.
Who has to sign the agreement?
A person authorised to represent the company according to the register. Where representation is joint or limited, more than one signature may be required — I check that before the contract goes out.
Does my name have to match my passport or ID?
Yes, particularly for the qualified electronic signature. If your register entry shows a married name and your ID a birth name, that is not a problem — both go into the contract, we just have to know beforehand.
In which language is the agreement?
In both. The contract is bilingual, German and English side by side, and the German version is the legally binding one. You never sign anything you have not read in your own language.
Do I need a notary or an apostille?
No. Neither is required for the appointment.
Can I sign with a scanned signature?
No. It has to be either a qualified electronic signature or a handwritten original. A scan or a typed name is not sufficient under German law.
What if the electronic signature does not work?
Then we do it on paper by post instead. It happens, it works, and it costs you nothing extra.
Existing contracts and special cases
Can I keep my existing recycling contract?
Yes. If a valid and paid participation is already in place, no second contract is concluded. I check the existing contract and the quantities already reported, and carry them over rather than duplicating them.
I already have an Interzero, Lizenzero or other system account. What happens to it?
It is reviewed first. Depending on the operator it is continued, adjusted or transferred. Some operators require their own written consent before a third party may file on your behalf — that is sorted before anything changes, and never at your expense twice.
My system account shows €0 and no reported quantities. Is it active?
Generally not. An account without reported and paid quantities is not a participation. That is worth knowing early, because it changes what still has to happen.
Can you work with Amazon FBA sellers?
Yes. Which packaging counts as yours depends on who supplies it, so we go through your flow before the mandate is accepted rather than assuming it.
What if I use a fulfilment provider?
That is fine. What matters is whose packaging goes to the customer and in whose name it is sent. Tell me how it works and I will tell you what falls to you.
I sell drinks in bottles. Do deposit rules apply?
Deposit obligations are a separate regime from packaging licensing and are checked individually before a mandate is accepted.
I sell batteries or electrical products. Is that included?
No. Packaging law, battery obligations and WEEE are three separate areas. Products of that kind are checked additionally before the contract, so you know what is and is not covered.
Can sole traders and very small Etsy shops use the service?
Yes — that is exactly who it is built for. There is no minimum size, and a shop sending a dozen parcels a year is as welcome as one sending a thousand.
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