StartFill customer guide · Germany

LUCID registration, authorised representative and dual system

Before we can ship your goods to customers in Germany, your company needs three things in place under German packaging law. This page walks you through each one with screenshots from the official LUCID Packaging Register.

Updated 16 October 2026Law PPWR (EU) 2025/40 + VerpackDGTime needed about 30 minutes

The whole guide as a 3½-minute film with narration and on-screen captions. The written steps follow below.

Overview

Three duties, in this order

Anyone who first sells packaged goods to consumers in Germany counts as a producer under packaging law. That includes brand owners, importers and online sellers, wherever they are based. When StartFill packs your orders, the shipping carton and filling material count as your packaging too.

01

Authorised representative

Only if based outside Germany

Required since 12 August 2026 for companies without a branch in Germany. Appoint one before you register, because LUCID asks for it.

02

LUCID registration

Free

Your company registers itself in the official register at lucid.verpackungsregister.org. Nobody else can do this for you, including us.

03

Dual-system licence

Paid, by weight

A contract with a dual system that collects and recycles your packaging. You pay per kg of paper, plastic, glass and so on.

Without registration, your products may not be sold in Germany.

The law sets a distribution ban for unregistered producers, and fines of up to €100,000 for missing registration and up to €200,000 for selling packaging without a dual-system licence. Marketplaces such as Amazon check your LUCID number, and as your fulfilment provider we check it before go-live.

Before you start

Check whether you are already registered

A company may only register once. If someone in your company registered before, find the existing login instead of starting again.

Search the public register

Open the register of producers, type your company name and click 1 Start query.

If your company appears 2, you are registered. The register number starts with DE followed by 13 digits. Send us this number.

Lost the login? Use “Forgot password” or “Email address(es) unknown?” on the LUCID start page. The register cannot reset it for you.

oeffentliche-register.verpackungsregister.org/Producer
Public register of producers with search button and one result row
Example search result. Company details are blurred.
Step 1 · Companies outside Germany

Appoint an authorised representative

Since 12 August 2026, a company based abroad with no branch in Germany that sells directly to end users in Germany must appoint an authorised representative for extended producer responsibility. This applies to companies from other EU countries too, and there is no exemption.

Who can act
A person or company with a registered office or branch in Germany, outside your own company. Your own staff cannot act as representative.
How many
One. You can only appoint one representative.
Contract
Written agreement in German, signed by both sides by hand or with a qualified electronic signature.
They take over
The dual-system contract, volume reports in LUCID and the declaration of completeness, in their own name.
You keep
Your own LUCID registration and any later changes to it.
Same company possible
Your representative and your dual system can be the same company or group. One partner then handles the representation, the licence and the reports.
When it counts
Only after the representative confirms the appointment in their own LUCID account. You get an email when it is active.

Choose a provider and sign

Your representative needs their own LUCID login 2 first. Ask them for their company name or representative ID, because you enter it during registration.

The register publishes no list of representatives and cannot recommend one. The main providers are compared below. StartFill does not act as authorised representative.

lucid.verpackungsregister.org
LUCID start page tiles for producers and for authorised representatives
1 Producers register here. 2 Representatives have their own login.

Main authorised-representative providers

ProviderWebsitePublished priceDual-system licence included?Also a dual system?Suited to
Green Dot Rep
Der Grüne Punkt group
verpackgo.com/representative€89 one-off + from €189 / yearNo, licence fees extraYes, Der Grüne PunktAmazon PAN-EU and foreign sellers; DE, EN, ZH, FR
Lizenzero
Interzero group
lizenzero.com/bevollmaechtigter€299 per countryPart of its EPR service; scheme fees extraYes, InterzeroOnline and marketplace sellers; covers many EU countries. Confirm it covers foreign sellers into Germany
ecosistant
Independent
ecosistant.eu€250 / year up to 1 t packagingNo, licence passed on at costNoForeign producers without German branch; DE, EN
rep-germany.de
Independent (R&R Vivendi GbR)
rep-germany.de€170 / year + VATNo, dual system paid separatelyNoEU and non-EU sellers on Amazon, eBay, Etsy; 9 languages
EaseCert
Independent
easecert.com€400 one-off; setup fee may applyNo, own dual-system contract requiredNoAmazon, eBay, Etsy, Shopify sellers; EN

Prices as published by the providers in October 2026, usually excluding VAT. Check the current price, contract term and what is included before you sign. Dual-system groups first, then independent providers. StartFill has no partnership with any of them and does not recommend one.

Representative and dual system from one company.

Your representative and your dual system can be the same company. Der Grüne Punkt (via Green Dot Rep) and Interzero (via Lizenzero) offer both. With one partner, the representative signs the dual-system contract in its own name and reports the same figures to the dual system and LUCID.

Relief is being discussed but not in force.

The EU has proposed pausing the cross-border representative duty, and the German government has proposed relief for sellers under 10 t a year. Until a change is adopted, the duty applies unchanged. Existing registrations must add their representative by 12 November 2026.

Step 2 · Everyone

Register in LUCID

Registration is free and takes about 15 minutes. You first create a login, confirm it by email, then complete the registration from your account.

Open the LUCID Packaging Register

Go to lucid.verpackungsregister.org. Use the language menu at the top right to switch to English.

Click 1 start your registration here.

lucid.verpackungsregister.org
LUCID welcome page with the registration link highlighted

Know the deadlines

After you create the login you get an activation email 1. Confirm it within 24 hours, or the login is deleted. Then complete the registration within 7 days.

Use a shared mailbox you will still have in a few years, such as compliance@yourbrand.com. The login email is the only way to reset your password.

…/Hersteller/Registrierung/Teil-1
Create login page with information about the 24-hour activation and 7-day deadline

Enter company name and designated person

  • 1 Company name exactly as in your company register and dual-system contract.
  • 2 Language for emails from LUCID.
  • Designated person: someone who may legally represent the company, such as the managing director or owner.

If LUCID says a company with this name is already registered, stop and go back to Check first.

…/Hersteller/Registrierung/Teil-1
Producer data form filled with an example company name and English as language
Filled in with placeholder data (“Example Brand Ltd”).

Create your login

  • 1 Login email, entered twice.
  • 2 A password of your choice, entered twice.
  • 3 Start the anti-robot check.
  • 4 Click Create login, then open the activation email.
…/Hersteller/Registrierung/Teil-1
Login data section with email, password, captcha and Create login button
Step 2 continued

Complete your registration in the account

After you log in, the dashboard shows four areas. Work through them from left to right. The screenshots below come from a live account. Names, numbers and addresses are blurred.

Find your registration number

Once the registration is approved, your dashboard shows the 1 registration number (DE + 13 digits) and status Registered. You also receive the registration notice by email.

Enter this number in your Amazon, Kaufland or Otto seller account, and send it to us.

…/Hersteller/Dashboard
LUCID dashboard with registration number and status

The four areas you maintain

  • 1 Master data: address, VAT number, representative, recovery email.
  • 2 Details about the packaging: which kind of packaging you put on the market.
  • 3 Brand names: every brand printed on your packaging.
  • 4 Data report: the kg you also report to your dual system.
…/Hersteller/Dashboard
Dashboard tiles: master data, packaging details, brand names, data report

Master data and representative

Enter your full address, telephone, VAT number and company register number. Only one VAT number and one tax number can be stored.

If your 1 country is not Germany, the form asks for your authorised representative in the Bevollmächtigter part. You cannot finish without one.

Add a second email as recovery contact. It is the only way back in if you lose access to the login email.

…/Hersteller/Stammdaten
Master data contact section with country and postcode fields; email and street blurred

Choose the packaging type

For goods sold to consumers and shipped in cartons, tick 1 Packaging subject to system participation. This covers retail packaging and all shipping packaging that ends up in private households.

…/Hersteller/Angaben-zu-den-Verpackungen
Packaging details with 'packaging subject to system participation' ticked

Add your brand names

Click 2 Add brand name for each umbrella brand on your packaging. They then appear in the list 1.

Enter umbrella brands only, not product names, sizes or model numbers. If your packaging shows no brand, enter your company name.

…/Hersteller/Marken/Markenansicht
Brand names list with Add brand name button

Confirm and send

Tick the three 1 statements and click 2 Send. The first statement confirms you register yourself and did not hire a third party, which the law does not allow.

Whenever your details change, such as a new address, brand or representative, update them here straight away.

…/Hersteller/Stammdaten
Statements with three checkboxes and Send button
Step 3 · Everyone

License your packaging with a dual system

A dual system (Systembetreiber) organises the collection and recycling of your packaging from German households. You sign a contract, state how many kg of each material you expect to sell per year, and pay a fee based on that. You are free to choose any licensed system. If you have an authorised representative, they sign this contract in their own name, and they can be the same company as your dual system.

Pick a system operator

The register lists all licensed operators with their contacts 1; the full list is in the table below. It may not recommend one or share prices, so compare offers yourself. Most offer online shops for small sellers.

Include in your quantities the shipping cartons, mailers, tape and filling material that StartFill uses for your orders. We send you these figures.

verpackungsregister.org/…/overview-of-system-operators
Official overview of system operators with the list heading highlighted

All licensed dual systems in Germany

Source: official overview of the Zentrale Stelle Verpackungsregister, October 2026. Listed alphabetically; no recommendation.

System operatorOnline shop for small sellersEntry priceSales email
BellandVision GmbH
Pegnitz · www.bellandvision.com/en
Online Licensingon requestvertrieb@bellandvision.de
Der Grüne Punkt – Duales System Deutschland GmbH
Cologne · www.verpackgo.com/en
verpackgosee shopanfrage@gruener-punkt.de
EKO-PUNKT GmbH & Co. KG
Cologne · www.eko-punkt.de
EASY-LIZEsee shopinfo-koeln@eko-punkt.de
Interzero Recycling Alliance GmbH / Lizenzero
Cologne · www.lizenzero.de/en
Lizenzerofrom €39 / yearkontakt@lizenzero.de
Landbell AG für Rückhol-Systeme
Mainz · www.landbell.de/en
EASyshopsee shopservice.vertrieb@landbellgroup.com
Noventiz Dual GmbH
Cologne · www.noventiz.de/en
Verpackung Direktsee shopinfo@noventiz-dual.de
PreZero Dual GmbH
Neckarsulm · www.prezero.de
Licence calculatorfrom €79 / yearvertrieb@prezerodual.com
Reclay Systems GmbH
Herborn · reclay-group.com
activate by Reclayno minimum quantitysales.de@reclay-group.com
Recycling Dual GmbH
Mönchengladbach · www.recycling-dual.de
EASY-LIZE portalsee shopsales@recycling-dual.de
Zentek GmbH & Co. KG
Cologne · www.zentek.de/en
Zmartfrom €59 / yearDSZ-Vertrieb@ZENTEK.de

Entry prices as published by each operator in October 2026; the real fee depends on your kg per material. “See shop” means no price is published. The register itself may not recommend operators or share prices.

Every year

Report the same quantities in LUCID

Whatever you report to your dual system, you also report in LUCID. The figures must match.

Know your reports and deadlines

  • Initial planned volume report: your expected kg for next year. When you start mid-year, submit it as an intra-year report.
  • Year-end volume report: actual kg for last year, by 1 June.
  • Over 10 tonnes a year: report in LUCID immediately after reporting to your dual system 1.
  • Corrections after 1 June go in as a supplementary report.
…/Hersteller/Datenmeldung
Data report page with deadline information and report type tiles

What a report looks like

Quantities are entered per system operator and material, in kg with three decimals. The figures below are invented examples.

System operatorGlassPaper, paperboard and cardboardFerrous metalsAluminiumBeverage cartonsOther compositesPlasticsOther materials
Your dual system0.000850.5000.0000.0000.0000.000120.2500.000

Paper/cardboard is usually your shipping cartons and paper fill; plastics covers bottles, pouches, tape and air cushions.

FAQ

Frequently asked questions

Short answers to what our customers ask most about LUCID, representatives and dual systems.

Do I need a LUCID registration if StartFill ships my orders?

Yes. The duty lies with the company that first sells the packaged goods in Germany, which is you. A fulfilment provider does not take it over. The shipping cartons and filling we use for your orders count as your packaging.

My company is outside Germany. Do I still need my own LUCID registration?

Yes. Registration is a personal duty of your company. Your authorised representative takes over the dual-system contract, the volume reports and the declaration of completeness, but you register yourself and enter the representative in your master data.

Can my authorised representative and my dual system be the same company?

Yes. Der Grüne Punkt (via Green Dot Rep) and Interzero (via Lizenzero) offer both. One partner then handles the representation, the licence and the reports.

I only sell on Amazon. Isn’t Amazon responsible?

No. As a seller on Amazon, including FBA, you are the producer of your packaging. Amazon checks your LUCID number and can block your listings in Germany without it.

What does it cost?

The LUCID registration is free. Dual-system licences for small volumes start at around €39 to €79 a year, depending on the operator and your kg per material. Authorised representatives charge roughly €170 to €400, per year or one-off depending on the provider.

What happens if I am not registered?

Your products may not be sold in Germany (distribution ban). Fines can reach €100,000 for missing registration and €200,000 for packaging without a dual-system licence. Marketplaces can block your offers, and we cannot start shipping for you.

Which packaging do I have to license?

All packaging that ends up with private end consumers: product packaging, outer boxes, shipping cartons, mailers, tape and filling material.

When do I report my quantities?

Each year you submit planned quantities for the next year and your actual quantities for the previous year by 1 June. Above 10 tonnes a year, you report in LUCID right after reporting to your dual system. The figures in LUCID and at your dual system must match.

Can StartFill register for me or act as my representative?

No. The law does not allow a third party to register for you, and StartFill is not an authorised representative. We send you the packaging weights every month and can report them to your dual system for €15 a month.

We are already registered, but our details have changed. What now?

Update your master data, brands or representative in LUCID straight away. Companies based abroad that were already registered must add their authorised representative by 12 November 2026.

How StartFill helps

We give you the numbers; you keep control

Packaging report, included

Every month we send you the kg per material of the shipping packaging we used for your orders, ready for your dual system and LUCID.

Reporting service, optional

We report your quantities to your dual system under your power of attorney, including the year-end report. €15.00 / month net. You pay licence fees to the dual system directly.

Questions

We are happy to help with these steps. Write to info@startfill.com or call +49 911 47711390.

Send us before go-live
  1. Your LUCID registration number (DE + 13 digits)
  2. The name of your dual system and proof of your contract
  3. Your authorised representative, if you are based outside Germany
  4. The weight per unit of your product packaging, by material (we add our shipping packaging)

This guide is for orientation only and is not legal advice. For legal certainty, contact the Zentrale Stelle Verpackungsregister, your dual system or your adviser.

Official sources: verpackungsregister.org · LUCID · Authorised representative (ZSVR). Screenshots taken 16 October 2026.

StartFill is operated by Blumental Bayern GmbH.