EPR System in Germany

For many e-commerce businesses, Germany is the natural next step: a large, mature market with strong purchasing power. But entering it raises an important question: how do Germany’s environmental obligations actually work? Unlike some countries that maintain a single, centralised environmental register, Germany divides responsibilities across several legal frameworks. The most important of these concern packaging under the Verpackungsgesetz and its LUCID register, the rules for electrical and electronic equipment set out in ElektroG and administered through Stiftung EAR, and the requirements for batteries and accumulators regulated by BattG, which are also overseen by Stiftung EAR.

Anyone selling into Germany should understand how these three areas interact, because overlooking them can lead to serious consequences. German authorities and marketplaces can demand proof of registration at any time, and failure to comply may result in penalties or even suspension of sales.

In the sections that follow, this article explains how these systems function within the broader European regulatory environment. It outlines who is expected to register, how each registration process works and what kind of reporting obligations traders face once they are active on the German market. The final summary offers a clear comparison to help you understand what changes when you expand beyond your domestic EU market and begin selling in Germany.

Why Germany Doesn’t Use a Single Central Environmental Register

Germany approaches environmental and product-responsibility law differently from countries that centralise everything in one nationwide database. Instead of combining packaging, electronics and battery obligations under a unified system, Germany distributes Extended Producer Responsibility duties across separate acts and specialised authorities. Packaging oversight lies with the Zentrale Stelle Verpackungsregister (ZSVR), which manages the LUCID register. Electrical and electronic equipment, as well as batteries, fall under Stiftung EAR, an institution designated to coordinate compliance in these product areas.

A separate digital platform, eANV / ZKS-Abfall, exists for documenting the movement of hazardous waste, but it covers only a narrow category of waste streams. Many foreign sellers initially mistake it for a comprehensive national register, but it is not intended to replace the broader producer-responsibility obligations that apply when placing packaged goods, electronic products or batteries on the German market.

The Three Pillars of the German Compliance System

Packaging (Verpackungsgesetz)

Germany’s Packaging Act requires any business introducing packaging into the German market to register in the LUCID system. This obligation applies regardless of whether the packaging is used for transport, service purposes or business-to-business shipments. When packaging is likely to end up in private households, companies must also conclude an agreement with a dual system responsible for nationwide collection and recycling. Registration is free of charge, but sellers must update their data, report placed volumes and ensure full traceability. Since 2022, marketplaces such as Amazon and eBay are legally required to verify that sellers comply before their products can be listed.

Electrical and Electronic Equipment (ElektroG)

Rules for electrical and electronic devices are anchored in ElektroG, Germany’s transposition of the WEEE Directive. Before making such products available in Germany, sellers must register with Stiftung EAR and obtain a WEEE number. Companies located outside Germany cannot complete this process independently and must appoint an authorised representative within the country. This representative becomes the official liaison for all compliance matters, from registration to ongoing reporting.

Batteries and Accumulators (BattG)

Battery obligations stem from the BattG legislation, which now requires all producers to register through Stiftung EAR. The authority issues a BattG registration number and oversees obligations that differ depending on the type of battery placed on the market. Once again, companies without a German establishment are required to appoint a local representative who assumes legal responsibility for fulfilling BattG duties. These national rules interact increasingly with the EU Battery Regulation (EU) 2023/1542, which is reshaping battery compliance across Europe and gradually introducing harmonised sustainability and end-of-life requirements.

What This Means for an EU-Based Seller

For businesses entering the German market, the absence of a single central register does not simplify compliance. Most sellers must navigate at least one of the German systems, and many fall under all three at the same time. This can mean registering in LUCID, entering into an agreement with a dual system for household-bound packaging, obtaining a WEEE number from Stiftung EAR and completing BattG registration for batteries contained in products or supplied separately.

German authorities and online marketplaces enforce these obligations strictly. Platforms increasingly require proof of registration before allowing listings to go live, which makes early compliance essential. For sellers across Europe, meeting these requirements is not optional; it is a precondition for accessing the German market and maintaining uninterrupted sales.

Verpackungsgesetz and the LUCID Register

Who Is Covered by the VerpackG Rules

The Packaging Act, known as Verpackungsgesetz or VerpackG, forms the backbone of Germany’s packaging compliance framework. The law applies to every business that places packaged goods on the German market. It makes no distinction between manufacturers, importers, cross-border sellers or online shops shipping orders directly to German consumers. If a product reaches a recipient inside any form of packaging, the company behind it is considered a producer within the meaning of German law.

The legislation focuses primarily on household and grouped packaging but extends its reach to certain types of transport packaging, service packaging and reusable packaging. For most sellers, this means that the moment a product leaves a warehouse wrapped, boxed, protected or sealed in any manner, obligations under VerpackG arise automatically.

Registration in LUCID and the Registration Number

The centrepiece of compliance is registration in the LUCID packaging register, operated by the Zentrale Stelle Verpackungsregister (ZSVR). Registration is free but absolutely mandatory; without it, products cannot legally be sold in Germany. Once the process is completed, the company receives a unique LUCID registration number. This identifier must be shared with business partners and is routinely required by online marketplaces before they allow listings to go live. Platforms such as Amazon and eBay actively suspend or block sellers who attempt to trade without a valid LUCID number, treating registration as the minimum entry requirement for the German market.

The Contract with a Dual System

Beyond registration, businesses must also enter into a contract with one of the authorised dual systems. These organisations are responsible for organising the collection, sorting and recycling of packaging waste throughout Germany. Companies declare the types and volumes of packaging they place on the market, while the dual system ensures that corresponding recycling services are funded and executed. The cost of participation depends on the scale and material composition of the packaging used; the higher the volumes, the higher the financial contribution.

Reporting Obligations

Every business covered by VerpackG must submit regular data reports detailing the quantities of packaging placed on the market. An annual report to the ZSVR is required in most cases and must match the figures submitted to the contracted dual system. Companies handling high volumes of packaging may additionally need to provide a formal confirmation of accuracy prepared by a certified environmental auditor, who verifies that the reported data is complete and consistent.

A Practical Example for an EU Online Store

Consider an online shop based elsewhere in the European Union that sells beauty products and begins delivering to customers in Germany. The items arrive in plastic bottles, which are then placed in cardboard boxes, cushioned with protective material and sealed with adhesive tape. Under German law, each of these components — bottle, box, filler material and tape — is classified as packaging.

Before the first order is dispatched to Germany, the seller must register in the LUCID system, obtain a registration number, conclude a contract with a dual system and prepare to report its annual packaging volumes. This structure ensures that the cost of collecting and recycling packaging is borne by the businesses introducing it rather than by the public. For the seller, it means additional administrative steps and financial obligations, but it also guarantees that trading in Germany is fully compliant with environmental law and free from the risk of marketplace restrictions or regulatory penalties.

BattG and Battery Registration with Stiftung EAR

Who Is Covered by the BattG Rules

Germany’s Battery Act, known as BattG, sets out the rules that govern how batteries and accumulators may be placed on the German market. Its scope is broad: it applies to manufacturers, importers and distance sellers offering batteries either as standalone products or as integrated components of electronic devices. Any business selling equipment such as power tools, toys, wearables or other devices containing built-in cells is automatically treated as a producer under the law.

Since early 2021, registration obligations have been consolidated under Stiftung EAR, the authority previously responsible only for electrical and electronic equipment. Today, Stiftung EAR maintains the official producer register and issues BattG registration numbers. Companies without a physical presence in Germany must appoint an authorised representative who assumes formal responsibility for compliance and communication with the authority.

Registration with Stiftung EAR

Registration must be completed before the first battery or battery-equipped product enters the German market. Once approved, the seller receives an official BattG registration number issued by Stiftung EAR. This number acts as formal proof of compliance and is routinely required by business partners and online marketplaces. Without it, the sale of products containing batteries is considered illegal in Germany and may result in financial penalties, enforcement action or the immediate suspension of listings by major e-commerce platforms.

Systems for Collecting and Handling Used Batteries

Compliance goes beyond registration. Producers are responsible for ensuring that used batteries are returned and managed within an approved collection and recycling system. For portable batteries, participation in an authorised take-back scheme is mandatory. For industrial or automotive batteries, producers must organise free-of-charge collection directly from users and guarantee proper recycling and treatment. These arrangements ensure that the financial burden of waste management falls on the companies introducing batteries to the market rather than on consumers or public budgets.

Labelling and Reporting Requirements

All batteries placed on the German market must carry the crossed-out wheelie-bin symbol, which informs consumers that they must not dispose of them with mixed municipal waste. Batteries containing heavy metals require additional chemical markings indicating the presence of substances such as lead, cadmium or mercury.

In addition to labelling, companies must report the quantities of batteries they place on the market and the volumes collected through the take-back systems. These reports are generally submitted annually to Stiftung EAR, although certain categories or collection systems may require more frequent updates depending on their operational or regulatory conditions.

A Practical Example for an EU Online Store

Imagine an online retailer based elsewhere in the European Union that starts offering wireless headphones to customers in Germany. The headphones contain an integrated rechargeable cell, which means the seller becomes subject to BattG obligations. Before shipments begin, the retailer must register with Stiftung EAR, obtain a valid BattG number, ensure that used batteries can be collected and returned through an appropriate system, label the products correctly and prepare to file annual volume reports. Only after fulfilling these steps can the company operate in Germany without regulatory risk.

Why This Matters

The BattG framework is built on the principle of Extended Producer Responsibility: the company introducing batteries to the market is responsible for the environmental and financial impact of their end-of-life stage. For businesses, this introduces administrative duties and additional costs, yet it also ensures that their operations in Germany are legally secure and fully aligned with European environmental standards. Proper compliance protects both market access and long-term business continuity, making it an essential component of any cross-border sales strategy involving battery-powered products.

Comparing Centralised Systems with Germany’s Multi-Register Framework

Packaging: Centralised Registers vs. LUCID & the VerpackG Structure in Germany

In some EU countries, packaging obligations can be managed through a single national system. Germany, however, divides the process into two coordinated elements. Administrative registration is carried out through LUCID, operated by the Zentrale Stelle Verpackungsregister (ZSVR), while the practical handling of recycling obligations is managed through a commercial agreement with a dual system. Since July 2022, every form of packaging requires a LUCID registration entry, regardless of whether the packaging is used for consumer goods, group packaging, service packaging or business-to-business deliveries.

Household-bound packaging must also be licensed with a dual system, which takes over responsibility for nationwide collection and recycling. Packaging intended solely for business customers may not require such licensing, but must still be declared in LUCID and handled under separate take-back obligations.

The key practical difference is that, unlike countries that keep everything within a single platform, Germany obliges sellers to work along two parallel tracks: the formal registration in LUCID and the contractual licensing with a dual system. The data provided in both places must match precisely, which often requires careful internal coordination.

Electronics: Centralised Registers vs. ElektroG & Stiftung EAR/WEEE in Germany

For electrical and electronic equipment, Germany operates through the ElektroG framework, administered by Stiftung EAR. Instead of a unified national platform that handles all reporting, sellers must register directly with this specialised authority and receive a WEEE number before marketing any device in Germany.

Companies without a German establishment must appoint an authorised representative, known as a Bevollmächtigter. Without such a representative, neither registration nor legal sale is possible. ElektroG requires that the WEEE registration number be visible when products are offered for sale and also included on sales documentation. This is not a product label; devices must still carry the crossed-out bin symbol and manufacturer identification on the product itself.

In practice, Germany replaces the idea of “one system to handle everything” with a dedicated supervisory authority that enforces its own registration procedures, guarantees, reporting cycles and compliance audits.

Batteries: Centralised Registers vs. BattG & Stiftung EAR in Germany

Battery and accumulator obligations in Germany fall under BattG and are also administered by Stiftung EAR. Once registration is approved, producers receive a BattG registration number. Sellers of portable batteries must participate in an approved take-back system, while producers of industrial or automotive batteries must independently organise the free collection and proper processing of spent batteries.

Every battery must be labelled with the crossed-out bin symbol, and batteries containing heavy metals require additional markings. The German approach is therefore built on the same principle as other EU systems — Extended Producer Responsibility — but executed through a standalone authority rather than a single central register.

Differences in Reporting: Frequency, Scope and Format

Reporting obligations differ significantly across the three German frameworks. For packaging, companies must report data both to their dual system and to LUCID. The dual system sets its own reporting frequency, which may be monthly, quarterly or annual. LUCID requires at least an annual volume declaration, often with an initial forecast followed by later corrections. High-volume producers must additionally submit a Vollständigkeitserklärung by mid-May each year, confirmed by an authorised auditor.

Under ElektroG, reporting is more granular. Many categories of B2C electronics require monthly volume updates, followed by an annual statistical report. The specifics depend on the device category and whether it falls under B2C or B2B classification.

For BattG, producers report their placed-on-market volumes to Stiftung EAR and, in the case of portable batteries, also to the collection system they participate in. Reporting is generally annual, although some schemes impose more frequent submissions to maintain operational accuracy.

Common Challenges for Companies Entering the German Market

Many new entrants begin by searching for a single “German equivalent” to a centralised national register. This leads to delays, because Germany uses three distinct compliance pillars that must each be addressed independently. Packaging obligations are sometimes misunderstood, especially regarding business-to-business packaging, which still requires a LUCID registration even if it is not “household-bound.”

Foreign companies frequently overlook the requirement to appoint an authorised representative for electronics and batteries, which stops the registration process in its tracks. Another recurring issue is confusion between the eANV/ZKS-Abfall platform — which handles hazardous-waste documentation — and the producer-responsibility registers, even though they serve entirely separate functions.

Data inconsistencies between a dual system and LUCID are also common, as is the omission of the WEEE number on product listings and invoices. Since mid-2022, marketplaces are legally required to block offers from sellers who do not comply with packaging regulations, which means incomplete registrations can immediately disrupt sales.

Summary: No Single Register = Three Independent Systems

Entering the German market means operating within a decentralised compliance landscape. Instead of one central environmental register, sellers must handle packaging obligations under the VerpackG and LUCID, electrical and electronic device obligations under ElektroG via Stiftung EAR, and battery obligations under BattG, also administered by Stiftung EAR. Each system has its own registration procedures, reporting expectations and audit structures.

Core Obligations for Sellers Entering Germany

Any company planning to sell in Germany must identify which product groups it introduces to the market and which German rules apply. Packaged goods require a LUCID registration and, for household-bound packaging, participation in a dual system. Electronic devices require a valid WEEE number and, for companies without a German presence, an authorised representative. Products containing batteries require BattG registration, access to an appropriate collection system, proper product labelling and ongoing reporting.

Because German marketplaces are legally obliged to verify compliance, these requirements must be fulfilled before sales begin. Without valid registration numbers, sellers simply cannot enter the market.