EPR Full Service & Compliance for ElektroG4,
BattDG & VerpackDG | ECOPV-EU

A “producer” is any company that places packaging on the market of an EU member state for the first time on a commercial basis. This explicitly includes distance sellers who sell goods directly to end consumers in another member state, regardless of where their company is actually headquartered.

The primary goal of the PPWR is the EU-wide harmonization of extended producer responsibility (EPR). Cross-border online retailers without a branch in the EU destination country are considered producers in the end consumer’s country and are required to appoint a local authorized representative there. This regulation closes loopholes in international e-commerce. At the same time, the monitoring and liability obligations for platform operators have been tightened; they are now liable for unregistered sellers in the same way as under electrical and battery legislation.

The LUCID number is the official registration number issued by the Central Agency for Packaging Registers (ZSVR). Every company that commercially supplies packaged goods to the German market must apply for this number before making its first sale.

The number serves as transparent proof of legality in e-commerce and is available for viewing in the public manufacturer directory. It is a mandatory requirement for entering into a valid license agreement with a dual system. Online marketplaces such as Amazon or eBay verify the LUCID number fully automatically.

Registration is done entirely online and free of charge via the online portal of the Central Packaging Register (ZSVR). After entering your company information, tax ID, and the brand names you use, your LUCID number will be issued immediately.

Compared to WEEE applications, the process is straightforward. However, it is important that all brand names used – without exception – be entered exactly as they appear in the portal, since the registration is legally valid only for the brands listed there. Since August 2026, foreign distance sellers without a German branch have no longer been permitted to complete the registration themselves; instead, they are required to appoint an authorized representative based in Germany. Regardless of this, once the number is received, the fee-based volume licensing process with the dual system must be completed.

An Authorized Representative for Packaging is a person or company based in the respective EU destination country that, on behalf of a foreign manufacturer, legally fulfills the manufacturer’s packaging obligations in that country. As of August 12, 2026, this designation by the PPWR is legally mandatory for all cross-border distance sellers without a registered office in the destination country.

Anyone who delivers goods directly to private end consumers in another EU country without maintaining their own branch there may no longer sell without an authorized representative. The authorized representative handles registration in the destination country, ongoing data reporting, and contracts with the local waste disposal and recycling systems.
We already successfully provide this statutory service for the ElektroG and BattDG, and under the new VerpackDG, we also fully assume this role for your packaging volumes.

No. The LUCID registry is a purely national platform operated by the German Central Agency for Packaging Registration (ZSVR). It applies exclusively to the German market; separate country- or state-specific registrations must be completed for each additional EU destination country.

Although the PPWR harmonizes technical packaging standards across Europe, the administrative infrastructure remains decentralized. Anyone who ships across borders to multiple EU countries must register with the locally responsible registries in each individual country and pay country-specific fees. There is no central, Europe-wide packaging registry. To minimize this massive bureaucratic coordination effort, we consolidate your European EPR reports across countries into a single system.

The Single-Use Plastic Fund Act (EWKFondsG) requires manufacturers and importers of certain single-use plastic products (e.g., takeout packaging, beverage cups, or tobacco filters) to pay an annual special levy. The funds collected go into the state Single-Use Plastic Fund to compensate municipalities for cleaning public spaces.

The law transposes the EU Single-Use Plastics Directive into German law. Based on the polluter-pays principle, the costs for the disposal and removal of discarded plastic waste in parks and on streets are shifted from the general public to the distributors. The fund is managed digitally by the Federal Environment Agency (UBA), which distributes the funds to cities and municipalities according to a statutory points system. As of January 1, 2026, fireworks containing plastic components are also subject to this levy.

Registration is conducted entirely online via the DIVID portal of the Federal Environment Agency (UBA). Manufacturers and importers must enter their company information, tax ID numbers, all brand names used, and the exact product types as specified in Annex 1.

The DIVID platform serves as the central government interface. In addition to initial registration, it is used to process annual data reports and the settlement of the single-use plastic levy. The UBA also uses this portal to manage the distribution of fund resources to municipalities. Since registration is a legal requirement for lawful distribution, it must be completed before the first sale takes place.
We handle the entire technical and content-related setup of your account on the DIVID portal.