29/09/2026
Non-German seller registered in LUCID? You have until 12 November 2026 to fix this.
Most foreign sellers haven't noticed the change yet.
On 12 August 2026, Germany's Packaging Act (VerpackG) was replaced by the new Packaging Law Implementation Act (VerpackDG), alongside the EU's PPWR.
One change hits international e-commerce directly:
β Before: appointing an Authorised Representative in Germany was optional.
β
Now: it's mandatory.
Who this applies to:
You're based outside Germany, have no German branch, and sell packaged products or empty packaging directly to end consumers in Germany.
What you need to do:
β Appoint an Authorised Representative with a registered office or establishment in Germany
β Add them to your master data in LUCID
β Already registered before 12 August? The transition deadline is 12 November 2026
The detail many people miss:
Your AR takes over your EPR obligations in Germany. But registering in LUCID stays your own responsibility. You can't hand that part off.
New registrations must name the AR from day one. Existing registrants will see a missing-authorisation notice when they log in.
Under 7 weeks left. If you sell into Germany from abroad, check your LUCID account this week.
β»οΈ Repost this for anyone in your network selling cross-border into Germany.
Have you already appointed your AR, or is this news to you? π