I already have a German LUCID number. What else do I need?
Summary
A German LUCID number alone is not enough. Germany packaging also needs dual-system participation, an authorised representative if your business is not established in Germany, and declarations. LUCID is free, so the Germany price does not drop.
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Germany · Packaging
- Reporting for the year is included. Third-party scheme and authority fees are passed on at cost, never marked up.
A German LUCID number alone is not enough. Germany packaging also needs dual-system participation. A business not established in Germany needs an authorised representative too, under Regulation (EU) 2025/40 (the PPWR), Article 45(3). The quantities you place on the market are then declared for each period. LUCID registration is free, so holding it does not change the Germany packaging price: the service charges for the representative and the dual-system participation. Eldris arranges both and files the declarations.
What a LUCID number is, and what it is not
LUCID is Germany's packaging register, run by the Zentrale Stelle Verpackungsregister (ZSVR), and registering in it is free. A LUCID number shows that your business is on that register for the packaging it sells in Germany. It is not a contract with a dual system, and it does not appoint a representative to act for you.
The register is the first German packaging duty, not the whole of it. A seller of packaged products to German consumers registers in the LUCID packaging register and also joins a dual system for that packaging. The dual system is the scheme contract that takes your declared quantities and charges for them per kilogram by material. The register entry and the scheme contract are two separate things, and the number proves only the first.
A LUCID entry leaves three further gaps. It names no authorised representative. A business established outside Germany has needed one for its packaging since the PPWR began to apply on 12 August 2026. It covers packaging only, because electrical equipment and batteries register separately with stiftung ear. It also covers Germany only: a German registration does not cover any other country. What the PPWR changed for sellers already in LUCID is set out in the guide to LUCID and the PPWR.
The three things a LUCID holder still needs
A seller that already holds LUCID still needs three things in Germany. They are dual-system participation, an authorised representative where the business is not established in Germany, and declarations of the quantities placed on the market. Eldris contracts the dual system, appoints the representative and files the declarations.
Dual-system participation is the contract for your German packaging. The Germany packaging line covers it, with an allowance included. Dual-system fees above that allowance are charged per kilogram by material and passed through at cost.
The representative is the second. Under Regulation (EU) 2025/40, Article 45(3), a producer that sells directly to consumers in a member state where it is not established appoints an authorised representative there. Eldris includes the representative in the price where the law requires one. It is appointed under the power of attorney you sign, with Eldris as your single point of contact.
The declarations are the third. For each period, as the scheme sets it, you send Eldris the weight and number of units you placed on the German market. Eldris then files the declarations. Annual declarations, including nil returns, are included in each registration's price.
Why the Germany price stays the same
Holding a LUCID number does not change the Germany packaging price. LUCID registration is free, so an existing number removes nothing that the line charges for. What the service charges for is the authorised representative and the dual-system participation.
Sellers who already hold LUCID often ask for the representative alone at a lower price. The answer follows from what the line contains. On the pricing page, the Germany packaging line lists the LUCID register as free. It lists the dual-system participation as included, with an allowance of packaging. The free part is the part you have already done. The cost sits in what remains: the representative for a business established outside Germany, and the dual-system contract.
The line is one annual payment. It runs for 12 months from the date Germany confirms the registration and renews at the same price. Dual-system fees above the included allowance sit outside it. They depend on the weight and material you declare, and are passed through at cost, never marked up. The published tariffs, and an estimator for your own quantities, are on the scheme and authority fees page.
Electronics, batteries and the insolvency guarantee
A LUCID number covers packaging only. Electrical equipment and batteries register with stiftung ear, and equipment that private households can use also needs an insolvency-proof guarantee every calendar year. The guarantee's cost varies by device category, so it is quoted once your category is confirmed.
The registration duty for electronics comes from Directive 2012/19/EU, Article 16(1). It requires a producer that sells electrical equipment at a distance to be registered in the member state it sells to. In Germany the register is stiftung ear. A WEEE registration there is a separate file from your LUCID entry, with its own number.
The guarantee covers the cost of taking back equipment that private households can use. The producer proves it every calendar year, so it is an annual cost. Devices used only by businesses need prima facie evidence of exclusive commercial use instead, and the portal asks which products, if any, fall there. No figure for the guarantee appears in this guide, because the amount depends on the device category: Eldris quotes it once the category is confirmed. How the representative for electronics works is set out in the guide to the German WEEE authorised representative.
Existing contracts, and what to send Eldris
Tell Eldris about your LUCID number and any running contract before you pay, by replying to your quote. Taking over an existing representative or scheme contract, or transferring an active LUCID entry, is quoted separately. The portal then asks for your existing German numbers, so nothing is registered twice.
Some sellers hold LUCID with a dual-system contract already running, or with a representative appointed elsewhere. Moving that arrangement to Eldris is not priced in the calculator; it is quoted for your case once Eldris knows what is in place. A seller with LUCID and nothing else takes the Germany packaging line as it stands.
After payment, the portal asks for the six documents every country needs. They are your company certificate, a director's passport, any VAT certificates, a signed power of attorney, proof of your storefront and product photos. Germany adds no extra document, and its power of attorney is signed online. The portal also asks for your LUCID number and any German WEEE or battery numbers you hold. Eldris usually submits within 48 hours of payment and your product information. The services are set out on the Germany registration page. This question sits with the others sellers ask on the EPR questions page.
Frequently asked questions
Is LUCID registration free?
Yes. Registering in LUCID costs nothing, and the data reports and related activities of the Zentrale Stelle are free for producers too. The costs of German packaging sit elsewhere: the dual-system contract, charged per kilogram by material, and the representative a business established outside Germany needs.
Does a LUCID number cover other EU countries?
No. A German registration does not cover any other country, and each member state keeps its own register. A seller that sells packaged goods directly to consumers in another member state registers there too, with a representative where it is not established.
Do I need the representative if my company is in another EU country?
Yes, if you sell directly to consumers in Germany and your business is not established there. Regulation (EU) 2025/40, Article 45(3) turns on where the business is established, not on whether it is inside the EU. Eldris includes the representative in the Germany price where the law requires one.
Is the WEEE insolvency guarantee a yearly cost?
Yes. The producer proves the guarantee every calendar year, so it is an annual cost. Its amount varies by device category, and Eldris quotes it once your category is confirmed. Equipment used only by businesses needs prima facie evidence of exclusive commercial use instead of a guarantee.
Can Eldris take over my current dual-system contract?
Tell Eldris before you pay, by replying to your quote. Taking over an existing representative or scheme contract, or transferring an active LUCID entry, is quoted separately rather than priced in the calculator. The portal also asks for your existing German numbers, so that nothing is registered twice.
Who files the German packaging declarations?
Eldris does. You send the weight and number of units you placed on the German market for each period, and Eldris files the declarations. Annual declarations, including nil returns, are included in each registration's price.
Sources
- Directive 2012/19/EU on waste electrical and electronic equipment (WEEE) EUR-Lex
- Regulation (EU) 2023/1542 on batteries and waste batteries EUR-Lex
- Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) EUR-Lex
- LUCID packaging register (Zentrale Stelle Verpackungsregister) Germany
- stiftung ear, the German register for electrical equipment and batteries Germany
- Eldris prices and average registration times: the Eldris price list
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EPR registration from £185 per country per year, annual reporting included and the authorised representative arranged where the law requires one.
Packaging, electronics (WEEE) and batteries in 29 countries. Average registration time runs from 1 week (Germany packaging) to 9–17 weeks (Greece), or 4–5 months for Spain packaging without a Spanish tax number. See every price
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