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Already have a LUCID number? The changes to report before 12 November 2026

Short answer

Businesses registered under the old packaging law still count as registered, but changes to the registration must be made by 2026-11-12. Businesses without a German establishment must add their authorised representative after logging into LUCID. VerpackDG § 68 Abs. 2; ZSVR: Bevollmächtigung

The key facts at a glance

Deadline
2026-11-12: changes by already registered businesses. VerpackDG § 68 Abs. 2
First-time registration
Businesses with no earlier duty to register were to register by 2026-09-12 (that date has passed). VerpackDG § 68 Abs. 2
Old system participations
Those concluded before 2026-08-12 continue at most until 2026-12-31. VerpackDG § 68 Abs. 1
Representative is a change
The statute lists a change or end of the representative's mandate as a reportable change. VerpackDG § 6 Abs. 1 Satz 3
Fine tier
Late reports of changes: the EUR 10,000 tier (derived from the statute's tiers). VerpackDG § 66 Abs. 1 Nr. 2; VerpackDG § 66 Abs. 3
Dates of the packaging law2026-08-12 (passed)Packaging Regulation applies,German VerpackDG takes effect,representative duty starts2026-09-12 (passed)First-time registration deadlinefor those with no earlier duty2026-11-12Deadline for registeredbusinesses' changes (including therepresentative)2026-12-31Old take-back systemparticipations end at the latest
Figure 1. Dates of the packaging law

Is the old registration still valid?

Yes. A business registered under the old packaging law is deemed registered under the new one. VerpackDG § 68 Abs. 2

But changes the new law requires must be reported by 2026-11-12. VerpackDG § 68 Abs. 2

The register's notice: already registered businesses must adjust their entries and name their representative afterwards. ZSVR: Bevollmächtigung

Which changes must be reported

Changes to registration data, or a permanent end of the producer activity, must be reported to the register without delay. VerpackDG § 6 Abs. 1 Satz 2

That duty expressly includes a change or end of the authorised representative's mandate. VerpackDG § 6 Abs. 1 Satz 3

The designation of the representative needs confirmation by the register. VerpackDG § 5 Abs. 5

When the representative changes, the end of the old mandate must be reported to the register too. VerpackDG § 5 Abs. 6

A self-check list

  1. Log into LUCID and look for the representative section in your registration.
  2. If it is empty, first sign a written German contract with a German representative.
  3. Check that your chosen representative already has a representative login in LUCID; otherwise you cannot select it.
  4. Designate it in LUCID and wait for it to confirm in the system.
  5. While there, check brand names and packaging types and update them too.

Your representative must have a representative login in LUCID before you can select and designate it. ZSVR: Bevollmächtigung

The designation takes effect only after the representative has confirmed. ZSVR: Bevollmächtigung

What if you report late

Failing to report, or reporting wrongly or late, a change that must be reported is an offence. VerpackDG § 66 Abs. 1 Nr. 2

Under the statute's tiers this item is on neither the EUR 200,000 nor the EUR 100,000 list and falls into the remaining tier of EUR 10,000. VerpackDG § 66 Abs. 1 Nr. 2; VerpackDG § 66 Abs. 3

That fine tier is a reading of the statute's tiers. Whether a first-time naming of a representative counts as a "change" is for a German lawyer; do not wait for the deadline day.

What this guide did not verify

Not verified here: whether naming a representative for the first time is legally a "change", and whether the register deactivates old numbers without a representative. A German lawyer or the register must answer both.

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What sellers also ask

2026-09-12 has passed and I have not registered. What now?

That was the first-time deadline for businesses with no earlier duty. Failing to register is fined up to EUR 100,000. VerpackDG § 68 Abs. 2; VerpackDG § 66 Abs. 1 Nr. 1; VerpackDG § 66 Abs. 3

Register now, starting with the representative.

What happens to the old system contract?

System participations concluded before 2026-08-12 continue at most until 2026-12-31, subject to deviating private agreements. VerpackDG § 68 Abs. 1

What does a representative cost?

The register says to ask the representative for the cost. This guide found no public price it could verify. ZSVR: Bevollmächtigung

Where does each statement come from?

Every source below is a legal text or an authority page; click through to compare.

  1. VerpackDG § 5 Abs. 5 · read 2026-10-18
  2. VerpackDG § 5 Abs. 6 · read 2026-10-18
  3. VerpackDG § 6 Abs. 1 Satz 2 · read 2026-10-18
  4. VerpackDG § 6 Abs. 1 Satz 3 · read 2026-10-18
  5. VerpackDG § 66 Abs. 1 Nr. 1 · read 2026-10-18
  6. VerpackDG § 66 Abs. 1 Nr. 2 · read 2026-10-18
  7. VerpackDG § 66 Abs. 3 · read 2026-10-18
  8. VerpackDG § 68 Abs. 1 · read 2026-10-18
  9. VerpackDG § 68 Abs. 2 · read 2026-10-18
  10. ZSVR: Bevollmächtigung · read 2026-10-27

This guide summarises public legal texts and authority pages as general information. It is not legal advice. For your case, ask a licensed German lawyer.

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