LUCID and the German Packaging Act: What Foreign Beauty Brands Must Do

Who is the producer, and therefore who registers

The Verpackungsgesetz does not care who designed the box or who printed it. It asks who was the first to place packaging, filled with goods, on the German market as part of a business. Section 3 of the Act calls that company the Hersteller, the producer, and the word misleads every brand we talk to, because it means the first distributor in Germany, not the manufacturer.

The duty attaches to the packaging that typically ends up with a private end consumer. For a skincare brand that is the jar, the carton, the leaflet, the cellophane, the shipping box, the filler and the tape. Secondary packaging that reaches the consumer, such as a gift box, counts. Transport packaging that stays with the retailer, such as the pallet wrap and the outer case, does not require system participation but has needed registration in LUCID since 1 July 2022, and the producer must take it back free of charge on request.

The three steps

Step 1: register in LUCID

LUCID is the online register run by the Zentrale Stelle Verpackungsregister, a foundation under the supervision of the Federal Environment Agency, based in Osnabrück. Registration is free, takes about twenty minutes, and is done in your own company's name, with your brand names listed. You receive a registration number starting with DE followed by thirteen digits. The register is public: anyone can look up whether a brand is registered, and competitors do. A company without an establishment in Germany can register directly. Under section 35 of the Act it may also appoint an authorised representative in Germany to take over its duties; the registration itself stays in the producer's name.

Step 2: sign a licence contract with a dual system

The dual systems are the private companies that organise collection and recycling of household packaging in Germany. There are around ten of them, with names such as Der Grüne Punkt, Interzero, BellandVision, Landbell, Reclay, Noventiz, Zentek and PreZero. You choose one, enter the expected quantities per material fraction for the year, and pay. The fractions are glass, paper and cardboard, ferrous metals, aluminium, plastics, beverage cartons and other composites. The fee is per kilogram and differs by material, with plastics the most expensive fraction and glass the cheapest. Most systems offer online contracts for small quantities with a minimum annual fee.

Step 3: report the quantities to LUCID

The same quantities you licensed with the system must be reported in LUCID, so that the register can cross-check. There is a planned-quantity report when you start and when you change, and a year-end report of the actual quantities by 15 May of the following year. Producers above the thresholds of 80,000 kilograms of glass, 50,000 kilograms of paper and cardboard or 30,000 kilograms of all other materials combined must additionally file an audited declaration of completeness by the same date. Prestige beauty brands rarely reach those volumes in their first years; drugstore brands do.

What it costs

The register is free. The money goes to the dual system, and for a brand of the size that reads this guide it is small. A worked example with rounded figures, to give the order of magnitude rather than a quote: a brand selling 10,000 units a year in Germany, each in a 60 gram glass jar with a 20 gram folding carton and 10 grams of plastic components, puts 600 kilograms of glass, 200 kilograms of paper and 100 kilograms of plastic on the market. At the fee levels the systems have been quoting, that is in the range of a few hundred euros a year, including the minimum fee, with the plastic fraction the largest single line even though it is the smallest by weight. Shipping boxes for direct-to-consumer parcels add paper weight and are often forgotten in the first estimate.

Two things cost more than the fees. The first is doing it late: the systems license from the date of the contract, not retroactively, and a competitor's warning letter for selling unlicensed packaging arrives with a lawyer's invoice. The second is doing it twice: brands that switch from direct shipping to a German importer sometimes keep paying for packaging the importer now licenses. Check who is the producer every time the route to market changes.

The marketplace and fulfilment rule

Since 1 July 2022, online marketplaces may not allow a producer to offer system-participation packaging on their platform unless the producer is registered in LUCID, and fulfilment service providers may not handle such goods for an unregistered producer. Amazon asks for the LUCID number in Seller Central and deactivates cosmetic listings without one. Zalando, Otto, the Douglas marketplace and eBay run the same check. A German fulfilment warehouse will ask for the number before the first inbound shipment. This is the point at which most foreign brands discover the law, usually two weeks before a launch date. Do it two months before.

What happens if you do not

• Packaging that is not registered may not be placed on the German market. The Act is explicit, and the register is public.
• Fines go up to 100,000 euros for missing registration and up to 200,000 euros for missing system participation.
• German competition law allows competitors and consumer associations to send a formal warning letter for selling without licensing, with a fee and a cease-and-desist declaration. Packaging compliance is a regular target of these letters, because the register makes the breach easy to prove.
• Marketplaces block the listing, and fulfilment providers refuse the stock.

Professional products, salons and devices

Packaging that ends up with commercial users rather than private households, for example a five-litre salon shampoo or a professional colour range sold only to hairdressers, is not system-participation packaging. It still has to be registered in LUCID, and the producer must take the packaging back free of charge where it accumulates, or arrange for that. In practice many professional brands license it anyway, because the same product often appears in a retail size, and the register does not distinguish.

Beauty devices follow a second law. An LED mask, a facial cleansing brush or a salon steamer is electrical equipment under the Elektro- und Elektronikgerätegesetz and must be registered with the stiftung elektro-altgeräte register, stiftung ear, before it is sold in Germany. A foreign producer without a German establishment must appoint an authorised representative for that registration. Products with built-in batteries fall under the Batteriegesetz in addition. These are separate registrations with their own fees and their own fines, and a brand that sells both a cream and a device needs all of them.

Austria, Switzerland and the EU Packaging Regulation

Austria has its own packaging ordinance and its own collection schemes, with ARA the largest. Since 1 January 2023, a distance seller without an establishment in Austria that ships packaged goods to Austrian consumers must appoint an authorised representative in Austria, who takes over the registration and licensing duties. Unlike in Germany, where the representative is optional, in Austria it is mandatory. Marketplaces run the same check as in Germany.

Switzerland has no extended producer responsibility law for sales packaging. There is a prepaid disposal fee on glass beverage bottles and voluntary schemes for PET and aluminium, none of which apply to a cosmetic jar. A brand shipping to Switzerland has customs and the Swiss responsible person to deal with, not packaging licences. The guide on landed cost covers the Swiss customs side.

The EU Packaging and Packaging Waste Regulation has applied since 12 August 2026. It keeps extended producer responsibility national, so LUCID and the dual systems stay, but it harmonises the definitions, requires producers without an establishment in a member state to appoint an authorised representative for producer responsibility in each member state where they first make packaging available, and introduces harmonised packaging labels from August 2028. Germany is adapting the Verpackungsgesetz to it. For a foreign brand the practical reading is that the optional German representative will become the rule across the EU, and that choosing a service provider who can act in Germany, Austria and France at once saves three contracts.

The LUCID checklist

• Decide who the producer is for each route to market: importer, your EU entity, or you.
• Register in LUCID in the producer's name with all brand names, before the first sale. Note the DE registration number.
• Estimate packaging weights per unit and per material fraction, including shipping boxes and inserts for direct-to-consumer parcels.
• Sign a dual system contract for the planned quantities; keep the contract and the system's confirmation for marketplace checks.
• Enter the same planned quantities in LUCID; diary the year-end report for 15 May.
• Give the LUCID number to Amazon, Zalando, Otto, Douglas marketplace and your fulfilment provider before onboarding.
• Register transport and professional packaging in LUCID even where no licence fee applies.
• Check stiftung ear and the Batteriegesetz if you sell devices.
• Appoint an authorised representative in Austria if you ship to Austrian consumers.
• Revisit who the producer is whenever you switch between direct shipping, EU stock and an importer.

Questions brands ask us

Tity Sonko

Founder and Managing Director of SONKO Consulting GmbH in Leverkusen, Germany. Tity works with international prestige beauty brands on their entry into Germany, Austria and Switzerland, from the first compliance check to the first retail order. She writes the weekly newsletter The DACH Prestige Signal.