Selling in Germany under GPSR: LUCID, WEEE and battery registration

Updated 29 October 2026

The GPSR is the same in every EU country. What changes when you ship to Germany is which registers you need and who has to act for you inside Germany. For a seller based outside Germany — in China, the UK or another EU country — three German registers matter, and all three now expect a representative in Germany.

Packaging: LUCID and, since August 2026, a representative

On 12 August 2026 the EU Packaging and Packaging Waste Regulation (PPWR) started to apply. In Germany it works together with the new Packaging Law Implementation Act (VerpackDG), which replaced the Packaging Act (VerpackG). Registration, system participation and volume reports stay. What changed for cross-border sellers:

A representative is now mandatory. If you are based abroad, have no German branch and ship packaged goods directly to consumers in Germany, you must appoint an authorised representative for extended producer responsibility. Before, this was voluntary. You name the representative when you first register; producers who are already registered are asked to add one when they log in.
LUCID stays with you. Registration in the LUCID Packaging Register remains your own responsibility. The representative takes over the other packaging obligations.
Shipping packaging always counts. Boxes, mailing bags, tape, labels and filling material used to ship to consumers are always subject to system participation. You need a contract with a dual system (Systembeteiligung) and you report the same quantities to LUCID.
Marketplaces check before you sell. A marketplace must obtain your LUCID registration confirmation and a self-certification that you meet your producer obligations. Without them, your products may not be offered. A fulfilment provider must stop serving you if the information is missing and you do not fix it in time.

Electrical and electronic equipment: stiftung ear through a German representative

Electrical and electronic equipment is registered with stiftung ear, the national register under the Electrical and Electronic Equipment Act (ElektroG), which issues the WEEE registration number marketplaces ask for. A company abroad cannot register itself. It must mandate an authorised representative with a branch in Germany, who takes over the producer obligations in their own name.

The mandate must be in writing and in German, signed by both sides, for at least three months.
One representative covers all of a producer’s brands and equipment types.
stiftung ear processes the registration only after it has confirmed the mandate. The representative is then published next to your registration.

Batteries: the same structure

Portable, SLI, LMT, electric-vehicle and industrial batteries also need a registration at stiftung ear before you place them on the German market. A producer without a subsidiary in Germany cannot register itself; a German authorised representative applies on its behalf. You register per brand and battery category, and you may only sell once the registration has been issued.

Who checks products in Germany

Product safety enforcement belongs to the federal states (Länder). Their authorities check about 0.5 product samples per 1,000 inhabitants a year — around 50,000 products — and most states run their own product testing units. A committee of the states (AAMÜ) and their central office for safety engineering (ZLS) coordinate the work, with support from the federal institute BAuA.

Language

The GPSR requires instructions and safety information in a language consumers can easily understand, as determined by the member state where the product is sold (Article 9(7)). For Germany, plan for German on the product or packaging, in the instructions and in your listings. The GPSR label generator prints the standard warnings in German.

Checklist for Germany

An EU responsible person named on the product and in the listing — compare published provider prices.
LUCID registration in your own name, a dual-system contract and, if you ship from abroad, an EPR authorised representative.
stiftung ear registrations through a German representative for electrical equipment and batteries.
German-language safety information and warnings.
Your registration numbers entered in each marketplace.

Not sure which of these apply to your products? Run the compliance checker. The background is in our guides to packaging EPR and WEEE registration.

Frequently asked questions

Does my EU responsible person also cover LUCID and stiftung ear?

No. The GPSR responsible person is a product-safety contact for the whole EU. Packaging, electrical equipment and batteries each need their own German registration and, for sellers based abroad, a representative in Germany. Some providers offer several of these.

Can I register in LUCID myself from outside Germany?

Yes. According to the ZSVR, registration in the LUCID Packaging Register remains the producer’s own responsibility. The authorised representative takes over the other packaging obligations and is named when you register.

Sources

ohdock provides software tools and general information, not legal advice. Check the official texts, or ask a qualified adviser, for your situation.