Last week, Mr. Wang, who runs a German-focused online store in Shenzhen, was still feeling confident: his store’s annual sales were in the millions of euros, and he’d already obtained his LUCID registration number—so he thought he was in the clear. But when he checked, he found that his number was registered under the old Packaging Act (VerpackG) system in 2024, and the rules will change completely after August 12, 2026.

It’s a clean cut—the EU’s Packaging and Packaging Waste Regulation (PPWR) and Germany’s Packaging Act Implementation Act (VerpackDG) officially took effect on the same day, August 12, 2026, completely replacing the old packaging law. In today’s post, we’ll lay out the most common pitfalls for Chinese sellers all at once.

01

August 12 is a turning point—not just another case of “the boy who cried wolf.”

First, the conclusion: the LUCID registration number you already haveIt won't become invalid just because the method changes.. The German Central Packaging Registry (ZSVR) has made it clear that existing registration numbers remain valid; there is no need to re-register in the middle of the year, and existing recycling system contracts will remain valid through December 31, 2026.

However, ”valid” does not mean ”compliant.” The PPWR extends packaging responsibility from manufacturers to retailers, requiring sellers to accurately report packaging data for each SKU and to include a Declaration of Conformity (DoC) and technical documentation. The most critical requirement is:Starting August 12, 2026, non-EU companies must designate and register a local Authorized Representative (AR) in Germany.—Representatives from other EU countries don’t count.

In other words, the days when all it took was ”applying for a LUCID number” are over; what’s required now is a complete closed-loop process involving ”registration number + German AR + signing a contract with the recycling system + reporting packaging volumes + ongoing fee payments.”

If you’re facing a similar situation—selling products on the German marketplace but haven’t yet sorted out compliance with packaging and battery regulations, and are worried your store might be suddenly taken down—feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat/Phone: 18620388671), and we’ll help you implement a comprehensive compliance solution.

02

Packaging Method: The LUCID Number Is Just the First Step

The German Packaging Act (VerpackG) took effect in 2019. All sellers who sell packaged goods to end consumers in Germany must register with the LUCID system and then sign a contract with a dual recycling system (such as the Green Dot or Interseroh) and pay the required fees. Even if you sell just one plastic bag, you must still register.

Both steps are essential: First, obtain a free 13-digit registration number starting with “DE-P” from the LUCID website (which must be linked to a German VAT number); second, select a recycling system and pay based on the estimated packaging weight. The registration is only legally valid once the data from both steps matches in the LUCID system.

In terms of costs, recycling and disposal fees for small and medium-sized sellers typically range from 300 to 1,400 euros per year, plus an all-inclusive service fee of approximately 500 to 1,500 RMB for handling AR and annual reporting. May 15 of each year is the deadline for submitting packaging data for the previous year; failure to submit by this date may result in immediate fines.

Another point that’s often overlooked: the Packaging Act, the Battery Act, and WEEE registration numbersNot interchangeable. For electronic alarm clocks with batteries, all three items may need to be registered at the same time.

03

Battery Law OfH: The Quietest Thunder of 2026

The German Battery Act (BattG) is the national implementation of the new EU Battery Regulation (EU 2023/1542). Effective January 1, 2026, the old recycling system (ERS) will be phased out, and the OfH (Organization for Extended Producer Responsibility) system will be fully implemented. January 15 is the final deadline—all companies selling battery products in Germany must complete their registration with an OfH and submit reports on the volume of batteries placed on the market over the past three years, chemical composition reports, tax identification numbers, and authorized representative information.

Battery registration numbers that are not linked to a specific product will be revoked, and the goods may be seized by customs, subject to sales restrictions on the platform, and fines of up to 100,000 euros.

Non-EU companies must also designate a German Authorized Representative (AR): Effective August 18, 2025, the AR must be a company registered in Germany, have a physical office address (which the EAR will verify on-site), and provide proof of financial capacity. The entire registration process typically takes 60 to 90 days, so don’t wait until you see a pop-up notification on the platform to get started.

04

How to Check the Platform, and What Is the Cost?

Amazon has sent notifications to sellers on nine sites—Germany, France, Spain, Belgium, Italy, the Netherlands, Ireland, Poland, and Sweden—urging them to complete registration under the Packaging Act before the PPWR takes effect, or face compliance risks. The submission path is typically Performance > Account Status > Manage Your Compliance > Submit Compliance Information. Be sure not to check the box labeled ”I am not a manufacturer,” or your application will be rejected immediately.

The cost far exceeded expectations. In March 2026, a major seller in Shenzhen with annual sales exceeding 30 million euros faced a triple blow—a 120,000-euro fine, seizure of inventory, and placement on a blacklist—simply because it failed to renew its packaging law registration number, which triggered a WEEE inspection. In the first quarter of 2026, on the German marketplace alone, more than 12,000 Chinese sellers received EPR warning emails; approximately 30 percent failed to take timely corrective action and were forced to close their stores.

Most seriously, the Packaging Act imposes environmental fines of up to 200,000 euros, while the Battery Act imposes fines of up to 100,000 euros; criminal liability may also apply (in the event of a lithium-ion battery safety incident).

If you’re facing a similar situation—wanting to complete your German EPR registration, sign up for a recycling system, and file your annual report all at once—feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat/Phone: 18620388671), and we’ll help you implement a comprehensive compliance solution covering the entire process.

05

Five Things Chinese Sellers Should Do Now

First, identify your priority sites; don’t spread your energy too thin across nine countries. Focus on completing the major ones, such as Germany and France, first. European agencies are currently in the midst of their summer break, and processing times have slowed significantly; the longer you wait, the more difficult it will be to stay on track.

Second, log in to LUCID to verify that you can log in successfully and that your company information is accurate. If you already have an account, simply update it and link your AR.

Third, immediately check the OfH binding status of battery products; if they are not bound, have a compliant German AR re-register them.

Fourth, review the packaging materials and estimated weight for each SKU, prepare the declaration data in advance, and design packaging that uses a single material whenever possible to comply with the new regulations.

Fifth, keep a close eye on annual renewals—having your account expire is the most basic mistake you can make.

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