Companies under obligation are called producers in the Verpackungsgesetz (Packaging Act). The law essentially defines producer as any party who is the first to fill packaging with goods and place it on the German market on a commercial basis.

• This is usually the party producing and packaging the product.

• It may also be retail companies that distribute own brands if the packaging is filled by a third party on the retail company's behalf before being handed over to the retail company and if the packaging bears only the name and/or brand of the retail company.

• Importers are also producers if they bear legal responsibility for the goods at the time they cross the border. 

• Mail order companies and online retailers that fill shipment packaging with goods for the first time also count as producers.

Every company that is a producer under the Verpackungsgesetz must register with the LUCID Packaging Register. If the company distributes its goods in packaging subject to system participation on the German market (retail, grouped and/our shipment packaging), the company must also pay for that packaging's recycling. To do so, the company has to conclude a system participation agreement with a system operator and regularly report its packaging volumes to both its system operator and the LUCID Packaging Register (data reporting).