For an answer to the question, please see the following excerpt from our FAQ page.
The Verpackungsgesetz (Packaging Act) defines a company that is the first to place packaging filled with goods on the German market as a 'producer' – and every producer is required to register with the LUCID Packaging Register by no later than 1 July 2022.
A 'producer' required to register is therefore:
any party who is the first to fill empty packaging with goods and place it on the German market (initial distributor);
- any party who is the first to import packaged goods into Germany, and place them on the German market (importer). As a matter of principle, the party who bears legal responsibility for the goods at the time they cross the border is regarded as the 'importer'. The producer can be
located outside of Germany, shipping goods to Germany; or
- located in Germany, ordering the shipment.
any party in the mail order business who is the first to fill and place shipment packaging on the German market (mail order company or online retailer);
An exception may apply to pre-participated service packaging: in the case of service packaging, the final distributor of this packaging can also request that the supplier/initial distributor of the empty packaging bears the registration requirement and other obligations; the final distributor will, however, still be required to register.