100 grams or 100 tonnes? Regarding the question of whether you need to register in the LUCID Packaging Register, the packaging volume does not matter. If you are the party placing packaging filled with goods on the German market on a commercial basis for the first time, you are always required to register with the LUCID Packaging Register.
Companies with packaging volumes above a certain threshold are subject to another obligation: filing a declaration of completeness. These companies are required to file their volumes of packaging subject to system participation with the ZSVR by no later than 15 May of a given year for the previous year. Each declaration of completeness must be checked by an independent auditor registered in the LUCID Packaging Register. 

Here you can find further details about the declaration of completeness and how to fulfil these obligations.
 

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).  

Further information about packaging law obligations and how to fulfil them can be found in this checklist.
 

The packaging law requirements also concern companies that introduce their packaged goods in Germany on a commercial basis. The requirements imposed by the Verpackungsgesetz apply to importers if they bear legal responsibility for the goods at the time they cross the border. The question of who the importer is depends on the specific contractual provisions agreed between seller and buyer, i.e. the contractual parties can bilaterally decide who fulfils the obligations under German packaging law when importing goods.

In addition to the registration requirement in the LUCID Packaging Register, the importer under obligation must also comply with the other provisions of the Verpackungsgesetz (such as system participation and data reporting about packaging volumes).
 

For drop shipping, a seller offers goods without warehousing the goods themselves. The seller never touches the goods themselves. They buy them from a third party who packages the goods and sends them directly to customers, without themselves acquiring ownership of the goods.
A drop shipping seller is not a producer within the meaning of the Verpackungsgesetz, and is therefore not required to register with the LUCID Packaging Register. In the case of shipment packaging, the packaging law obligations (registration, system participation, data reporting about packaging volumes) lie with the respective shipper of the goods. However, a drop shipping seller has one statutory due diligence obligation: they must ensure that their contractual counterparty (i.e. the party whose goods they sell) fulfils their obligations under packaging law. If the drop shipping seller distributes their goods via an electronic marketplace, they must also provide the latter with evidence that their contractual counterparty is complying with the law as well. That is because the marketplace has to fulfil its own statutory due diligence obligations.
 

In the case of fulfilment, a company that sells goods to its customers tasks a fulfilment service provider with certain responsibilities such as warehousing, packaging, addressing and sending their goods. 
If you perform at least two of these four activities for your customers and have no ownership rights to these goods, you are considered a fulfilment service provider. In this case, you do not need to register with the LUCID Packaging Register or comply with other obligations under the Verpackungsgesetz. 

However, you do have a statutory due diligence obligation. This means that you have to check whether your ordering parties are registered with the LUCID Packaging Register and have concluded a system participation agreement. Otherwise, you are no longer allowed to offer your services to your customers, as goods from customers that do not fulfil their packaging law obligations are automatically banned from distribution.
 

Whether you need to register depends on whether your branch is legally independent (which is usually the case if it is registered in the commercial register). If your branch is legally independent, it must have its own registration with the LUCID Packaging Register. In addition, you have to check whether there are any other obligations.

Further information about packaging law obligations and how to fulfil them can be found in this checklist.
 

It is a registration number in the LUCID Packaging Register. This number is noted on the administrative act that was sent to you electronically by the ZSVR after registration. You can also find the number in your personal dashboard in the LUCID Packaging Register.
 

Packaging subject to system participation is packaging that typically accumulates as waste with private final consumers. This includes:

• Retail packaging (product packaging)
• Grouped packaging
• Shipment packaging
• Service packaging (packaging that is filled at the point of sale and used to enable or support handing over goods to the customers)

Packaging that is not subject to system participation includes:

• Transport packaging
• Reusable packaging
• Industrial packaging that typically does not accumulate as waste with private final consumers
• Single-use beverage packaging subject to deposit
• Retail packaging for hazardous contents

How do I check whether the packaging in which I sell my products is subject to system participation?
You can use the system participation requirement catalogue to find out. The catalogue is a digital database that you can use to search for the products that you sell in your packaging. It shows you whether the packaging of a product is subject to system participation. You can search the catalogue here.

An overview of packaging with and without system participation requirement can be found in this graphic.
 

When registering with the LUCID Packaging Register, you have to enter all brand names for which you as a producer bear producer responsibility. You enter these brand names subdivided into packaging subject to the system participation requirement and packaging not subject to the system participation requirement:

• If a certain brand name is used both on packaging that is subject to system participation and packaging that is not subject to system participation, please enter the respective brand name twice.
• If you want to place products on the German market without a brand name, please enter the company name.
   

You need to enter a VAT number or taxpayer reference number to register with the LUCID Packaging Register. If you do not have a VAT number, please indicate this during the registration process. You will then be prompted to enter your taxpayer reference number.
 

In this case, please enter the German VAT number.
 

You need to enter a VAT number or taxpayer reference number to register with the LUCID Packaging Register. 
Please check yourself what national identification number corresponds to the German VAT number or taxpayer reference number. The following information will help you: 

• The primary purpose of the VAT number is to regulate cross-border transactions within the EU for value-added tax reasons. In many countries (e.g. in Germany) this number is different from a regular identification or taxpayer reference number. If you do not have a VAT number, please indicate this when registering with the LUCID Packaging Register. You will then be automatically prompted to enter a taxpayer reference number.
• The taxpayer reference number is the number that the tax authority assigns to every taxable natural or legal person. It is uniquely assigned to one single taxable person. Companies generally are assigned a taxpayer reference number that they are required to include in their tax returns and invoices.

Are you sure that neither a VAT number nor a taxpayer reference number is assigned to your company? If that is the case, please enter your personal taxpayer reference number.