If you sell on Shopify and ship even a single parcel to Germany, you are already within the scope of the VerpackG, the German Packaging Act. It is not a formality reserved for large companies: the obligation kicks in from the very first unit placed on the market, with no minimum threshold. In this guide we look — practically and without jargon — at what being compliant actually means: registration on LUCID, a contract with a dual system, and the Datenmeldung (the quantity declaration) which, as we will see, has to be filed twice.
The goal is to give you a clear map of the three distinct obligations the law imposes, so you can see where you stand today and what you are missing. EPR Pack Report exists precisely to automate the most tedious part of all this — calculating packaging weight order by order — but the responsibility to register and declare stays with you: it's worth understanding the full picture.
What VerpackG is and why it concerns you too
The Verpackungsgesetz (VerpackG) is the German law that implements Extended Producer Responsibility (EPR) for packaging. The principle is simple: whoever first places packaging on the German market — filling it with goods destined for the final consumer — is responsible for its collection and recycling, and must contribute financially to the system that handles it.
For a foreign Shopify merchant shipping to customers in Germany, this means that the packaging you use (the box, the mailer, the bubble wrap, the tape, the label) makes you a producer under the law. It doesn't matter where your company is based: what matters is where the parcel ends up.
The point that surprises many is the absence of a de minimis threshold: there is no minimum volume below which you are exempt. Even a single order triggers the obligations.
The three distinct (and separate) obligations
The most common mistake is to think that VerpackG compliance is a single procedure. In reality there are three distinct steps, each with its own function. Skipping one means you are not compliant even if you have done the other two.
1. Registration on LUCID
LUCID is the public packaging register run by the ZSVR (Zentrale Stelle Verpackungsregister). Registration is one-off and must be completed before you start selling in Germany. You receive a registration number (the EPR-Registrierungsnummer) that platforms and marketplaces can ask you for.
It's a free and relatively quick step, but it is the entry point: without LUCID registration you cannot be compliant.
2. Contract with a dual system
Registering is not enough. You must also sign a contract with a dual system (duales System), i.e. one of the private operators authorised to organise the collection and recycling of packaging: among the best known are Der Grüne Punkt, Interzero and Reclay, but there are others. The dual system is who you pay your eco-contributions to, calculated on the weight and material type of the packaging you place on the market.
This contract is mandatory: it is the mechanism through which you actually fund recycling. LUCID registration and the dual-system contract run in parallel and must be consistent with each other.
3. Datenmeldung: the quantity declaration (twice)
Here lies the German peculiarity. The Datenmeldung — the declaration of the packaging quantities placed on the market — must be reported twice, with the exact same figures: once to the dual system you have a contract with, and once to LUCID. The data must match; any discrepancies are exactly what the register checks.
The declaration itself has two parts:
- Planmengenmeldung — the quantities forecast for the current year. It is an estimate of how much packaging you expect to place on the market.
- Istmengen (or Jahresabschluss-Mengenmeldung) — the actual quantities for the year just ended, as a final report.
Both must be filed, typically at the start of the year: you declare the actuals for the closed year and the forecast for the new one.
How often do you declare?
A recurring question is: how often do I have to declare? The answer is not rigidly fixed by law. The frequency of the Datenmeldung depends on the contract with the dual system you chose: it can be annual, quarterly or monthly. LUCID aligns with the frequency agreed with the dual system.
In practice, it's the nature of your contract that sets the rhythm of the declarations. For a small or medium Shopify merchant, an annual cadence is common, but it's worth checking the specific terms of your own dual system.
What about the Vollständigkeitserklärung?
You may have heard of the Vollständigkeitserklärung (VE), the "declaration of completeness" certified by an auditor and to be filed by 15 May of the following year. It's important to clarify that it only concerns companies with very high volumes: over 30 tonnes of plastic or 50 tonnes of paper/cardboard per year.
In other words: it concerns almost no small or medium Shopify merchant. If your volumes are far from those thresholds, you can set it aside — but it's good to know it exists, in case your business grows.
The data format: XML
Unlike other countries (in Italy, for example, everything is filled in online), in Germany the declaration goes through an XML file. You upload it directly to the LUCID portal and, separately, in the format required by your dual system.
Watch out for one operational detail: the formats of the different dual systems are not identical to one another. The file Interzero needs is not necessarily structured like the one Der Grüne Punkt needs. This is exactly the kind of repetitive, error-prone work that's worth automating: EPR Pack Report calculates weights by material from your real Shopify orders and generates the export in the correct format, both for LUCID and for the dual system.
The fines: up to €200,000
VerpackG is not a recommendation. In case of a breach, fines reach up to €200,000, and — an aspect often underestimated — an immediate distribution ban applies: marketplaces are required to block unregistered sellers. This means non-compliance is not just a financial risk; it can translate into your sales to Germany stopping overnight.
Summary: VerpackG obligations in a table
| Obligation | What it is | When | Notes |
|---|---|---|---|
| LUCID registration | Enrolment in the ZSVR register | One-off, before selling | EPR number mandatory |
| Dual-system contract | Agreement with Der Grüne Punkt, Interzero, Reclay… | Before selling | Mandatory, funds recycling |
| Planmengenmeldung | Forecast quantities, current year | Start of year | Estimate |
| Istmengen / Jahresabschluss | Actual quantities, year ended | Start of year | Final report |
| Double declaration | Same figures to LUCID + dual system | Per contract (annual/quarterly/monthly) | Data must match |
| Vollständigkeitserklärung | Certified completeness declaration | By 15 May of the following year | Only > 30 t plastic or > 50 t paper |
| Minimum threshold | None (zero de minimis) | — | Obligation from the first unit |
| Maximum fine | Up to €200,000 + distribution ban | — | Marketplaces block unregistered sellers |
What to do now
If you ship to Germany, the logical order is: register on LUCID, sign a contract with a dual system, and then organise the quantity calculation so you're ready to declare. The first two steps are bureaucratic and done once; the third is recurring, and it's the one that eats your time month after month if you handle it by hand in a spreadsheet.
Do you also sell in Italy or France? The rules change quite a bit. We have a guide to CONAI for e-commerce in Italy and one on Citeo and EPR in France, plus a comparative European guide that puts the three countries side by side.
EPR Pack Report does not replace your legal responsibility, but it removes the most fragile part of the process: the manual calculation of packaging weight and the preparation of the files. You remain the sole party responsible for the declaration; we make sure the figures are ready and correct.