Selling into Germany from stock in Portugal
What a seller shipping from Portuguese stock to German customers settles first: LUCID and the 2026 packaging rules, stiftung ear, batteries and language.
Five things settle before the first parcel goes to a German customer. A LUCID registration in the seller’s own name. A packaging authorised representative, if the seller has no German branch and sells directly to end users. A stiftung ear registration for any electrical equipment, and another for any battery it contains. And safety information printed in German. None of it depends on where the warehouse sits; it depends on who first makes the goods available in Germany, and to whom.
Goods released for free circulation in Portugal travel to Germany without customs formalities. Germany’s producer registers do not care about that part. They apply from the first unit sold to a German end user, and each one has its own rule and its own deadline.
1. Register in LUCID before the first sale
The Zentrale Stelle Verpackungsregister, which runs LUCID, defines the producer as whoever first fills packaging with goods and places it on the German market commercially. A foreign online seller shipping straight to German consumers is normally that party, for its own shipping and sales packaging.
Three details from the register matter more than the rest:
- Registration has to be finished before packaging filled with goods reaches the German market for the first time, not afterward.
- It is a personal duty. The producer applies itself; a third party cannot supply the information or declarations in its place.
- Whatever gets reported to a system operator gets filed with LUCID at the same time, automatically.
Registration runs alongside system participation, a contract with a licensed operator that funds collection and recycling. Producers under 10 tonnes of such packaging in the previous year may use a simplified route: one year-end report, filed by 1 June.
2. Appoint an authorised representative for packaging, from 12 August 2026
That date is when the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, began to apply. Alongside it, Germany’s new Packaging Law Implementation Act, the VerpackDG, replaced the old Verpackungsgesetz. The core obligations, registration, participation, reporting, did not change. Who has to carry them did.
Since that date, any company without a German branch that sells packaging or packaged products directly to end users needs an authorised representative. Directly here means without a retailer in between. That representative takes on the packaging obligations in its own name: system participation, volume reports, declarations of completeness. Two things still stay with the producer regardless: the LUCID registration itself, and any change to its details.
Watch one proposal closely here, because it does not help a manufacturer outside the EU. Article 45(3) of the PPWR is the provision behind this rule. On 10 December 2025 the European Commission proposed, in COM(2025) 982, suspending it until 1 January 2035. That suspension only applies to producers already established in the EU selling into another member state. Producers outside the EU stay fully in scope: a member state can still require them to appoint an authorised representative by written mandate. Packaging Journal reports the Council has stalled on the proposal after a majority of member states objected. For a non-EU manufacturer, plan around the German rule as it stands, not around a proposal that does not reach you.
3. Register electrical equipment through an authorised representative
Under the ElektroG, Germany’s WEEE law, stiftung ear tells foreign companies plainly: “you cannot register yourself.” A written mandate, in German, signed by both sides, running at least three months, has to be in place before stiftung ear will process a registration. The requirement mirrors the WEEE Directive itself. Article 17 of Directive 2012/19/EU requires a producer in one member state selling into another to appoint a representative there.
4. Register batteries separately, including built-in ones
stiftung ear also runs battery registration, and it works the same way. Register before placing batteries on the German market. Appoint a representative if the company is foreign. Join a producer responsibility organisation for each battery category sold. A cordless appliance brings both registrations into play at once, the equipment and the battery inside it.
Germany aligned its battery law with the EU Batteries Regulation (EU) 2023/1542 on 7 October 2025, replacing the previous law. The transport side of batteries, separate from this registration question, is covered in shipping lithium batteries from an EU warehouse.
5. Put safety information in German
The GPSR requires instructions and safety information in a language consumers can easily understand, and Germany’s product safety act, the ProdSG, names that language directly. The rule sits in § 6 ProdSG, amended with effect from 19 February 2026 (BGBl. 2026 I Nr. 29). Under it, the instructions and safety information required by Article 9(7) of the GPSR must be in German. The Cologne Chamber of Industry and Commerce describes this as covering safety-relevant information, instructions and warnings specifically, not every word on the pack.
Sector rules can add to this. Cosmetics labels, for example, follow the language rules of the Cosmetics Regulation, set out in holding cosmetics stock for the EU market.
What if a German distributor buys the goods instead?
The authorised-representative rule above is built around direct sales to end users, without a retailer between the seller and the buyer. A seller who sells only to a German distributor or retailer sits in a different position.
That does not remove the underlying questions; it moves them into the supply agreement. Before signing, a German trade buyer asks who is the producer for each layer of packaging and who registers the equipment and batteries. The buyer also asks whose name appears on the product. What European distributors ask before signing covers the rest of that list.
Plenty of sellers run both channels from the same stock: a web shop for consumers, a distributor for retail. The direct flow then carries the full set of registrations; the distributor flow gets settled contract by contract.
Sources, and how delivery from Portugal fits in
Once the five items above are in place, each German order is a parcel or a pallet from Portugal, with no customs step in between. VAT on those consumer sales runs on a separate track, covered in OSS, IOSS, and what they do not cover. Whether a given shipment travels as a parcel, a pallet or groupage is a carrier decision covered in parcel, pallet or groupage from Portugal.
None of the five items above is a fixed number a seller can copy from one shipment to the next. Each depends on the product, so the German register concerned and the seller’s own advisers are the ones who settle it for that product.
How EFC ships German orders from stock in Portugal
Stock for German customers sits at EFC’s base in Portugal, moves with its logistics partner, and ships once it has been released for free circulation. The five registrations above are not ours to hold. EFC does not register anyone in LUCID or with stiftung ear, and does not act as authorised representative for packaging, WEEE or batteries. It offers no view on which apply to a specific product. Marketplaces selling into Germany must check these registrations, so registration belongs before the listing goes up, not after the first order arrives. Where our GPSR Responsible Person role applies, for consumer products only, it is set out on responsible person.
Sources
| Label | Value | Source |
|---|---|---|
| LUCID registration | producer definition; registration before first placing; personal duty; third parties may not register | Zentrale Stelle Verpackungsregister, questions about registration, opened 2026-08-18 |
| Data reporting | same report to system operator and LUCID; simplified year-end report under 10 tonnes, by 1 June | Zentrale Stelle Verpackungsregister, data reporting, opened 2026-08-18 |
| 12 August 2026 change | PPWR and VerpackDG replaced the Verpackungsgesetz; basic obligations remain | Zentrale Stelle Verpackungsregister, what changed on 12 August 2026, opened 2026-08-18 |
| Packaging authorised representative | mandatory from 12 August 2026 for sellers without a German branch selling directly to end users; LUCID registration stays with the producer | Zentrale Stelle Verpackungsregister, authorised representative, opened 2026-08-18 |
| PPWR | Regulation (EU) 2025/40; applies from 12 August 2026 | European Commission, packaging waste, opened 2026-08-18 |
| Commission proposal | COM(2025) 982 of 10 December 2025; suspends Article 45(3) of Regulation (EU) 2025/40 until 1 January 2035 for EU-established producers; third-country producers stay in scope (recitals 6 and 8, Article 2) | European Commission, COM(2025) 982 final, opened 2026-08-18 |
| Proposal status | Council discussions halted after a majority of member states objected | EPR Spain, PPWR authorised representative deadline, opened 2026-09-25 |
| ElektroG registration | foreign companies cannot register themselves; written mandate in German, minimum three months | stiftung ear, applying for WEEE registration as a foreign company, opened 2026-08-18 |
| WEEE Directive | authorised representative for producers selling into another member state | Directive 2012/19/EU, Article 17, EU text on EUR-Lex, opened 2026-08-18 |
| Battery registration | registration before placing on the market; foreign companies need an authorised representative; producer responsibility organisation per category | stiftung ear, obligations of battery producers, opened 2026-08-18 |
| German battery law | new law replaced the previous one on 7 October 2025 | German Federal Environment Ministry, European Batteries Regulation, opened 2026-08-18 |
| GPSR language | instructions and safety information in a language consumers can easily understand | GOV.UK, EU Regulation 2023/988 on general product safety, detailed guidance, opened 2026-08-18 |
| ProdSG amendment | Gesetz zur Änderung des Produktsicherheitsgesetzes, BGBl. 2026 I Nr. 29, in force 19 February 2026; § 6: instructions and safety information under Article 9(7) GPSR in German | buzer.de, ProdSG as amended with effect from 19 February 2026, opened 2026-08-18 |
| Language in Germany | § 6 ProdSG summarised as German for safety information, instructions and warnings | IHK Köln, the German Product Safety Act 2026, opened 2026-08-18 |