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.
Goods released for free circulation in Portugal travel to Germany without customs, but Germany’s producer registers still apply from the first unit sold there. A seller that ships packaged goods to German end users registers in the LUCID Packaging Register before the first sale, and since 12 August 2026, a seller without a German branch that sells directly to end users also needs an authorised representative for packaging. Electrical equipment and batteries each need registration with stiftung ear, through an authorised representative for foreign companies, and safety information must be in German.
None of this depends on where the warehouse is. It depends on who first makes the goods available in Germany, and to whom.
Do I need to register in LUCID if I ship from another EU country?
Yes, if you are the producer for that packaging in Germany. The Zentrale Stelle Verpackungsregister, which runs LUCID, describes the producer as the party who is first to fill packaging with goods and place it on the German market on a commercial basis. A foreign online seller shipping directly to German consumers is typically that party for its shipping and sales packaging.
Three points from the register’s own pages matter most:
- Registration must be completed before packaging filled with goods is placed on the German market for the first time.
- Registration is a personal duty. The producer applies itself; the information and declarations may not be provided by third parties.
- Whenever a company reports packaging volumes to its system operator, the same report is also filed with LUCID.
Registration sits beside system participation: a contract with a licensed system operator that finances the collection and recycling of the packaging. A simplified reporting rule applies to producers that made available less than 10 tonnes of such packaging in Germany in the previous calendar year: they may file one year-end report, by 1 June.
What changed in German packaging law on 12 August 2026?
On 12 August 2026, the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, began to apply. With it, Germany’s Packaging Law Implementation Act, the VerpackDG, replaced the Verpackungsgesetz. The register states that the basic obligations, registration, system participation and data reporting, remain. What changed is who must fulfil them.
The largest change for sellers abroad is the authorised representative. From 12 August 2026, all companies without a branch in Germany that sell empty packaging or packaged products directly to end users in Germany, without an intermediary retailer, must appoint one. The representative takes on the obligations under the PPWR and the VerpackDG in its own name: system participation, volume reports, declarations of completeness and related duties.
Two things stay with the producer. LUCID registration, and any change to the registration details, cannot be handed to the representative. The representative’s details must be entered in LUCID before the goods are first made available in Germany.
One proposal needs reading closely, because it does not help manufacturers outside the EU. On 10 December 2025, the European Commission proposed, in COM(2025) 982, to suspend Article 45(3) of the PPWR until 1 January 2035. That is the provision making an authorised representative mandatory for producers established in one EU country that sell packaged products directly to end users in another.
The proposal expressly leaves producers established outside the EU in scope. Its text keeps the existing rules for them: member states may still require a producer from a third country to appoint an authorised representative by written mandate, or must ensure traceability and enforcement by other means. Packaging Journal reports that Council discussions on the proposal were halted after a majority of member states objected. For a non-EU manufacturer selling into Germany, the German register’s rule is the one to plan around.
Can a foreign company register with stiftung ear directly?
Not for electrical and electronic equipment. Under the ElektroG, the German WEEE law, stiftung ear tells foreign companies plainly: “you cannot register yourself.” A foreign company must mandate an ElektroG authorised representative in Germany. The mandate is in writing, in German, signed by both parties, and runs for at least three months. Once stiftung ear confirms the mandate, the registration application can be processed.
The requirement mirrors EU law. The WEEE Directive 2012/19/EU, Article 17, requires a producer established in one member state that sells electrical equipment into another member state to appoint an authorised representative there.
Do batteries need a separate registration?
Yes. stiftung ear also administers batteries. Before placing batteries on the market in Germany, a producer must be registered with stiftung ear. A foreign company placing batteries on the German market for the first time needs an authorised representative. Producers must also join a producer responsibility organisation for each battery category they sell, and report the quantities placed on the market.
The German battery law was aligned with the EU Batteries Regulation (EU) 2023/1542; Germany’s Federal Environment Ministry states that the new law replaced the previous one on 7 October 2025. Batteries built into a product still count. A cordless appliance brings both the equipment and its battery into scope. The transport side of batteries is covered in shipping lithium batteries from an EU warehouse.
Which language must product safety information use?
German. The GPSR requires instructions and safety information in a language consumers can easily understand. Germany’s product safety act, the ProdSG, as amended with effect from 19 February 2026, sets that language. Under § 6 ProdSG, for products within the scope of the GPSR, the instructions and safety information required by Article 9(7) of the GPSR must be written in German, and the Cologne Chamber of Industry and Commerce summarises the rule as covering safety-relevant information, instructions and warnings. The amending act was published in the Federal Law Gazette as BGBl. 2026 I Nr. 29.
Sector rules add their own language requirements. Cosmetics labels, for example, follow the Cosmetics Regulation, as set out in holding cosmetics stock for the EU market.
A worked example
Suppose a maker of cordless kitchen appliances from outside the EU releases its stock for free circulation in Portugal and sells to German consumers through its own web shop. The details are hypothetical, for the mechanics only.
Before the first German order, it holds four things. A LUCID registration in its own name, with its packaging authorised representative entered. A system participation contract covering its shipping and sales packaging, managed through the representative. A stiftung ear registration for the appliance under the ElektroG and for the built-in battery under the battery law, both through a German authorised representative. And German instructions, warnings and safety information in the box.
From then on, each order is a parcel from Portugal to a German address, with no customs formality in between. How VAT is charged on those consumer sales is a separate subject, taken up in OSS, IOSS, and what they do not cover.
What if a German distributor buys the goods?
The register frames the new authorised-representative obligation around sales made directly to end users in Germany, without an intermediary retailer. A seller that sells only to a German distributor or retailer, which then resells, is in a different position from one that ships parcels to consumers.
That does not make the questions disappear. It moves them into the supply agreement. Who is the producer for each layer of packaging, who registers the equipment and the batteries, and whose name and address appear on the product are all points a German trade buyer will raise before signing. What European distributors ask before signing lists the others.
Many sellers do both at once: a web shop for consumers and a distributor for retail. In that case, the direct flow carries the full set of registrations, and the distributor flow is settled contract by contract.
What does the seller check before the first German sale?
- Who is the producer for the packaging, the equipment and the batteries in Germany.
- The LUCID registration, the authorised representative and the system participation contract.
- ElektroG and battery registrations, with a written German mandate.
- German instructions and safety information, and the GPSR operator details on the product.
- The delivery mode for each type of order, from parcel to pallet, as covered in parcel, pallet or groupage from Portugal.
This is general information, not legal advice. Registration duties for a specific product are confirmed with the relevant register and the seller’s advisers.
How this runs at EFC
Stock for German customers can sit at EFC’s base in Portugal, run with its logistics partner, and ship from there once it has been released for free circulation. The registrations in this article stay with the brand. EFC does not register anyone in LUCID or with stiftung ear, does not act as authorised representative for packaging, WEEE or batteries, and gives no legal advice. Its GPSR Responsible Person role, for consumer products only, 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 | Packaging Journal, EU Commission wants to scrap authorised representative obligation for PPWR, opened 2026-08-18 |
| 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 legislation.gov.uk, 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 |