Do I need to register in LUCID as a Dutch web shop supplying to Germany?

LUCID obligation applies from the first package to Germany

Yes, a Dutch online shop that supplies packaged products to end users in Germany registers in LUCID, the German packaging register. Germany has no minimum threshold: whereas the Netherlands only imposes a registration obligation with Verpact from 50,000 kilos of packaging per year, in Germany the first package is already sufficient. One package per year to a German customer is enough to make an online shop a producer within the meaning of the register.

The fact that Dutch turnover remains below the Verpact threshold does not change this: the Dutch threshold says something about the Dutch market, not the German one. Anyone placing packaged products on the German market under their own name falls under the German registration obligation, regardless of what does or does not apply in the Netherlands. In practice, this is also enforced by the marketplaces themselves: German and international platforms request the LUCID registration number and exclude sellers who cannot provide that number, often faster than the regulator intervenes. Anyone selling to German customers via a marketplace will encounter this check before any official enforcement process begins.

What Article 44 and LUCID stipulate on this

Article 44 of Regulation (EU) 2025/40 makes registration in the producer register of each Member State where packaging is first placed on the market a prerequisite for placing those packages on the market: packages from an unregistered producer may not be placed on the market. For Germany, that register is LUCID, managed by ZSVR, and that register's own rules contain no minimum quantity. This explains why the Dutch threshold at Verpact does not provide an exemption for Germany: they are two separate registers each with their own conditions, and the PPWR obligation to register applies per country where packaging is first placed on the market.