Germany EPR (VerpackG) for Shopify

Germany EPR for Shopify Merchants in 2025: What You Actually Need to Know

If you're selling to Germany through Shopify and dealing with VerpackG compliance feels like navigating a bureaucratic maze, you're not alone. Here's what you need to know without the legal jargon.

The Bottom Line (Skip Ahead If You're Rushed)

Selling packaged goods in Germany means you need to register with LUCID, join a dual system for recyclable packaging, and report your volumes by material type Ecosistant Sustainable-markets. The main deadlines are December 31st for next year's forecast and May 15th for last year's actual volumes LUCID Packaging Register: Background and Guide – ecosistant. High-volume sellers (80+ tons glass, 50+ tons paper, or 30+ tons lightweight materials) need an audited Declaration of Completeness You just received a notice from the Central Agency to submit a Declaration of Completeness and need a reliable and fast support? - Landbell.

EPR One takes your Shopify orders and turns them into the XML files LUCID and dual systems need, you review the numbers and submit them yourself. Currently Germany-only, but built to expand.

What VerpackG Actually Means for Your Store

Germany's Packaging Act (VerpackG) requires anyone distributing packaged goods to German consumers to handle three things: register in LUCID, participate with a dual system, and report packaging volumes German Packaging Act (VerpackG): A 2025 Guide to International Packaging Laws (Part 1) - Tetra Tech Sustainable Markets. The law covers anyone placing packaging on the German market for the first time, manufacturers, importers, and yes, Shopify merchants shipping to Germany.

"Private final consumers" isn't just households. It includes restaurants, hotels, small offices, anywhere packaging ends up in household-like waste streams. Your cardboard mailer, the plastic poly bag, even the packing tape? All count.

The Packaging Types That Matter

Retail packaging is what your product comes in, the box, the protective wrap, everything the customer receives.

Shipment packaging is your mailer boxes, envelopes, bubble wrap, tape, and fillers. All of it counts.

Service packaging is filled at the point of sale (think takeaway cups). Unless you're running a physical store in Germany, you probably don't deal with this.

The ZSVR (the authority running all this) has a helpful infographic showing what's "subject to system participation", basically, what you need to pay the dual system to recycle.

The Three Steps You Can't Skip

1. Register in LUCID

LUCID registration is free and required before you sell anything packaged in Germany German Packaging Act (VerpackG): A 2025 Guide to International Packaging Laws (Part 1) - Tetra Tech Sustainable Markets. You'll get a registration number that proves you're compliant. Marketplaces can (and do) verify this number LUCID Packaging Register: Background and Guide – ecosistant, skip it and you could face sales bans.

The ZSVR offers step-by-step guides and a post-registration checklist on their site (verpackungsregister.org). Registration takes about 30 minutes if you have your company details ready.

2. Join a Dual System

Dual systems like Der Grüne Punkt, Interzero, or others handle the actual collection and recycling of your packaging in Germany. You sign a contract, pay fees based on your packaging materials and weights, and they take care of the rest.

The ZSVR maintains a list of approved dual systems with contact info. Fees vary by material and design, more recyclable packaging costs less.

3. Report Your Volumes

You report to both your dual system AND to LUCID. The numbers need to match exactly. This is where most merchants either spend hours in spreadsheets or pay consultants €1,500+ per year.

LUCID Reports: The Three Types That Matter

LUCID distinguishes between what you plan to do and what you actually did:

Planned volume report (Forecast/HPM1) - Your estimate for the coming calendar year. Must be filed by December 31st of the current year LUCID Packaging Register: Background and Guide – ecosistant. After that deadline, you'll need to file it as an intra-year report instead.

Intra-year volume report (HNM1) - Use this for adjustments during the current year, or if you missed the December 31st forecast deadline. It replaces your original forecast.

Year-end volume report (Actuals/HJM1) - The real numbers from last year. Due by May 15th of the following year LUCID Packaging Register: Background and Guide – ecosistant. After May 15th, you'll need supplementary reports for corrections.

Your dual system agreement might require more frequent reporting, check your contract.

2025 Deadlines (Mark Your Calendar)

December 31, 2024 - Last day to file your 2025 forecast. Miss this and you're filing an intra-year report.

May 15, 2025 - Deadline for 2024 actual volumes. Also the deadline if you need to submit a Declaration of Completeness for high volumes.

About That Declaration of Completeness

If you exceeded any of these thresholds last year, you need an audited Declaration of Completeness by May 15th:

Glass: 80,000 kg or more
Paper/paperboard/cardboard (combined): 50,000 kg or more
Lightweight materials (metals, plastics, beverage cartons, composites combined): 30,000 kg or more You just received a notice from the Central Agency to submit a Declaration of Completeness and need a reliable and fast support? - Landbell

The ZSVR can also require a Declaration even below these thresholds Packaging law: Declaration of completeness if they think something's off. The audit must be done by registered experts, you'll find them in LUCID's auditor register.

What "Being Compliant" Looks Like Day-to-Day

Most merchants follow this flow:

Get your LUCID number and dual system contract sorted before selling
Use ZSVR's catalogue to classify your packaging (retail vs. shipment vs. other)
Track what you're actually shipping to Germany, by material and weight
Report planned volumes before year-end, actuals by mid-May
If you're high-volume, coordinate your Declaration of Completeness audit early

Sounds simple. In practice? It's tracking hundreds or thousands of SKUs, figuring out if that plastic film is LDPE or PP, weighing individual components, and keeping it all updated when you change suppliers.

How EPR One Handles This (Without the Spreadsheet Headache)

Quick disclaimer: EPR One generates the files, you're still the declarant who reviews and submits them. You remain responsible for accuracy.

What's Live Now for Germany:

Portal-ready XML + CSV - Download HPM1 (planned), HJM1 (actuals), and HNM1 (intra-year) files formatted for LUCID and major dual systems. Plus human-readable CSVs so you can actually see what you're submitting.

Map materials once, use everywhere - Assign packaging materials and weights at the product or variant level. Create presets for your standard "small box with poly bag" setups and bulk-apply them by product type, tag, vendor, or search.

Country and variant overrides - Need different packaging for one variant? Want to exclude dropshipping locations so you don't double-count? Override at the variant or location level.

Shipping packaging flexibility - Pick between:

Percentage uplift (e.g., add 15% of order weight as cardboard + plastic with your chosen material split)
None (product packaging only)
Or enable both product + shipping packaging

"Only what sold" validation - We only flag SKUs that actually shipped to Germany in your report period. No wasting time entering materials for that test product you listed two years ago and never sold.

Audit trail baked in - Timestamped records of every material mapping you accepted, every override you made, every report you generated, and every manual adjustment you entered.

Manual adjustments - Selling on Amazon.de too? While we're building CSV import, add manual adjustments for date ranges to include non-Shopify sales in your reports.

Dashboard that actually helps - See your compliance readiness percentage (based on registered vs. unmapped products weighted by actual sales), high-impact unmapped SKUs, live estimated weights/costs if you enter your fee rates, and upcoming LUCID/dual system deadlines.

Built for Multi-Country (Even Though Germany Is the Only Live Market)

The data model uses a master material list that maps to country-specific codes with versioning. Tag your product once as "Cardboard 91 - Corrugated board" and we'll translate it to Germany's PPK 21 code (and eventually France's PAP 21 or wherever else you expand).

Country-specific fields like Germany's reuse counts or France's recyclability bonuses are already in the database, just feature-gated until those countries go live.

Data stays in the EU - Hosted in Frankfurt, files stored in EU-Central AWS. No data leaves European jurisdiction.

Walking Through a Typical Setup

Step 1: Onboarding - Enter your LUCID and dual system registration numbers. Choose your packaging mode (product + shipping, shipping-only for importers, or product-only if you're doing your own fulfillment).

Step 2: Map your best-sellers first - Start with whatever sold most to Germany last year. Variants inherit from products unless you override them.

Step 3: Shipping packaging - Pick your method (percentage uplift with material splits, or none). Weight-based box rules are coming soon but feature-flagged for now.

Step 4: Exclusions - Mark digital products, exclude dropship/3PL locations to avoid double-counting.

Step 5: Validate - The app shows only SKUs sold to Germany for your chosen period and flags anything missing materials.

Step 6: Generate & submit - Pick HPM1, HJM1, or HNM1, download XML + CSV, review the numbers, and submit through your LUCID and dual system portals. (Forecasts project next year based on this year's trends, you can adjust before downloading.)

Common Scenarios (Solved)

"We're importers without our own brands." Use shipping-only mode. You still need LUCID registration and system participation for that shipment packaging.

"We dropship some products; others we fulfill." Use location exclusions to skip those dropship shipments. Only map materials for what you're actually placing on the market.

"We forgot to file our forecast by December 31st." File an intra-year report now. LUCID treats it as your current forecast.

"We need to correct our actuals after May 15th." You'll need to file a supplementary year-end volume report per ZSVR's guidance.

"We might hit high-volume thresholds this year." Start watching your totals now. Line up a registered auditor familiar with ZSVR's Declaration of Completeness guidelines before April so you're not scrambling.

The Accuracy and Liability Part (Read This Section)

You are the declarant. EPR One calculates and exports files, but YOU review and submit them to LUCID and your dual system.

We validate (flag missing weights, obvious inconsistencies), but validation isn't legal advice or a compliance guarantee.

Keep your CSVs, XML submissions, and the app's audit log. If you cross Declaration of Completeness thresholds, ensure it's audited per ZSVR guidelines You just received a notice from the Central Agency to submit a Declaration of Completeness and need a reliable and fast support? - Landbell. Fines can reach €200,000 for serious violations German Packaging Act (VerpackG): A 2025 Guide to International Packaging Laws (Part 1) - Tetra Tech Sustainable Markets.

Checklist Before You Start

✓ Do you have your LUCID registration number and dual system contract?

✓ Have you decided whether to track product + shipping, shipping-only, or product-only for this period?

✓ Do you have materials and weights for your top-selling SKUs? (Start there, validation is based on what actually sold to Germany.)

✓ If you're potentially high-volume, do you have a plan for getting your Declaration of Completeness audited?

What's Coming Next (Multi-Country)

EPR One's data model lets you tag materials once with a master list, then automatically applies country-specific codes as each market goes live. Germany is active; additional countries (France, Italy, others) will release as we finalize their mappings and validations.

Country-specific features like Germany's reuse indicators or France's recyclability/disruption flags are already modeled, just waiting behind feature gates.

Final Reality Check

German packaging law changes. Portal requirements update. Always cross-check your specific dual system agreement and the latest ZSVR guidelines for your reporting year. The official ZSVR website (verpackungsregister.org) is updated for 2025,bookmark it.

EPR One turns 200 orders into a LUCID report in about 3 minutes instead of 3 hours in a spreadsheet. Germany is live now. More countries are coming. You still review and submit everything yourself, we just handle the calculations and file formatting so you don't have to become a VerpackG expert to stay compliant.

Looking for the app? See EPR for Shopify.