Exporting to Germany — packaging law (LUCID), VAT and EU rules
Germany is the EU's largest market, and it enforces one obligation more consistently than most member states: extended producer responsibility for packaging. Exporters who have cleared the EU's product rules still get caught by this one.
Packaging: the obligation most exporters discover late
Under Germany's packaging law, whoever places packaged goods on the German market must register in the national packaging register (LUCID) and license the packaging through a dual system so that its collection and recycling is financed. The obligation can attach to the party that first puts the packaged product on the German market — which may be your German importer, or may reach back to you, depending on how the sale is structured.
This is not a customs requirement and it will not stop a shipment at the border — which is exactly why it gets missed. It is a market-access obligation that can surface later as a demand for registration, declarations and licence fees. Establish who is the producer for packaging purposes with your importer before you agree the Incoterm and the price.
Customs and import VAT
- Duty is assessed at the EU point of entry on the customs value, as anywhere in the union. Germany requires the importer to hold an EORI.
- German import VAT applies at the standard rate, and reduced rates apply to defined categories of goods. Confirm the current rate and whether your product falls in a reduced category — the categories are not intuitive.
- If you quote DDP, model the import VAT explicitly. A VAT-registered German importer normally recovers it; you generally cannot.
All the EU rules still apply
Germany does not waive anything: CE marking for regulated product categories, REACH for chemicals and articles, and the EUDR and CBAM regimes apply as elsewhere in the union. See the EU guide — and add the packaging obligation above to the checklist, because that is the German-specific addition.
Distribution, documents and reading the market
- Germany's retail channel is consolidated and demanding on packaging format, barcodes and delivery reliability — specifications are enforced, not negotiated at the dock.
- Invoice, packing list, transport document, certificate of origin; packaging registration and licensing evidence where you are the producer.
- For market data, Germany reports as part of the EU, so use EU-level series or German national statistics — the two will not match exactly.
Use the tools
- Market research — German and EU import data
- Exporting to the EU — VAT, CE, EUDR and CBAM
- Duty & landed-cost calculator
- How to estimate landed cost
Sources & further reading
German Customs (Zoll) ZSVR — packaging register (LUCID) EU Access2Markets
These guides summarise public material from the bodies named above. They are general information, not advice on a specific shipment, and they are not a substitute for a ruling from your customs authority or a qualified customs broker / consultant.
More guides
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- How to read trade data without fooling yourself
- How to estimate landed cost — FOB, CIF, duty and delivered
- The export document set: what is statutory and what is not
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