Received a LUCID Abmahnung (German warning letter): what to do now
A warning letter over a missing LUCID registration catches many sellers off guard. This page explains why these letters are sent, which deadlines apply and how you remove the cause for good. The content is general information, not legal advice.
Why a missing LUCID registration triggers warning letters
Anyone selling packaged goods to end customers in Germany must be registered in the LUCID packaging register before the 1st sale and must license their packaging volumes with a dual system. These duties come from the German Packaging Act and apply without any minimum volume, including small shops and marketplace sellers.
The register is public. Competitors and associations entitled to enforce competition law systematically check who sells without being registered, and send fee-based warning letters (Abmahnung) over the violation.
What a typical Abmahnung contains
The structure is almost always the same:
- A demand to sign a cease-and-desist declaration with a penalty clause: you commit to selling only while registered, and you promise a contractual penalty for every further violation.
- A short deadline, often just a few days up to 2 weeks.
- A bill for the other side’s legal fees.
The 4 most important steps after a LUCID warning letter
Note the deadline and respond. A warning letter does not go away if you ignore it. If you let the deadline pass, the other side can apply for a preliminary injunction, which makes everything considerably more expensive.
Do not sign the cease-and-desist declaration unchecked. Pre-drafted declarations are often broader than the violation requires and bind you for years. For the legal review and the reply to the other side, a lawyer for German competition law is the right contact. We do not provide legal advice and do not handle this part.
Remove the cause: register and license. Regardless of any dispute about the letter itself, the violation has to end. Only with a LUCID registration and system participation do you sell lawfully again. If you have signed a cease-and-desist declaration, only this protects you from the contractual penalty.
Keep the evidence. The registration confirmation, the licensing contract and your volume reports prove that the violation has been removed. You need these documents towards the other side, towards marketplaces and in court.
Sellers based in Germany register themselves
The LUCID registration is free of charge, takes about 15 minutes and is done directly with the register authority. In addition, you need a contract with a dual system covering your packaging volumes. You do not need an authorised representative; our service is for sellers without a German establishment.
Sellers without a German establishment need an authorised representative
Without an establishment in Germany you cannot fulfil part of the duties yourself. From 12.08.2026 the EU Packaging Regulation (PPWR) additionally requires an authorised representative based in Germany; otherwise shipping to German end customers is no longer permitted.
That is exactly our service: for 170 € per year we act as your authorised representative, handle the contact with the authorities and file your volume reports. You register in LUCID with our step-by-step guide; if you already have a LUCID number, you simply enter it in the order form.
Fines come on top of the warning letter
The Abmahnung is the private-law side. In addition, the authorities can punish violations of the German Packaging Act with fines of up to 200,000 € per case, and a sales ban is a further risk. Marketplaces such as Amazon check the LUCID number and delist offers without a valid registration.
Common questions on registration and past sales
Whether you need to report past periods, which deadlines apply and what exactly the authorised representative takes over: see our questions and answers.