As a rule, responsibility follows whoever first places the product on the German market; depending on your model, the registration may sit with you or with your importer. It should be clarified by contract, not left unassigned.
Concretely, whoever first places packaged goods on the German market must register in the LUCID packaging register and join a dual system before the first shipment; selling without it can bring a sales ban and fines. So the question is not whether it is done, but who is contractually assigned to do it — you or your importer — and that must be settled before launch.
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This content is for general information only and does not constitute legal advice. Please contact our team for an assessment of your specific circumstances.
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