Grouped by subject. Every answer states the rule, the source and the date it was last checked. The whole library as one file: answers.md · answers.json
Marketplace sellers 14
I sell on a marketplace. What does Germany require for my packaging?
Every major marketplace selling to German buyers asks for your LUCID registration number, and none takes your legal duties over. You still need a dual-system licence, and since 12 August 2026 a German authorised representative if your company has no establishment in Germany.
I sell on Etsy. Do I need EPR in Germany?
Yes, from the first parcel to a buyer in Germany. Register yourself in LUCID, license your packaging with a dual system and add your LUCID number in Etsy under Shop Manager › Finances › Legal and tax information. If your shop is not based in Germany, you also need a German authorised representative since 12 August 2026.
I sell on Amazon. Do I need EPR in Germany?
Yes. Submit your 13-digit LUCID number in Amazon's “Compliance Information for Extended Producer Responsibility” portal and license your packaging with a dual system. If your company has no establishment in Germany, you also need a German authorised representative since 12 August 2026. FBA does not change that.
I sell on eBay. Do I need EPR in Germany?
Yes, if you sell as a business to buyers in Germany. Register yourself in LUCID, license your packaging (eBay offers a licence through its partner Lizenzero) and send your LUCID number to eBay in your account settings. If you are based outside Germany, you also need a German authorised representative; the licence does not cover that.
I sell on Kaufland.de. Do I need EPR in Germany?
Yes. Kaufland requires sellers on Kaufland.de to register in LUCID, and says the registration is made personally by the seller, regardless of where the company is located. You also license your packaging with a dual system, and if you have no establishment in Germany you need a German authorised representative since 12 August 2026.
I sell on OTTO Market. Do I need EPR in Germany?
Yes. OTTO Market asks for your LUCID registration number during onboarding. You also need a dual-system licence for your packaging, and if your company has no establishment in Germany, a German authorised representative since 12 August 2026.
I sell from my own online shop (Shopify, WooCommerce). Do I need EPR in Germany?
Yes. Your own shop has no marketplace checking your LUCID number, but the law is the same: if you ship packaged goods to consumers in Germany you register in LUCID, license your packaging with a dual system, and, if your company has no establishment in Germany, appoint a German authorised representative.
I buy on Alibaba and sell in Germany. Who is the producer?
Usually you. Alibaba is a business-to-business marketplace: the supplier sells to you, and whoever first makes the packaged goods available to end users in Germany is the producer. If that is your company, the LUCID registration, the licence and, if you are based abroad, the German representative are yours.
Is a LUCID number enough to sell on Amazon or Etsy in Germany?
It is enough to pass the marketplace check, not to comply. You also need a dual-system licence for your packaging, and since 12 August 2026 a German authorised representative if your company has no establishment in Germany (§ 5(2) VerpackDG).
Does the marketplace license my packaging for me in Germany?
Generally no. Amazon, Etsy, Kaufland and OTTO collect your LUCID number; the dual-system licence is yours to buy. eBay offers one through its partner Lizenzero, which you still buy yourself, and which does not make anyone your representative.
Amazon says it may comply on my behalf. Is Amazon then my German representative?
No. A German authorised representative is appointed by a written mandate in German (§ 5(4) VerpackDG) and must be named in your LUCID entry and confirmed by ZSVR (§ 5(5)). Amazon's statement describes what it may do when a seller is non-compliant.
Does German packaging law apply to private sellers on eBay?
eBay applies the packaging rules to business sellers with buyers in Germany, whether they pack the goods themselves or import them already packed. Selling your own used things occasionally is different; if you sell regularly or buy goods to resell, treat yourself as a business seller.
My Amazon or eBay listings were blocked for EPR, but I am registered in LUCID. Why?
Marketplaces must assess whether your registration details are complete and reliable before letting you sell. Check three things: that your LUCID number is entered in the platform's EPR section for Germany, that the company name and details match your LUCID entry, and that your registration is complete; a producer based abroad must also name its German representative.
I use Amazon FBA and never ship to customers myself. Why do I need a LUCID number?
Because you are the one selling to end users in Germany; Amazon only fulfils for you. ZSVR is explicit: when a fulfilment provider packs goods for its clients in shipping packaging, the client, the seller of the goods, carries the packaging obligations for it. So the product packaging and the FBA shipping box are both yours to register and license.
Who needs a representative 4
I only send a few items a year to Germany. Does German packaging law still apply?
Yes. There is no minimum quantity or turnover: registration and system participation apply from the first parcel of packaged goods you send to a buyer in Germany. Small volumes usually mean the dual system's minimum fee, not an exemption.
I also sell electronics in Germany. Is that the same registration as packaging?
No, two separate registrations. Packaging is registered in LUCID under the packaging law. Electrical and electronic equipment falls under the ElektroG, with its own registration at stiftung ear and, for producers based abroad, its own authorised representative. Batteries are a third regime.
Does a German representative also cover my sales to other EU countries?
No. Article 45(3) PPWR requires an authorised representative in each member state where you make packaging available and are not established. A German representative covers your German obligations only; another country where you sell needs its own arrangement under its own rules.
Can I avoid German packaging law by not selling to Germany?
Yes. Registration, licensing and the representative duty all attach to making packaging or packaged goods available in Germany. If you stop shipping to buyers in Germany, those duties do not arise for future sales. Duties for parcels you already sent remain.
Establishment 1
Does a warehouse in Germany, or Amazon FBA, make my company established there?
Not if someone else runs it. § 5(2) VerpackDG asks whether your company has an establishment (Niederlassung) in Germany. Stock held in Amazon's or a logistics provider's warehouse is not your establishment, so a company based abroad still needs a German authorised representative.
LUCID and licensing 3
Can a marketplace or a service provider register me in LUCID?
No. Registration in LUCID is a strictly personal duty (höchstpersönliche Pflicht (a strictly personal duty)): you register your own business, free of charge. § 5(2) VerpackDG excludes it from what a representative takes over, and § 5(1) bars any other third party from doing it.
Do I have to license the shipping box, filling and tape too?
Yes. Shipping packaging that ends up with consumers in Germany, the box, envelope, paper, tape, filling and bags, counts as packaging subject to system participation, licensed by material and weight with a dual system, like the product's own packaging.
When do I have to report my packaging volumes in Germany?
You report to ZSVR the same figures you give your dual system, without delay. If you made available less than 10 tonnes of system-participation packaging in Germany the previous year, you instead report the year's figures once, by 1 June of the following year. Larger producers also file a declaration of completeness by 15 May.
Sellers by country 2
I am a seller from outside the EU (UK, US, Switzerland, China…). Do I need a German EPR representative?
Yes, if you sell packaged goods directly to end users in Germany and have no establishment there, whether you are in the UK, the US, Switzerland, China or anywhere else outside the EU. You still register in LUCID yourself. If you only sell to a German importer or retailer that resells, that company is the producer instead.
I am a seller from another EU country (France, Austria, Poland, Netherlands, Italy, Spain…). Do I need a German EPR representative?
Yes. Since 12 August 2026 being in the EU does not exempt you: a producer established in one member state that sells directly to end users in Germany, with no establishment there, must appoint a German authorised representative. This covers sellers in France, Austria, Poland, the Netherlands, Italy, Spain and every other EU country.