By Razvan Toma · Founder · Last checked 3 October 2026 · Sources linked below
Because you are the seller supplying end users in Germany; Amazon only fulfils the order for you. ZSVR is explicit about fulfilment: when a fulfilment provider packs goods for its clients in shipping packaging subject to system participation, the client, the seller of the goods, must meet the packaging obligations for it. So both the product's own packaging and the box Amazon ships it in are yours to register and license. If your company is based abroad, FBA stock in Germany does not make you established there, so you also need a German representative. Sources (4)ZSVRZSVR — Versand- und Onlinehandel
VerpackDG § 5VerpackDG § 5
VerpackDG § 7VerpackDG § 7AmazonAmazon — Extended Producer Responsibility compliance