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I sell on Amazon. Do I need EPR in Germany?

Yes: a LUCID number in Amazon's EPR portal, a dual-system licence, and since 12 August 2026 a German representative if your company is based outside Germany. FBA does not change that.

By Razvan Toma · Founder · Last checked 3 October 2026 · Sources linked below

Quick answer

Yes. Selling packaged goods to buyers in Germany through Amazon makes you subject to German packaging law, and Amazon checks it. You submit your 13-digit LUCID number in Amazon's “Compliance Information for Extended Producer Responsibility” portal, and you license your packaging with a dual system. If your company has no establishment in Germany, since 12 August 2026 you also need a German authorised representative. Using FBA or Pan-European FBA does not change that: Amazon's warehouse is not your establishment, and Amazon is not your representative.

What Amazon asks for

For packaging, Amazon asks you to prove compliance with your 13-digit LUCID number, submitted in the “Compliance Information for Extended Producer Responsibility” portal. Packaging and paper count as one EPR category, so one number covers both. Electrical and electronic products are a separate category, registered at stiftung ear.

Amazon says that if you are found to be non-compliant, it may need to deactivate your non-compliant listings, or comply with the regulations on your behalf.

The steps

  1. Register in LUCID yourself. It is free, and nobody, Amazon included, can do it for you.
  2. License your packaging with a dual system, by material and weight.
  3. Submit your LUCID number in Amazon's EPR portal.
  4. If your company is not established in Germany, appoint a German authorised representative by a written mandate in German, and name them in LUCID.

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Selling into Germany from abroad?

The new EU packaging law (PPWR) has applied since 12 August 2026. Four questions tell you whether it makes you appoint a representative in Germany — including when it does not.

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