By Razvan Toma · Founder · Last checked 3 October 2026 · Sources linked below
Every major marketplace selling to German buyers asks for your LUCID registration number, and none of them takes your legal duties over. Etsy, Amazon, eBay, Kaufland and OTTO all collect it, because Article 45(4) PPWR requires online platforms to obtain your registration details before letting you sell to consumers in Germany. But the number only proves you registered. You still need a dual-system licence for your packaging, and since 12 August 2026 a company with no establishment in Germany must also appoint a German authorised representative, a Bevollmächtigter, under § 5(2) VerpackDG. Etsy now says so on its own help pages. Sources (9)
Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)
VerpackDG § 5VerpackDG § 5VerpackDG § 7VerpackDG § 7
ZSVRZSVR — BevollmächtigungEtsy Seller HandbookEtsy Seller Handbook — New EU packaging and EPR rules (3 September 2026)AmazonAmazon — Extended Producer Responsibility complianceeBayeBay — Erweiterte Herstellerverantwortung bei Verkäufen in DeutschlandKaufland Global MarketplaceKaufland Global Marketplace — EPR general informationOTTO MarketOTTO Market — onboarding guide
What each marketplace asks for
From each platform's own help page, read 3 October 2026.
| Marketplace | What it asks for | Where you enter it | Says you may need a representative |
|---|---|---|---|
| Etsy | Your LUCID number (Etsy also collects EPR numbers for other EU countries) | Shop Manager › Finances › Legal and tax information | Yes, in EU countries where your business is not established (3 September 2026) |
| Amazon.de | Your 13-digit LUCID number; packaging and paper count as one category | The “Compliance Information for Extended Producer Responsibility” portal | No mention for packaging |
| eBay.de | Your LUCID number; eBay offers a packaging licence through its partner Lizenzero | Account settings › Business information › Extended producer responsibility | Only for electrical equipment, not for packaging |
| Kaufland.de | Your LUCID registration, which the seller must make personally | Seller account | No mention for packaging |
| OTTO Market | Your LUCID registration number | At onboarding | No mention for packaging |
| Your own shop (Shopify, WooCommerce) | Nothing: no platform checks you | — | The law applies exactly the same |
Why the LUCID number is not the whole job
German packaging law asks three things of a producer, and a marketplace checks only the first.
- Registration in LUCID, which you must do yourself. It is free, and nobody can do it for you: § 5(2) VerpackDG excludes it from any mandate, and ZSVR calls it a strictly personal duty.
- A dual-system licence for the packaging you ship, paid by material and weight (§ 7 VerpackDG), with volume reports.
- A German authorised representative if your company has no establishment in Germany, required since 12 August 2026 (§ 5(2) VerpackDG, Article 45(3) PPWR). It is appointed by a written mandate in German and confirmed by ZSVR in LUCID.
A shop with a LUCID number and nothing else passes the marketplace check and still breaks the law on the other two.
Can the marketplace do it for me?
Not the representative part. A representative is appointed by a written mandate in German (§ 5(4)) and named in your LUCID entry (§ 5(5)); no marketplace signs one with its sellers. eBay offers a dual-system licence through Lizenzero, which covers step 2 only.
More on marketplace sellers
- I sell on Etsy. Do I need EPR in Germany?
- I sell on Amazon. Do I need EPR in Germany?
- I sell on eBay. Do I need EPR in Germany?
- I sell on Kaufland.de. Do I need EPR in Germany?
- I sell on OTTO Market. Do I need EPR in Germany?
- I sell from my own online shop (Shopify, WooCommerce). Do I need EPR in Germany?