Do TikTok Shop sellers need packaging EPR in Germany?

Q: Do TikTok Shop sellers need packaging EPR in Germany?

Yes. TikTok Shop is the marketplace; the seller who makes the packaged goods available to consumers in Germany is the producer. You register in LUCID yourself, license your product and shipping packaging with a dual system, and, if your company has no establishment in Germany, appoint a German authorised representative (§ 5(2) VerpackDG). There is no minimum volume.

Yes. If you sell to consumers in Germany through TikTok Shop, you are the producer of your packaging: LUCID registration, a dual-system licence and, with no German establishment, an authorised representative.

Since 12 August 2026, § 5 VerpackDG, implementing Article 45(3) of Regulation (EU) 2025/40, requires a producer with no establishment in Germany to appoint an authorised representative before it first makes packaging available in Germany. Read § 5

By Razvan Toma · Founder · Last checked 9 November 2026 · Sources linked below

Quick answer

Yes, the same rules as on any other marketplace.

Register in LUCID yourself, free.
License every layer that reaches the customer with a dual system: product packaging, shipping box, filling.
No establishment in Germany: appoint an authorised representative and name it in LUCID (§ 5(2) VerpackDG).
Enter your LUCID number where the platform asks for it.

With us: €149 a year, no setup fee, confirmed in LUCID the same day.

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