EU packaging rules (PPWR) apply since 12 August 2026 · day 91Check if it applies to you →
PPWR · since 12 Aug 2026 · Check if it applies to you →
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German packaging EPR for marketplace sellers

What a seller on Amazon.de, eBay.de, OTTO, Kaufland or Etsy needs for German packaging EPR: the LUCID number, the representative, the shipping box, FBA, and what to do when listings are blocked.

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

Checked: 6 November 2026 — the date every statement on this page was checked against the sources below.

Quick answer

You are the producer for everything a marketplace sells to German end users for you, including when Amazon fulfils the order. You register in LUCID, the packaging is licensed with a dual system, and without a German establishment you appoint an authorised representative. One LUCID number covers every marketplace.

Start here

ZSVR Amazon

When something goes wrong

What we do

We act as your authorised representative, license your packaging and file the reports, for €149 a year. See pricing.

Razvan Toma
About the authorRazvan Toma

Razvan Toma is the founder of EPR Germany Rep and of EPR France Rep, the French sister service. He has worked in waste management and recycling since 2009, running waste-separation programmes inside large B2B organisations in France for clients including Chanel, Microsoft, Decathlon, Pirelli, IKEA, Vinci, Capgemini and E.Leclerc. He reads the statutes and the regulator's own guidance directly, and publishes what they say — including when it means telling a visitor they do not need to buy anything.

Razvan on LinkedIn ↗

Frequently asked questions

Do I need a separate LUCID number for each marketplace?
No. One LUCID number covers all your sales channels in Germany.

Selling in Germany?

Your German authorised representative from €149 a year: help with your LUCID registration, dual-system contract and annual report included. No setup fee.