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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Keep your sellers registered. Keep their orders moving.

Since 12 August 2026, § 13(4) VerpackDG bars fulfilment service providers from storing, packing or shipping for producers that are not properly registered in LUCID. 3PLs add an EPR check to onboarding and earn 20% recurring.

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

Quick answer

A fulfilment service provider may not store, pack, address or ship packaging for a producer that is not properly registered in LUCID (§ 13(4) VerpackDG). The central agency ZSVR provides an automated data match so fulfilment providers can check. An unregistered seller is a problem for your warehouse, not only for the seller.

Why it matters to a warehouse

  • The duty is yours too. § 13(4) VerpackDG applies to fulfilment service providers directly, with an automated register match provided by ZSVR.
  • A warehouse does not make a seller established. Stock at a German 3PL does not give a foreign seller a German establishment, so it still needs a representative. See does a German warehouse count.
  • Your volume depends on it. A seller who cannot ship stops paying for storage; your costs stay the same.

VerpackDG § 13 VerpackDG § 5

What you can offer

Copy these into your service list or proposals. We deliver them.

  • An EPR check as part of seller onboarding
  • Registration support in Germany, France and Spain, done for the seller
  • Connections to Shopify, Amazon and WooCommerce for the sales figures

Published prices, no setup fee: Germany €149 a year for packaging, €500 a year each for electricals and batteries; France from €190 a year per stream; Spain €199 a year. Licence and scheme fees are passed on at cost. See pricing.

How to add it

Add one question to seller onboarding: “What is your LUCID registration number?” If there is none, send your link. Your warehouse team changes nothing.

Partner terms

TermWhat it means
Your fee20% of what your client contracts with us, and 20% again of every yearly renewal, for as long as the client stays. No cap.
Data service20% of every month a client stays on EPR EU Connect, our €89-a-month packaging data service.
ExcludedDual-system licence fees and scheme fees: we pass them on at cost, so there is nothing to share.
When paidOnce your client has paid us.
Client priceThe same published price as anyone else. Your fee comes out of ours.
Who keeps the clientYou. Each client signs its own mandate with our representative, because the law requires a named representative; everything outside EPR stays with you.
Your toolsA page at epreurep.com/yourfirm with your name and logo, a partner code, and a dashboard with leads, paid clients, their yearly fees and your fee.
Client dataYou see a client's own account only after the client approves your access, and it can withdraw it at any time.

How to start

  1. Apply. Tell us about your firm and your clients; we reply in writing with the partner terms.
  2. Get your page. epreurep.com/yourfirm, with your name and logo. Clients buy from it directly and every order is tracked to you.
  3. Introduce clients. Send the link or give your partner code. No integration.
  4. Follow it. Leads, paid clients and your fee in your dashboard. We do the registrations and the filing.

Apply to become a partner

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

Who keeps the client relationship?
You do. The client signs its own mandate with our representative, because the law requires one; everything outside EPR stays with you.
Does the client pay more through a partner?
No. The client pays the published price; your 20% comes out of our fee.
Does § 13(4) VerpackDG apply to us as a 3PL?
Yes, if you store, pack, address or ship packaged goods for producers. Check each producer's LUCID registration before you serve it.

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.