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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A marketplace blocks listings for a missing LUCID number

Worked example: a seller outside Germany finds its German listings blocked because no valid LUCID number is on file. Why marketplaces must check, the three things to fix and how fast it can be done.

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

Online platforms must collect and assess each producer's registration details before letting it sell (Article 45(4) PPWR, Article 30 of the Digital Services Act, both referred to in § 13(4) VerpackDG). To unblock: register in LUCID, enter the number in the platform's EPR section for Germany with matching company details, and, with no German establishment, name a German representative. With us the representative confirmation follows the same day.

Illustrative example. This is not one of our clients: the business is invented, while the law and our published prices are real.

The situation

A homeware seller in Turkey has sold on a German marketplace for a year. One morning its listings are deactivated with a message about extended producer responsibility in Germany.

Why it happened

Online platforms must collect each producer's registration details and assess them before letting it sell. Fulfilment providers may not store, pack or ship for producers that are not properly registered (§ 13(4) VerpackDG), and ZSVR offers both automated matching against the register. See listings blocked although registered.

VerpackDG § 13 ZSVR

The three things to fix

  1. A complete LUCID registration, including brand names and packaging types.
  2. The same company name and details in the marketplace as in LUCID.
  3. A named German representative, confirmed by ZSVR, if the company has no German establishment.

VerpackDG § 5 ZSVR help

What it costs

Our fee for packaging is €149 a year, with no setup fee. The dual-system licence follows your kilograms and is paid at the system's price, with no markup from us. 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

How fast can listings come back?
Once the registration and our confirmation are in place, the marketplace decides when it reactivates the listings.

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.