Checked: 7 November 2026 — the date every statement on this page was checked against the sources below.
The UK seller is the producer for every sale to German end users, even though Amazon stores, packs and ships the goods. Stock in Amazon's warehouse is not an establishment, so the seller needs a German authorised representative, its own LUCID registration and a dual-system licence for both the product packaging and the FBA shipping box. Sources (2)
ZSVRZSVR — Versand- und Onlinehandel
VerpackDG § 5VerpackDG § 5
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 small candle maker based in England sells on Amazon.de. Through Pan-EU FBA, part of its stock sits in Amazon warehouses in Germany. It has no office or staff in Germany, and Amazon has asked it for a LUCID number.
Who is the producer
The candle maker. It sells to the German customer; Amazon only fulfils the order. ZSVR is explicit that when a fulfilment provider packs goods for its clients, the client carries the packaging obligations. See why FBA sellers need a LUCID number.
What applies
| Question | Answer |
|---|---|
| Does the German warehouse make it established in Germany? | No. Stock in a warehouse someone else runs is not an establishment (details) |
| German authorised representative? | Yes, before the first sale (§ 5(2) VerpackDG) |
| Licence the FBA shipping box? | Yes, with the product packaging (shipping packaging) |
| Minimum volume below which nothing applies? | None (a few items a year) |
What to do
- Register in LUCID yourself. Registration is free and stays with the producer; nobody can do it for you.
- Sign the mandate with your German representative, in writing and in German, before the first sale.
- Name the representative in LUCID. With us, the confirmation follows the same day once you have named us and signed.
- License your packaging with a dual system. Your representative concludes the contract in its own name, by material and weight.
- Enter your LUCID number on each marketplace you sell on, and report your volumes as the year goes on.
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 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 ↗