In Germany, Amazon will be obliged to check if you comply with your EPR obligations in two product categories: (1) packaging and (2) Electrical and Electronic Equipment (EEE).
This page focuses on your requirements for packaging. For information on EEE, go to EPR Requirements: Waste Electrical and Electronic Equipment (WEEE) in Germany.
For packaging, you must prove your compliance to Amazon by submitting a registration number (LUCID number) on the Compliance Information for Extended Producer Responsibility (EPR) portal by June 14, 2022. Amazon will start blocking non-compliant listings starting June 15, 2022, to comply with the EPR legal requirement effective July 01, 2022.
Watch this Seller University video about Extended Producer Responsibility (EPR) packaging requirements in Germany.
For more information on enforcement of non-compliant listings, read the “Enforcement FAQ."
We highly recommend that you act immediately to avoid the risk of your listings being blocked.
Starting July 01, 2022, the following important changes will be effective:
To prove your compliance to Amazon, go to Compliance Information for Extended Producer Responsibility (EPR) and submit your LUCID registration number. Amazon may reserve the right to contact you for additional information, for example, to ask for a system participation certificate, if required.
For an overview of what you need to do and for the information materials for online retailers provided by the Central Body Packaging Register (Zentrale Stelle Verpackungsregister – ZSVR), go to this link and take a look at this summary. If you are a producer, you must follow these steps:
In the context of the German packaging law, you are considered a producer if you are the first to place packaging filled with goods in Germany on a commercial basis.
For detailed guidance, go to info graphic by ZSVR.
If your packaging is subject to system participation, you must enter a system participation contract with one or more systems (PROs). According to the German packaging law, packaging subject to system participation is defined as packaging that typically accumulates as waste with private final consumers. This includes retail packaging, grouped packaging, service packaging, and shipment packaging.
If your packaging is not subject to system participation, you do not need a system participation contract (though you will still need a registration). According to the German packaging law, this includes transport packaging, reusable packaging, single-use beverage packaging subject to deposits, retail packaging for hazardous contents and retail grouped packaging that does not typically accumulate as waste with private final customers.
For more information, go to ZSVR’s catalogue to determine if your packaging is subject to system participation.
 According to the German packaging law, transport packaging is used for protecting or securing products during transport and storage but is not intended to be used by the final customer. This can include cardboard boxes in which products are combined and bundled as well as the films around beverage cans, bubble wrap or transport pallets made of cardboard. Secondary packaging that is used for shipping products to the final customer does not count as transport packaging.
ZSVR has compiled a summary of frequently asked questions in the FAQ by ZSVR.
For more information about the solutions, Amazon offers to help you meet your EPR compliance requirements, go to Amazon solutions for Extended Producer Responsibility (EPR) compliance.
Current Amazon solutions include:
EPR SPN service is a store on our Amazon Seller Central partner network that allows our sellers access to vetted service providers offering Extended Producer Responsibility (EPR) services. They assist sellers with EPR registration and reporting obligations and act as the point of contact for all questions on EPR compliance. We have created the SPN network to increase the number of agencies you have access to and can use to achieve compliance within the tight deadlines given by authorities (for example, July 01, 2022, for DE packaging).
Go to EPR Service Provider Network to access vetted service providers, review their services and select a preferred Service Provider to work with.
Upon conclusion of registration process and receipt of the registration number from the authorities, you must upload the registration number on Compliance Information for Extended Producer Responsibility (EPR) on Seller Central.
The manual offers step-by-step guidance on how to comply with EPR German packaging law by June 30, 2022, and report your packaging volumes.
For more information about the solutions Amazon offers to help you get a LUCID Registration Number, go to Amazon solutions for Extended Producer Responsibility (EPR) compliance.
We will start providing information about the amount of secondary packaging used by FBA service to ship your products in August. Information for the secondary packaging used by Amazon to ship your products will be available in EPR Category Reports on a monthly, quarterly and annual basis covering period from July 01, 2022. Before that you can use the following information for the high-level forecast - 95g of paper and 5g of plastic is used to ship one item on average. To estimate the associated eco-fees use web calculators, the links are available in EPR Manual for Packaging in Germany (page 24).
At the moment Amazon EPR Category Reports provide estimation of your primary packaging for both AFN (Amazon Fulfillment Network) and MFN (Merchant Fulfillment Network) sales on Amazon store. Reports are available on EPR Category Reports, with Amazon EPR report FAQ, and EPR report field definitions to support you further with EPR reporting.
Amazon will share the information about secondary packaging used to ship your products (only shipped by FBA service) in EPR Reports. The report will be available on a monthly, quarterly and annual basis covering period from July 01, 2022. The first monthly report covering July will be available in August 2022.
Typically, a couple of Eurocent per item. Details can be provided by the systems (PROs). For a list of systems, go to overview by ZSVR.
If two or more products were shipped in one box, the weight of the box, dunnage, and tape used for this parcel will be split equally among these products. Eco-fees accounted for this shipment are also split equally among all products and sellers of these products are responsible for the corresponding quota. Amazon will share the total amount of secondary packaging used to ship your products adjusted to these splits.
Amazon will validate this number with ZSVR within three business days after submission. We will notify you when the validation result is available. Consider that Amazon will use your VAT or taxpayer reference number, your company name and address to validate your LUCID number. Ensure that the data on the LUCID packaging register matches the one you have provided to Amazon.
After you submit your LUCID number on Seller Central, Amazon will validate your submission with the appropriate government agency or PRO. It may take Amazon up to five business days to validate the registration number.
Once validated by Amazon, the status next to your number will change from “Submitted” to “Valid” or “Invalid + reason for invalid”. If the status is “Valid” no further action is required from you, and you can disregard these notifications. However, if the status is “Invalid”, refer to the reason provided and take appropriate action.
If any of these conditions apply, resubmit the correct number. If none of these conditions apply, you can reach out to Selling Partner Support through Seller Central.
Only international companies without a branch in Germany can appoint an “authorized representative” to fulfil packaging law regulations for them. With the exception of registering in the LUCID Packaging Register, the authorized representative assumes responsibility for all of your obligations under the German packaging law and fulfils them in their own name. The one-time registration requirement in LUCID is a personal obligation that rests with you, the original party under obligation. For more information, go to the website of the ZSVR.
If you are non-compliant, Amazon will start blocking FBA inventory to fulfilment centres on June 15, 2022. To unblock your inbound inventory, confirm that you comply with the requirements for packaging by visiting the EPR Compliance Portal.
As a drop shipper, you buy products from a third party who packages them and sends them directly to the customer. This happens without you touching the product yourself. In some cases, this can imply that you are not the producer. If the third party is a fulfilment service provider and you use their services, you may be considered the producer of the secondary packaging which is used for shipping your products. According to the German packaging law, fulfilment services are services that include at least two of the following activities: warehousing, packing, labelling and shipping. For the clarification issued by ZSVR, go to FAQ.
If you use drop shipping and are not a producer, contact Selling Partner Support and indicate that you are not a producer because of drop shipping. It can take several business days to close this investigation and we will contact you for details.
After June 15, 2022, if you have not submitted a LUCID number or you have submitted a LUCID number which is invalid, your listings will be subject to suspension. You will receive a notification via email directing you to the “Fix Your Product” section in Seller Central, which will highlight the listings which are suppressed and guide you to the Compliance Information for Extended Producer Responsibility (EPR) portal to submit your LUCID number.
You can check the status of your LUCID number submission on the EPR Compliance portal. If your LUCID number is valid and your listings have been enforced, you can reactivate your listings and continue to sell successfully. However, if the status is “Invalid”, your listings will be eligible for suspension. We recommend that you refer to the reason provided and take appropriate action to update your LUCID number as soon as possible. If you are experiencing issues with resubmitting or you have any questions on the decision, contact Selling Partner Support.
Following the reinstatement of your listings, you will find that your listings remain in “Inactive” status in Seller Central. To reactivate your listings on an individual basis or using a bulk uploader, go to Relisting Inactive listings: Individual and Bulk completion.
If you are not a producer, contact Selling Partner Support and indicate that you are not a producer. It can take several business days to close this investigation and we will contact you for details.
If you believe some or all of your listings have been incorrectly enforced, contact Selling Partner Support and provide the listings impacted.