Extended Producer Responsibility (EPR) requirements: Packaging in Germany

What Extended Producer Responsibility (EPR) categories are relevant when selling in Germany?

In Germany, Amazon is obliged to check if you comply with your Extended Producer Responsibility in two product categories: (1) packaging and (2) electrical and electronic equipment (EEE).

This page focuses on the requirements for packaging in Germany. For information on EEE, go to Extended Producer Responsibility requirements: WEEE in Germany.

For packaging, you must prove your compliance to Amazon by submitting your registration number (LUCID number) on the Compliance Information for Extended Producer Responsibility (EPR) portal (the Compliance Portal).

Watch this Seller University video about Extended Producer Responsibility packaging requirements in Germany for an overview of the compliance journey.

For more information on the deactivation of non-compliant listings, read the Listing deactivation FAQ.

Where can I find more information on the Extended Producer Responsibility requirements for packaging in Germany?

Detailed information is provided in this help article, but we also encourage you to familiarise yourself with the German Packaging Law (VerpackG) and the website of the German packaging authority, Zentrale Stelle Verpackungsregister (ZSVR).

ZSVR has also produced some how-to videos (available in German and English).

What do I need to do to comply for packaging in Germany?

For an overview of what you have to do and for the information materials for online retailers provided by the ZSVR, go to this link and take a look at this summary . If you are a producer, you must follow these steps:

Step 1: Register on the LUCID packaging register

• Register as a “producer” on the LUCID packaging register and provide your brand names.
• After registering, you will be given your LUCID number, which is required to enter into a system participation contract with a producer responsibility organisation (PRO).
• Once your registration has been completed, it can take up to 72 hours for the LUCID number to be shown on the LUCID packaging register and the number cannot be used until that point.
• For more information about the registration process, go to this checklist .

Step 2: Enter into a system participation contract

• Determine the packaging volumes that you sell in Germany by type.
• If your packaging is subject to system participation, enter into an agreement with one or more PROs and provide them with your LUCID number.
• For more information and a detailed list of the dual system operators, go to Overview of systems and other contacts.

Step 3: Report your packaging volumes

• Submit data reports and pay system participation fees to your selected PROs on a regular basis.
• Sign in to the LUCID packaging register.
• Click Data reporting and submit the exact same data report provided to the selected PROs.
• For detailed information about data reporting, go to this checklist .

Step 4: Provide your LUCID number to Amazon

• Once your LUCID number has become available on the LUCID packaging register, go to the Compliance Portal and submit your LUCID number. You must make sure that it matches the number on the portal exactly and is in the correct format. See What is the format of a LUCID number? below for details.
• Amazon will then validate your LUCID number with ZSVR, which can take up to five working days.
• Once your number has been confirmed as valid, you must reinstate your inactive listings. For instructions, go to our Reinstating inactive listings: individual and bulk completion help page or our Guide to reinstate inactive listings due to non-compliance with EU regulations (available in German, English, French, Italian, Spanish and Chinese only).

If you are not a producer, go straight to step 4 to submit your supplier’s LUCID number on the Compliance Portal.

Amazon reserves the right to contact you for additional information. For example, to ask for a system participation certificate, if required.

How do I determine if my packaging is subject to system participation?

If your packaging is subject to system participation, you must enter a system participation contract with one or more PROs. According to VerpackG, 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 (although you will still need a LUCID number). According to VerpackG, this includes transport packaging^[1], reusable packaging, single-use drink packaging subject to deposits, retail packaging for hazardous contents and retail-grouped packaging that does not typically accumulate as waste with private final consumers.

For more information, go to this info sheet or visit ZSVR’s catalogue to determine if your packaging is subject to system participation.

^[1] _{According to VerpackG, transport packaging is used for protecting or securing products during transport and storage, but is not intended to be used by the private final consumer. This can include cardboard boxes in which products are combined and bundled, as well as films around drink cans, bubble wrap or transport pallets made of cardboard. Secondary packaging that is used for shipping products to the private final consumer does not count as transport packaging.}

How do I determine if I am a producer?

In the context of VerpackG, you are considered a producer if you are the first to place packaging filled with goods in Germany on a commercial basis.

• This is usually the manufacturer who produces and packages the product.
• It can also include retail companies that distribute own brands if (1) the packaging is filled by a third party on behalf of a retail company and (2) the packaging only bears the name or brand of the retail company.
• Importers are also producers if they bear legal responsibility for the goods at the time that they cross the border.
• Online retailers that fill shipment packaging with goods for the first time also count as producers.

You are considered the producer for Fulfilment by Amazon packaging used for shipping your products, if applicable.

For detailed guidance, go to info graphic by ZSVR.

What is the format of a LUCID number?

It is DE in capital letters, followed by a 13-digit number without a space in between (for example, DE1111111111111).

Note that if you submit a LUCID number that does not follow the required format, it will be marked as invalid by default. This is also the case if you submit a number on the “Selling application for Germany Extended Producer Responsibility (EPR) – packaging” page.

Can I complete my registration using my personal name?

No, you must register with your company name.

Can Amazon help me with my registration?

In addition to this help article, Amazon has developed other solutions to help you meet your Extended Producer Responsibility requirements:

• Extended Producer Responsibility (EPR) registration and filings services is a compliance resource that allows you to manage your Extended Producer Responsibility requirements in Germany. Here, you can work directly with third-party Extended Producer Responsibility service providers to receive support on fulfilling your Extended Producer Responsibility requirements and ensure your compliance. Service providers can assist with Extended Producer Responsibility registrations and filings, as well as help with authorised and legal representation.
• Our external Extended Producer Responsibility (EPR) Service Provider Network can support you with your Extended Producer Responsibility registration and reporting obligations for Germany and answer any questions that you have about Extended Producer Responsibility compliance. The cost of these services will differ depending on the selected service provider.
• Our Guide to become compliant with EPR (Extended Producer Responsibility) packaging requirements in Germany offers step-by-step guidance on how to comply with VerpackG and report your packaging volumes (available in German, English, French, Italian, Spanish and Chinese only).
• Our Extended Producer Responsibility (EPR) FAQ for Packaging in Germany contain answers on compliance with VerpackG (available in German, English, French, Italian, Spanish and Chinese only).

What happens if I cannot prove my compliance to Amazon?

Amazon is legally obliged to check if you comply with your Extended Producer Responsibility obligations in Germany and, if you do not, deactivate your non-compliant listings.

This applies to all listings using primary (that is, product packaging) or secondary (that is, shipping packaging, including Fulfilment by Amazon (FBA) packaging).

I’m already compliant for packaging in Germany. What do I need to do?

If you’re already registered on the LUCID packaging register and have submitted your LUCID number to Amazon on the Compliance Portal, you do not need to take any further action.

I’m not compliant for packaging in Germany. What do I need to do?

See What do I need to do to comply for packaging in Germany? and Can Amazon help me with my registration? for more information.

How many LUCID numbers do I need to submit?

There is one registration number that applies to all types of packaging (a LUCID number). You only need to submit the packaging number that you obtained from the authorities or your producer responsibility organisation (PRO) on the Extended Producer Responsibility Compliance Portal in Seller Central.

I am responsible for secondary packaging from Fulfilment by Amazon. How can I track the related costs?

We provide information about the amount of secondary packaging used by the Fulfilment by Amazon service to ship your products. Information on the secondary packaging used by Amazon to ship your products is available in Extended Producer Responsibility Category reports on a monthly, quarterly and annual basis. To estimate the associated system participation fees, you can use web calculators. The links are available in our Guide to become compliant with EPR (Extended Producer Responsibility) packaging requirements in Germany (page 24).

At the moment, Amazon Extended Producer Responsibility Category reports provide an estimation of your primary packaging for both Fulfilment by Amazon and Fulfilled by Merchant sales on Amazon.de. Reports are available on Extended Producer Responsibility Category reports. See the Amazon Extended Producer Responsibility report FAQ and Extended Producer Responsibility report field definitions for further information on Extended Producer Responsibility reporting.

How high are the costs related to secondary packaging that I should expect?

Typically, a couple of euro cents per item. Details can be provided by your selected PRO. For a list of systems, go to overview by ZSVR .

Who pays the costs related to secondary packaging if the product is shipped together with another product from another seller (regarding Fulfilment by Amazon)?

If two or more products are shipped in one box, the weight of the box, dunnage and tape used for the parcel will be divided equally among these products. System participation fees accounted for the shipment are also divided 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 among the sellers involved, according to these splits.

I only use drop-shipping. Do I need to register on the LUCID packaging register, and do I need to have a system participation contract?

As a drop-shipper, you buy products from a third party that 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 used for shipping your products. According to VerpackG, fulfilment services are services that include at least two of the following activities: warehousing, packing, labelling and shipping. For more information, go to FAQ by ZSVR.

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. In this case, go to Compliance Information for Extended Producer Responsibility (EPR) and submit the LUCID registration number of your producer. After submitting your LUCID number, contact Selling Partner Support.

Can I appoint an authorised representative to fulfil obligations on my behalf?

Only international companies without a branch in Germany can appoint an “authorised representative” to fulfil packaging requirements for them. With the exception of registering in the LUCID packaging register, the authorised representative assumes responsibility for all of your obligations under VerpackG and fulfils them in their own name. The one-off LUCID registration requirement is a personal obligation that rests with you – the original party under obligation. For more information, go to the ZSVR website.

How does Amazon validate my LUCID number?

Amazon validates this number with ZSVR within five working days after submission.

When validating your LUCID number, Amazon is looking for a match among one or more of the following attributes:

1. VAT number
2. Tax payer reference number or company registration number (if you do not have a VAT number)
3. The legal name of the business. In addition, we may use your business address for validation

These attributes are visible on your seller storefront page under Detailed seller information. Follow the instructions on Seller information displayed to buyers to update your information and make sure that it matches the information provided to ZSVR.

Note that you are required to go to the Compliance Portal to check your validation result. We recommend you do this six days after submission.

Why do I need to reactivate my listings myself?

Once we have confirmed that your LUCID number is valid, other checks need to be carried out manually by different compliance teams. For this reason, there is no automatic reinstatement process. To check if you have any other actions to take for your listings for packaged goods, go to the Account Health dashboard.

If your listings pass these additional checks and are confirmed to be fully compliant, you will be able to reinstate them. For instructions, go to our Reinstating inactive listings: individual and bulk completion help page or our Guide to reinstate inactive listings due to non-compliance with EU regulations (available in German, English, French, Italian, Spanish and Chinese only).

What if I don’t want to continue selling packaged goods on Amazon.de?

If you don’t want to continue selling packaged goods on Amazon.de, you can remove the corresponding listings via the Manage Inventory dashboard.

For more information, go to Manage your offers one at a time.

What are the steps to upload my LUCID number?

In order to ensure that you are compliant with VerpackG, you must upload your LUCID number on the Compliance Portal in Seller Central. Here are the steps that you must take:

• Go to the Compliance Portal.
• Insert your LUCID number in the open text box.
• Click Submit.

What does each field in the Compliance Portal mean?

Below are explanations of the main fields that you will find on the Add compliance for regulated product group pages in the Compliance Portal:

• Click Contact Selling Partner Support to receive help from Selling Partner Support.
• Click Register to receive support with registering for packaging in Germany.
• Open the text box in the Registration number column: This is where you enter your LUCID number.

Can I edit or remove the LUCID number that I provided?

You can resubmit a registration number by clicking the Resubmit link underneath your original LUCID number submission. There is no option to edit or remove a registration number.

If you have provided an incorrect registration number, use the Resubmit function and resubmit your number. Any incorrect numbers will remain on the Compliance Portal, but will be marked as invalid (they cannot be deleted).

What do the different LUCID number statuses mean?

After you’ve submitted your LUCID number on Seller Central, Amazon will validate your submission with ZSVR. It may take Amazon up to five working days to validate your LUCID number.

Once validated, 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. 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 contact Selling Partner Support through Seller Central.

How can I find my deactivated listings?

If you have not submitted a LUCID number or if you have submitted a LUCID number that is invalid, your listings will be deactivated. You will receive a notification via email directing you to the Fix your product section in Seller Central, which will highlight the listings that are suppressed and guide you to the Compliance information for Extended Producer Responsibility (EPR) portal to submit your LUCID number. You can find your suppressed listing details in Seller Central under Inventory > Manage all inventory > Search suppressed and inactive listings.

I have submitted a valid LUCID number, but my listings are still inactive. What do I need to do?

After you have submitted a valid LUCID number, your selling privileges will be reinstated. However, you will find that your listings still appear as Inactive in Seller Central.

To reactivate the listings on an individual basis or using a bulk uploader, see Relisting inactive listings: Individual and Bulk completion. Note that the bulk upload function is not available for sellers with individual selling plans and requires a subscription for a professional selling plan. For more information about individual selling plans and professional selling plans, go to Selling plans.

I am not a producer, but my listings have been deactivated. What do I need to do?

If you are not a producer, submit your supplier’s LUCID number on the Compliance Portal and contact Selling Partner Support to indicate that you are not the producer. Note that it can take several working days to close this type of investigation, and we will contact you for more details.

I believe that some or all of my deactivated listings do not require packaging. What do I need to do?

If you believe that some or all of your listings have been incorrectly deactivated, contact Selling Partner Support. To ensure that your request is processed quickly, provide a list of affected ASINs in your email.