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EPR Requirements: Packaging in Germany

What EPR categories are relevant when selling in Germany?

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."

Note: At this stage, you can only add a LUCID number for packaging on the EPR Compliance Portal. While you must be registered if you sell products in other product categories (for example, EEE), you cannot submit other registration numbers for Germany to Amazon yet. We will keep you updated in 2022 on when you can submit additional registration number(s) for EEE. For more information on packaging, refer to “What do I need to do to comply for packaging in Germany?”

What happens if you cannot prove your compliance to Amazon?

  • Starting July 01, 2022, Amazon will be legally obliged to check if you comply with your obligations in Germany and, if you do not, suspend your non-compliant listings.
  • Amazon will start blocking non-compliant listings starting June 15, 2022, for all listings using both primary (that is product packaging) and/or secondary (that is shipping packaging, including FBA packaging).

We highly recommend that you act immediately to avoid the risk of your listings being blocked.

Important: The estimation of the annual volumes of packaging on which eco-fees will be paid can be a lengthy process (it has taken up to 20 days for some sellers). Amazon needs five days to validate your LUCID registration number.

Where can I find more information on EPR for Germany?

For more information, we encourage you to get familiar with the German Packaging Law (VerpackG) and the website of the government authority.

What is changing and what do I need to do?

Starting July 01, 2022, the following important changes will be effective:

  • All producers of packaged goods in Germany must register in the LUCID packaging register. Previously, this only applied to producers of packaging subject to system participation.
  • You will be considered the producer for Fulfillment by Amazon (FBA) packaging used for shipping your products, if applicable. Amazon will be responsible for FBA packaging until June 30, 2022.

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.

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

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:

Step 1: Registration in the LUCID packaging register

  • Register as a “producer” in the LUCID packaging register and provide your brand names.
  • After registration, you will obtain your LUCID number which is required to enter into a system participation contract with a system (Producer Responsibility Organization; or PRO in short).
  • For more information about the registration process, go to the checklist.

Step 2: Entering into a system participation contract

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

Step 3: Reporting packaging volumes

  • Submit data reports and pay fees to the systems (PROs) on a regular basis.
  • Log in to the LUCID packaging register.
  • Click on Data reporting and submit the exact same data report provided to a system.
  • For detailed information about data reporting, refer the checklist.

How do I determine if I am a producer?

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.

  • 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) if the packaging bears only the name or brand of the retail company.
  • Importers are also producers if they bear legal responsibility for the goods at the time they cross the border.
  • Online retailers that fill shipment packaging with goods for the first time also count as producers.

For detailed guidance, go to info graphic by ZSVR.

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 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[1], 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.

[1] 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.

General FAQ

ZSVR has compiled a summary of frequently asked questions in the FAQ by ZSVR.

1. How can I become compliant for packaging in Germany?

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 Services Provider Network (SPN)

    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.

    Note: Price negotiations and service providers selection is strictly done by sellers and registrations and reporting are done offline between both parties.

    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.

  • Extended Producer Responsibility (EPR) Manual for Packaging Germany

    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.

2. I’m already compliant for packaging in Germany, what do I need to do?

3. I’m not compliant for packaging in Germany, what do I need to do?

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.

4. If I am responsible for secondary packaging from FBA starting July 01, 2022, how can I track the related costs?

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).

Note: These forecasts are for indication only and that Amazon will not be responsible for any discrepancies between the forecast and the final eco-fees amounts. We are constantly working on reducing the amount of secondary packaging used to ship your products.

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.

5. Where can I see how many secondary packaging Amazon has used for the shipment of the products I sold?

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.

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

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.

7. Who will be paying the costs related to secondary packaging if the product is shipped together with another product from another seller (regarding FBA)?

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.

8. How does Amazon validate my LUCID registration number?

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.

9. My LUCID number shows as invalid. What do I need to do?

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.

10. Can I appoint an authorized representative to fulfill obligations on my behalf?

Only international companies without a branch in Germany can appoint an “authorized representative” to fulfill 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 fulfills 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.

11. I can no longer send inbound inventory for Amazon FBA in Germany. What do I need to do?

If you are non-compliant, Amazon will start blocking FBA inventory to fulfillment centers on June 15, 2022. To unblock your inbound inventory, confirm that you comply with the requirements for packaging by visiting the EPR Compliance Portal.

12. I only use drop shipping. Do I need to register in LUCID and do I need to have a system participation contract?

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.

Enforcement FAQ

1. How can I find my listings which have been enforced?

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.

2. How can I confirm if my LUCID number is valid?

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.

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

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.

4. I am not a producer but my listings are being enforced. What do I need to do?

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.

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

If you believe some or all of your listings have been incorrectly enforced, contact Selling Partner Support and provide the listings impacted.

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