EPR Numbers in EU Countries: What Amazon Sellers Should Know

EPR numbers in EU countries — overview of registration duties for online sellers

Extended Producer Responsibility (EPR) has become one of the most important compliance topics for online sellers operating in Europe. Many Amazon, eBay and Shopify sellers are surprised to discover how significantly the requirements differ across EU countries.

In Germany, sellers usually know the system as "LUCID registration". But Germany is only one part of a much larger European EPR landscape.

Status of this article: All details were verified in August 2026 against the PPWR (Regulation (EU) 2025/40) and the official national portals.

What is an EPR number?

An EPR number is a registration number issued to companies that place certain products or packaging on the market in an EU country.

Depending on the country, EPR obligations may apply to packaging, electronics, batteries, textiles, furniture, toys and other regulated product categories.

The purpose of EPR systems is to ensure that producers, importers and distributors contribute financially to waste collection, recycling and environmental management.

For online sellers, EPR numbers have become especially important because marketplaces such as Amazon increasingly require valid registration numbers. Without one, sellers face listing removals, account restrictions, shipment blocks or compliance warnings.

What fundamentally changed on 12 August 2026

This is the most important development, and many older guides do not yet reflect it. Until 2026, each country decided for itself whether and when foreign producers needed an authorised representative. Since 12 August 2026, Article 45 of the PPWR (Regulation (EU) 2025/40) applies EU-wide:

Every producer not established in the Member State where it first places packaging on the market must designate an authorised representative in that Member State.

The second half is what matters: per Member State, not once for the whole EU. There is no single-window mechanism. A seller shipping to Germany, France and Italy needs three representatives — much like fiscal representatives for VAT.

Equally important: Article 45(4) obliges online marketplaces to verify that sellers actually hold valid registration in each country of sale. Amazon, eBay and Zalando are already building these verification systems. Where registration is missing, listing suspension follows immediately — no warning, no grace period.

A common misconception: from 12 August 2026 the PPWR harmonises the data format and procedure of registration (Article 44), but not the obligation itself. You still register separately in every country. Less friction per registration — but the same 27 registrations.

Germany: the LUCID number

In Germany the packaging EPR number is known as the LUCID number. Under the Packaging Act (VerpackG), companies placing packaging on the German market must usually register in the LUCID system, license their packaging through a dual system, and report packaging quantities correctly.

Registration in LUCID itself is free and usually completed online. The real complexity, however, begins later — with packaging classification, reporting obligations, marketplace responsibilities, and the question of whether additional environmental systems apply.

Why international sellers often struggle

Many German businesses handle EPR compliance independently, especially when they already have accounting departments or administrative staff familiar with German regulations. Smaller sellers also often do everything themselves at the start.

For international sellers, the situation feels very different. We once spoke with a US-based entrepreneur preparing to expand into Amazon Germany. He described German EPR compliance as a "major obstacle", comparable to obtaining a complicated certification — though he still planned to enter the market.

For sellers coming from a different legal and business environment, German administrative systems can feel overwhelming.

Additional systems create confusion

One of the biggest challenges is understanding whether products also fall under additional systems: WEEE/electronics registration, battery regulations, or Germany's single-use plastics fund (EWKFonds / DIVID).

In practice, classification is rarely straightforward. For example: individually wrapped sweets may be treated differently from unpackaged chocolate products; portion ice cream may fall under different rules than frozen cakes; and for some plastic food packaging the obligation depends on how the product is intended to be consumed.

Even experienced sellers sometimes struggle to interpret these distinctions correctly.

EPR systems across EU countries at a glance

Although EPR rests on EU law, every country implements it independently: different registration authorities, reporting systems, thresholds and sometimes different product categories.

Country	Registration body / PRO	Key characteristic
Germany	LUCID (ZSVR) + dual system	Registration is public, licensing is private — two separate steps
France	Citeo (also Léko, Adelphe), ADEME oversight	Mandataire REP compulsory since 10 July 2026; Triman logo and sorting instructions mandatory
Italy	CONAI with seven material consortia	System in place since 1998; environmental labelling mandatory; codice fiscale needed to register directly
Spain	Ecoembes or another approved PRO	Annual declaration due by 31 March of the following year
Netherlands	Verpact (formerly Afvalfonds Verpakkingen)	Renamed — older sources still use the old name
Austria	ARA and other collection systems	Authorised representative for foreign producers
Poland	BDO waste database	Registration in the state database required
Sweden	Naturvårdsverket and approved collection systems	Coordinated through the environmental protection agency

France operates one of the strictest EPR regimes in Europe. Besides packaging, obligations may extend to textiles, furniture, toys, sporting goods and garden products. The AGEC law additionally requires the Triman logo with sorting instructions on all consumer packaging — regardless of where the product was made.

Italy works through the CONAI consortium and its material-specific environmental contribution (Contributo Ambientale CONAI). Contributions for plastic packaging are being revised from 1 October 2026, mostly upwards. An Italian tax code is required to register directly; businesses that cannot obtain one register through an authorised representative.

How many registrations do you actually need?

The calculation is simpler than many expect — and the result larger: number of countries × number of waste streams your products touch.

An example: a brand shipping packaged electronics with batteries to Germany, France, Italy, Spain and the Netherlands. That means packaging registration in five countries, WEEE in five, batteries in five — over twenty separate registrations, before leaflets (paper) or bundled textiles are even considered.

Doing this calculation before market entry makes budget and timeline planning far more realistic.

EPR in Europe keeps gaining weight

Environmental requirements continue to expand across Europe. More marketplaces now request packaging numbers, WEEE numbers, battery registrations and additional reporting data — since August 2026 not voluntarily, but because the law requires them to.

At the same time, many sellers still underestimate how different these systems are from country to country. A German LUCID registration does not cover France, and a French Citeo declaration does not replace Italian CONAI membership.

Final thoughts

For some businesses, handling EPR independently is entirely realistic. For others — especially international sellers operating across multiple EU countries — professional guidance helps avoid confusion, save time and reduce compliance risk.

At Packaging Compliance we help Amazon sellers understand German packaging compliance requirements and support them through registration and reporting.