This comprehensive guide walks you through the entire process of registering with the LUCID Packaging Register (ZSVR) — a mandatory requirement for all Amazon sellers delivering packaged goods to customers in Germany.
1. Key concepts and requirements for 2026
The German Packaging Act (VerpackG) requires "producers" — a category that includes online sellers and importers — to take financial responsibility for the recycling of their packaging.
Who must register: Anyone who is the first to place packaging filled with goods (including shipping packaging) onto the German market.
Penalties: Fines under § 36 VerpackG are tiered: up to €200,000 for missing or improper participation in a dual system, up to €100,000 for missing or incorrect registration in LUCID, and up to €10,000 for faulty data reports — in each case per individual violation. Distribution bans and skimming of unlawfully obtained profits may be added on top.
The "What you are actually paying for: System participation finances household collection and recycling — the yellow bag, the yellow bin, paper and glass containers. It does not cover the cleaning of public spaces: street bins and park cleaning are financed through the separate Single-Use Plastics Fund (EWKF/DIVID). These are two distinct obligations with different purposes.
2. Your three main obligations
| Obligation | Action required | Portal |
|---|---|---|
| LUCID registration | Get your 13-digit registration number (DE…) | LUCID portal |
| System participation | Pay for a licence covering your packaging waste | Dual system partner (e.g. Lizenzero) |
| Data reporting | Report the weight of packaging (paper, plastic, etc.) | LUCID AND dual system |
3. Special instructions for Amazon FBA sellers
If you use Fulfillment by Amazon (FBA), Amazon handles the shipping — but you remain legally responsible for reporting the weights of the packaging used.
How to find your EPR reports
Amazon provides pre-calculated reports to help you file your declarations accurately:
1. Go to Seller Central.
2. Navigate to the Reports tab.
3. Select Fulfillment by Amazon.
4. In the left-hand menu, look for the EPR section and click EPR Category Reports.
5. Select the relevant year and period to download your data.
How to use the data
For the dual system (licensing): Most modern providers (such as Lizenzero or Reclay) let you upload the Amazon CSV file directly. The system automatically extracts the weights and calculates your fee.
For the LUCID registry: LUCID does not support file uploads. You must open your Amazon report, sum up the totals for each category (e.g. paper, plastic), and manually enter these numbers into the LUCID "Data Reporting" section.
4. The step-by-step process
Step 1: Register in LUCID
Go to the ZSVR website (verpackungsregister.org) and select "Producer".
Enter your company details: legal name, address, and contact information.
Identification: Provide your VAT number or tax ID.
Brand names: List all brands you sell under. If you don't have a brand, use your company name.
Step 2: License your packaging (dual system)
LUCID is just a registry; it doesn't recycle anything. You must pay a private company (a dual system) to handle the actual recycling.
Sign a contract with a provider (e.g. Interseroh+ or Der Grüne Punkt).
Enter your LUCID number into their portal to link the accounts.
Pay the fee based on your estimated annual weight.
Step 3: Report the data to LUCID
Log back into LUCID (lucid.verpackungsregister.org) and select "Data Reporting".
Select your dual system provider and enter the exact same weights you paid for.
Important: The data in LUCID and at your dual system must match perfectly.
Step 4: Update Amazon Seller Central
Go to Performance → Account Health → Regulatory Compliance.
Find the EPR section for "Germany Packaging".
Enter your DE… number. Validation usually takes about five business days.
5. Reporting calendar
Before 31 December: Submit your initial planned volume for the upcoming year.
During the year: Submit an intra-year report if your sales significantly exceed your forecast.
Before 15 May: Submit your year-end report confirming the actual weights sold in the previous year.
Final checklist
☐ Registered in LUCID as a "producer"
☐ Active contract with a dual system provider
☐ Amazon FBA report downloaded and weights calculated
☐ Data entered manually into LUCID and uploaded/entered in the dual system
☐ EPR number submitted and showing as "valid" in Amazon Seller Central
Official sources
- LUCID — packaging register
- Central Agency Packaging Register (ZSVR)
- VerpackG — statutory text
- VerpackG § 36 — penalty provisions
- Amazon: EPR information