As of: September 2026
Anyone selling goods via Amazon, Etsy, eBay or their own online shop into Germany must comply not only with tax, customs and product-safety rules, but also with German and European packaging requirements.
Since 12 August 2026, a new legal regime applies in Germany: the EU Packaging and Packaging Waste Regulation (PPWR) is complemented by the German Packaging Law Implementation Act (VerpackDG). In particular, this has changed the requirements for companies based outside Germany.
For online sellers, the following obligations can be especially relevant:
- Registration in the LUCID packaging register
- Participation of packaging subject to system participation in a scheme
- Reporting packaging volumes
- Correctly determining and documenting packaging materials
- Stating the relevant brands and company data
- Where applicable, appointing an authorised representative in Germany
- Meeting additional obligations under PPWR and VerpackDG
It makes no difference whether the sale takes place via Amazon, Etsy, eBay or your own online shop. What matters is the specific supply chain, the type of packaging, the producer role, and the place where the packaging or the packaged product is first made available on the market.
The essentials at a glance
| Obligation | Typical affected seller | What needs to be done? |
|---|---|---|
| LUCID registration | Producer within the meaning of packaging rules | Register before first making available on the market |
| System participation | For packaging subject to system participation | Conclude a contract with a dual system |
| Data reporting | Producer of packaging subject to system participation | Report volumes and material types |
| Determining packaging volumes | Sellers providing relevant packaging | Record packaging by material type and weight |
| Brand information | Registered producers | Keep the full list of brand names current in LUCID |
| Authorised representative | Companies based outside Germany without a German establishment | Appoint an authorised representative in Germany |
| Marketplace compliance | Sellers on Amazon, Etsy, eBay etc. | Enter the required EPR/LUCID data in the seller account |
Registration in the LUCID packaging register itself is free. Costs arise mainly from system participation and, for foreign companies, potentially from engaging an authorised representative.
1. What is LUCID?
LUCID is the packaging register of the Central Agency Packaging Register (ZSVR). Companies that are responsible as producers under the applicable packaging rules must register there.
Registration is not the same as a packaging licence. For packaging subject to system participation, the principle is:
Register → participate → report
The ZSVR expressly describes registration as the first step. Packaging subject to system participation must then be enrolled in a dual system, and the corresponding volumes must be reported.
2. Is LUCID registration alone enough?
No. A LUCID number does not automatically mean that all packaging obligations are met. For packaging subject to system participation, sellers must distinguish between three steps:
The company registers in the LUCID packaging register.
The seller concludes a contract with an approved dual system and enrols the relevant packaging accordingly. In Germany, approved dual systems currently include Der Grüne Punkt, Interzero, Landbell, Reclay, Zentek and Noventiz.
Packaging volumes are reported both to the dual system and in the LUCID packaging register.
The ZSVR requires that a report to the dual system, with the same volumes, material types and the same reporting period, is also entered in LUCID.
3. Which packaging is relevant in online retail?
For online sellers, shipping packaging is especially important. According to current ZSVR guidance, packaging used to ship goods to end consumers as part of online retail or other forms of distance selling counts as e-commerce packaging. This can include, for example:
- shipping boxes
- mailer bags
- shipping envelopes
- filling material
- plastic film
- flakes
- tissue paper
- adhesive tape
- other components of the shipping packaging
The ZSVR explicitly states that shipping packaging is subject to system participation.
Typical example: a seller sells a ceramic mug via Etsy and ships it to a customer in Germany. For shipping, they use: a product box, tissue paper, a shipping box, paper filling material, adhesive tape. It is therefore not enough to look only at the packaging of the product itself. The entire relevant packaging chain must be checked.
4. Which packaging must an online seller record?
A practical packaging matrix might look like this, for example:
| Packaging | Material | Weight/shipment | Quantity | Total weight |
|---|---|---|---|---|
| Product box | Paper/cardboard | 120 g | 1,000 | 120 kg |
| Shipping box | Paper/cardboard | 180 g | 1,000 | 180 kg |
| Paper filling | Paper/cardboard | 40 g | 1,000 | 40 kg |
| Adhesive tape | Plastic | 10 g | 1,000 | 10 kg |
| Bubble wrap | Plastic | 25 g | 500 | 12.5 kg |
| Total | 362.5 kg |
The actual legal classification of individual packaging components should be checked against current PPWR/VerpackDG rules and ZSVR guidance. Nonetheless, such a packaging matrix is a very good basis for a traceable volume calculation.
5. How are packaging volumes reported?
Data reporting states, among other things, the respective material types and packaging volumes in kilograms. The ZSVR names, for example: paper, board, cardboard (PPK), plastics, ferrous metals, glass. Volumes are entered in LUCID in kilograms, to three decimal places.
The report to the dual system and the report in LUCID must match.
For companies with less than 10 tonnes of packaging subject to system participation in the preceding calendar year, the ZSVR provides for a simplified annual final volume report. However, the specific reporting obligation depends on the individual situation and the system contract.
6. What does system participation mean?
System participation is a core part of extended producer responsibility. The seller enrols the relevant packaging with an approved dual system – for example Der Grüne Punkt, Interzero, Landbell, Reclay, Zentek or Noventiz. This funds, among other things, the costs of collecting, sorting and recycling packaging waste.
Determine packaging volumes → choose a dual system → conclude a system participation contract → report volumes.
Costs depend in particular on material type, packaging weight, packaging volume, and the terms of the respective dual system.
7. Amazon: which packaging obligations apply?
Anyone selling via Amazon into Germany should distinguish between the marketplace's requirements and the statutory obligations. Amazon may require proof of EPR compliance for relevant products or packaging. An existing LUCID registration should therefore be correctly entered in the relevant Amazon seller account.
FBA does not automatically mean all packaging obligations disappear. Anyone using Fulfilment by Amazon (FBA) should check which packaging is relevant within the specific supply chain and who it is legally attributed to. Statutory producer responsibility is not determined solely by who physically packs or ships the goods.
8. Etsy: LUCID and EPR
Etsy also informs sellers about German EPR requirements. For affected packaging, sellers must meet the statutory requirements and provide the required EPR information or registration data.
Etsy shop → check packaging obligations → LUCID → system participation → data reporting → enter EPR data in the shop.
Sellers should not assume that Etsy takes over their statutory obligations.
9. eBay: packaging obligations
Commercial eBay sellers who make goods available on the German market must also comply with the relevant packaging rules. For a typical seller, this means:
- check the packaging obligation
- complete LUCID registration
- enrol packaging subject to system participation
- report volumes
- enter the required EPR/LUCID data in the eBay account
The marketplace does not replace the seller's statutory obligations.
10. What changed on 12 August 2026?
This is one of the most important changes for international online sellers. On 12 August 2026, the new EU Packaging and Packaging Waste Regulation (PPWR) and the German Packaging Law Implementation Act (VerpackDG) entered into force.
Important: this is not just about Germany. The PPWR is an EU regulation and applies directly in all 27 member states. Each country implements it through its own national implementing act and its own national authority – in Germany, this is the VerpackDG together with the ZSVR. If you also sell into, say, France, Italy or Spain, you additionally need to check the national registers and representative rules there; they follow the same EU-wide principle but differ in detail.
For companies based outside Germany without a German establishment, a special rule on authorised representation has applied since then. The ZSVR states the requirement clearly:
A company based abroad, without an establishment in Germany, that supplies empty packaging or packaged products directly to end consumers in Germany, must appoint an authorised representative.
This affects, for example, certain: French Amazon sellers, Dutch Etsy sellers, Austrian online shops, British eBay sellers, US marketplace sellers, Chinese direct shippers.
11. EU companies vs. non-EU companies: do I need an authorised representative?
What matters is not solely whether the company is from the EU or a third country. Far more important is: company location → German establishment → direct sale to end consumers in Germany.
| Situation | Establishment in Germany | Direct sale to end consumers in Germany | Authorised rep. |
|---|---|---|---|
| Company based in Germany | Yes | Yes | ❌ No |
| EU company without German establishment | No | Yes | ✅ Yes |
| Non-EU company without German establishment | No | Yes | ✅ Yes |
| Foreign company with German establishment | Yes | Yes | ❌ No (due to this special rule) |
| Foreign company without German establishment | No | No | Depends on the supply chain and producer role |
| Foreign company without German establishment | No | Yes | ✅ Yes |
Important: the specific producer role in cross-border supply chains must be checked against the PPWR and national implementing rules. The simple formula "EU = no authorised representative, non-EU = authorised representative" has not been correct since 12 August 2026.
12. Example: French Etsy seller
A company from France sells handmade products via Etsy directly to customers in Germany. The company is based in France, has no establishment in Germany, and sells directly to German end consumers.
Result: LUCID: yes · System participation: yes, insofar as packaging subject to system participation is involved · Authorised representative: yes. The fact that France is an EU member state changes nothing about this.
13. Example: US Amazon seller
A company from the US sells products via Amazon directly to German customers and has no establishment in Germany.
Result: LUCID: yes · System participation: yes, where relevant · Authorised representative: yes. Here too, it is not decisive that the US is not an EU member state. What matters is the combination of a foreign location, the absence of a German establishment, and direct distribution to end consumers in Germany.
14. Example: Dutch company with a German establishment
A Dutch company additionally has an establishment in Germany. In this case, the special obligation to appoint an authorised representative for companies without a German establishment does not apply. The other packaging obligations may of course still exist.
15. What does an authorised representative do?
An authorised representative can take on the further obligations of extended producer responsibility for the foreign company. The legally possible scope includes, in particular:
- concluding a contract with a dual system and paying for system participation
- reporting packaging volumes in LUCID
- further processes in the LUCID packaging register
- submitting the audited declaration of completeness (VE) – only relevant if your annual packaging volumes exceed certain statutory thresholds (e.g. 30,000 kg for certain material fractions); this does not affect most small and medium-sized sellers
- take-back obligations for transport, sales and secondary packaging
- participation in a nationwide deposit scheme – only relevant for deposit-liable single-use beverage packaging
Important: which of these points a specific authorised representative actually takes on for you depends on the contract with them. Not every provider offers the full legal scope – some limit themselves to the core tasks (system participation, data reporting) and only offer VE submission or deposit-scheme participation for an extra fee, or not at all. Check the contract carefully to see exactly which services are included.
What does the authorised representative not do? An important exception is registration in the LUCID packaging register. This remains a strictly personal obligation of the producer.
Foreign seller → registers themselves in LUCID
Foreign seller → appoints an authorised representative
Authorised representative → takes on the further EPR obligations
Changes to the company's own registration data are likewise still made by the company itself.
16. Who can become an authorised representative?
Under current ZSVR requirements, an authorised representative can generally be a natural or legal person who:
- has a company location or establishment in Germany
- concludes a written contract in German with the foreign company
- has their own login, or an authorised-representative ID, in the LUCID packaging register
The authorised representative must be external to the company. A company may appoint only one authorised representative. The contract must be concluded in writing, in German.
The ZSVR does not publish an official list of all authorised representatives. The obligated company must choose a suitable provider itself.
17. How is the authorised representative entered in LUCID?
For a new registration, the authorised representative must already be stated during the registration process. A foreign company that is already registered must supplement its existing data accordingly.
The authorised representative must already themselves be registered in the packaging register as an authorised representative.
Only then can they be selected and named by the obligated company in LUCID. The appointment only becomes effective once the authorised representative confirms it in the packaging register.
18. A simple decision logic for international sellers
Do I need an authorised representative in Germany?
Yes → the special authorised-representative obligation for foreign companies does not apply.
No → continue to step 2.
Yes → the special obligation for companies without a German establishment does not apply.
No → continue to step 3.
Yes → an authorised representative is required.
No → the specific supply chain and producer role must be checked.
This logic corresponds to the current ZSVR guidance.
19. What happens without compliance?
The packaging obligations are not a voluntary EPR measure. The VerpackDG contains, among other things, provisions on: registration, system participation, data reporting, authorised representation, restrictions on making products available, and administrative offences.
Companies should therefore not wait to react only once Amazon, Etsy or eBay make a compliance request. The statutory obligation arises regardless of whether a marketplace has already requested the relevant data.
20. How big is the packaging problem in Germany?
Packaging regulation has a substantial practical background. According to the Federal Environment Agency (UBA), around 17.9 million tonnes of packaging waste were generated in Germany in 2023. The recycling rate was around 69.4%, while a total of around 97.1% of packaging waste was recovered.
Packaging is therefore one of the significant waste streams in Germany. For online retail, it is particularly relevant that shipping packaging can directly contribute to the rising volume of packaging.
21. The most common mistakes made by Amazon, Etsy and eBay sellers
Mistake 1: "I have a LUCID number. I'm done."
Wrong. LUCID registration, system participation and data reporting are different requirements.
Mistake 2: only the product packaging is considered.
Shipping boxes, mailer bags, filling material and other packaging components can also be relevant. Especially in online retail, the entire shipping packaging should be reviewed.
Mistake 3: "Amazon/Etsy/eBay handles it."
A marketplace may require compliance data or provide certain technical processes. However, the seller's statutory producer responsibility is not automatically transferred to the marketplace as a result.
Mistake 4: packaging volumes are only estimated.
A blanket statement such as "we ship around 5,000 parcels a year" is not a reliable packaging volume calculation. Better: weigh the packaging → determine the material → record the quantity → calculate the total weight.
Mistake 5: foreign sellers only consider EU membership.
Since 12 August 2026, the simple distinction "EU = no authorised representative" is not correct. What matters in particular is the location, a German establishment, the delivery route and the end consumer.
Mistake 6: the authorised representative is confused with a staff member who handles data.
An employee of your own company who maintains LUCID data is not automatically a lawful authorised representative. The ZSVR requires the authorised representative to be a person or company external to the business that meets the statutory requirements.
22. Which documents should a seller keep?
| Document / information | Purpose |
|---|---|
| LUCID registration | Proof of registration |
| System participation contract | Proof of system participation |
| Volume reports | Proof of reported packaging volumes |
| Packaging matrix | Calculation of packaging volumes |
| Weight data from suppliers | Basis for the volume calculation |
| Own weighing/calculation records | Traceability |
| Brand overview | Checking the LUCID data |
| Marketplace EPR data | Proof towards platforms |
| Authorised representative contract | For obligated foreign companies |
| Correspondence with the dual system/ZSVR | Documenting clarifications |
23. Checklist: setting up shipping to Germany correctly
Company
- Where is my company based?
- Do I have an establishment in Germany?
- Do I sell directly to end consumers in Germany?
- What role do I have under the PPWR?
Packaging
- Which product packaging am I placing on the market?
- Which shipping packaging do I use?
- Which filling materials are used?
- Which other packaging components do I use?
- Are material types and weights documented?
LUCID
- Is my company registered?
- Is the company data up to date?
- Are the relevant brands correctly listed?
- Does an authorised representative need to be entered?
System participation
- Do I have a contract with a dual system?
- Are the correct material types recorded?
- Are the packaging volumes correctly calculated?
Data reporting
- Are the volumes reported to the dual system?
- Are the same volumes entered in LUCID?
- Are the reporting period and material types identical?
- Are changes or corrections documented?
Foreign companies
- No German establishment?
- Direct sale to German end consumers?
- Authorised representative selected?
- Written contract concluded?
- Authorised representative named in LUCID?
- Confirmation of the appointment received?
Marketplace
- Amazon EPR data checked?
- Etsy EPR data checked?
- eBay EPR data checked?
- Does the marketplace data match the actual compliance data?
24. Conclusion
Anyone selling via Amazon, Etsy, eBay or their own online shop into Germany should not reduce packaging compliance to a single LUCID number. For packaging subject to system participation, the rule is: register → participate → report.
For international sellers, an important additional question has arisen since 12 August 2026: is the company based outside Germany, does it have no establishment in Germany, and does it sell packaging or packaged products directly to end consumers in Germany? If these conditions are met, an authorised representative in Germany must be appointed.
LUCID registration remains a strictly personal obligation of the company. The authorised representative then takes on the further obligations of extended producer responsibility.
Don't wait to react only to a request from Amazon, Etsy or eBay. First check your own supply chain, packaging, producer role and EPR obligations – then correctly set up the required registrations, system participations and reports.
Frequently asked questions about LUCID and packaging obligations
Do I need LUCID if I only sell a few products into Germany?
You should not assume a general de minimis threshold that automatically exempts online sellers from the registration obligation. What matters is the specific producer role, and whether the statutory conditions for a registration obligation are met.
Is LUCID registration free?
Yes. Registration in the LUCID packaging register is free. Costs arise solely from system participation with the dual system.
Is LUCID registration enough without a dual system?
For packaging subject to system participation: no. In addition to registration, system participation is required.
Do I have to register if I sell via Etsy?
If you are responsible as a producer under the applicable packaging rules, the corresponding obligations must be met. Selling via Etsy does not change this.
Do I have to register if I sell via eBay?
Selling via eBay does not remove the statutory packaging obligations. Commercial sellers should therefore check whether registration and system participation are required.
Do I have to register if I sell via Amazon FBA?
FBA alone does not automatically mean that all packaging obligations disappear. What matters is the specific supply chain and the respective producer role.
Do I need an authorised representative as a French company?
If the French company has no establishment in Germany and distributes packaging or packaged products directly to end consumers in Germany, an authorised representative has been required since 12 August 2026.
Do I need an authorised representative as a US company?
Yes, if the statutory conditions are met – in particular if there is no German establishment and sales go directly to end consumers in Germany.
Does the authorised representative have to take over my LUCID registration?
No. Registration itself remains a strictly personal obligation of the producer. The authorised representative takes on the further packaging-law obligations.
Can I appoint several authorised representatives?
No. Each producer may appoint only one authorised representative for extended producer responsibility.
Official sources
- Central Agency Packaging Register (ZSVR) — LUCID packaging register
- ZSVR — information on authorised representation
- ZSVR — system participation and data reporting
- ZSVR — roles and obligations under PPWR and VerpackDG
- Gesetze im Internet — Packaging Law Implementation Act (VerpackDG)
- EUR-Lex — EU Packaging and Packaging Waste Regulation (PPWR)
This article does not replace legal advice. Status: September 2026.