Who needs LUCID registration? Edge cases for Amazon sellers

Asked whether an Amazon seller needs LUCID registration, the short answer is almost always yes. The more interesting question is the second one — who exactly counts as obliged, and in which constellations does the duty not apply?

This is precisely where sellers make the most expensive mistakes: registering when someone else in the chain is responsible, or relying on someone else while the duty actually sits with them.

Status of this article: All details were verified in August 2026 against the Packaging Act and the publications of the Central Agency Packaging Register.

The only criterion that matters

The law does not ask whether you manufacture, import or merely resell. What matters is a single question:

Who first commercially places the filled packaging on the German market? That person or company is the "first placer on the market" — and the law calls them the "producer", even if they produce nothing.

Two things follow. Your company's location is irrelevant: a US business shipping into Germany via FBA is just as much a first placer as a trader from Hamburg. And sales volume is irrelevant too — there is no de minimis threshold. The duty begins with the very first item of packaging, side businesses included.

Who is obliged — and who is not

Dropshipping: the case where you are not the producer

If your supplier packs the goods and ships them directly to the German end customer, you are not the first placer on the market. The packaging obligations sit with the shipper.

That does not settle the matter, though. Since 1 July 2022, marketplaces must verify that valid registration and system participation exist for the goods sold. Without proof, the sale is blocked — regardless of who is legally responsible.

What you actually have to do: ask your supplier for their LUCID number and system participation proof — or look the number up yourself in the public register. Submit both to Amazon, but not as your own data. It must remain visible that a third party is the producer under packaging law.

Beware of mixed models: as soon as you pack and ship part of the orders yourself, you are very much the first placer for that portion and need your own registration.

The one genuine exception: service packaging

The Packaging Act recognises exactly one constellation in which the licensing duty may be shifted to someone else — § 7(2) VerpackG for service packaging.

Service packaging is filled with goods only at the point of hand-over: bakery bags, coffee-to-go cups, chip trays, salad bowls. Anyone handing out such packaging may require an upstream distributor — producer or wholesaler — to participate in a system, and buy the packaging already licensed.

However: since 1 July 2022 the LUCID registration itself can no longer be delegated. Even a business handing out exclusively pre-licensed service packaging must register itself. Only the licensing moves to the supplier, not the registration.

Practical note: get the pre-licensing confirmed in writing — ideally as a note on the invoice or delivery slip. Without proof, the duty falls back on you in case of doubt.

Used packaging: the proof that is often overlooked

Anyone reusing already-used packaging is in principle also a first placer — unless there is concrete proof that this specific packaging has already participated in a system. Only then does the duty fall away.

For sellers who reuse cardboard boxes this means: without solid evidence, the obligation remains. Simply assuming "this must have been licensed at some point" is not enough.

You must register personally

A point that surprises many: the registration under § 9 VerpackG and the data reports under § 10 VerpackG may not be delegated to third parties. No service provider, no tax adviser, no compliance vendor can carry out those two steps for you.

Providers can take over all remaining duties — calculating volumes, arranging system participation, monitoring deadlines. But creating the account and filing the report must happen from your own access. If a provider promises otherwise, be cautious.

Equally important: registration must take place before you first place packaging on the market, not afterwards.

When do you need a declaration of completeness?

Here there really are thresholds — the only ones in the entire system. Anyone reaching or exceeding one of these volumes in the previous calendar year must additionally submit a declaration of completeness:

Important: exceeding one of the three is enough — the duty then applies to all packaging types. Below the thresholds the declaration falls away, but the registration and licensing duties remain. The ZSVR can also require smaller businesses to submit one if there are indications of faulty reporting.

What happens if registration is missing

The consequences reach beyond your own company. Without proper registration the products are subject to a distribution ban — which also applies to every subsequent distributor.

For B2B sellers this is the underestimated point: if you supply unregistered goods to a retailer, that retailer may not resell them either. Your compliance failure becomes your customer's problem — and a reputational risk for you.

On top of that come fines of up to €100,000 for missing registration and up to €200,000 for missing system participation, plus suspension of the seller account by the marketplace.

In short

☐ What matters is who first places the filled packaging on the German market — not where the company is based
☐ No de minimis threshold: the duty starts with the first item of packaging
☐ In genuine dropshipping the shipper is responsible — you must submit their proof to the marketplace
☐ For private labels the commissioning party is the producer, not the filler
☐ Service packaging is the only licensing exception — registration stays with you
☐ Registration and data reporting must be done personally
☐ Declaration of completeness only from 80 t glass, 50 t paper or 30 t other materials
☐ Missing registration triggers a distribution ban that also hits subsequent traders

Official sources

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