Detailed answers for sellers and companies working with the German market.
Yes. Kaufland is an electronic marketplace under the Packaging Act, and since 1 July 2022 it may only admit sellers who are properly registered in the LUCID register. The LUCID number is already requested at seller sign-up and is checked regularly against the public register.
You don't need a separate number for Kaufland: one LUCID registration covers every sales channel. What matters is that packaging volumes from all channels are reported and licensed together.
eBay asks commercial sellers for their LUCID number in the seller account and cross-checks it against the public register. If the entry is missing or the company name doesn't match exactly, listings get restricted or the account is blocked for the German marketplace.
This isn't eBay policy — marketplace operators are legally required to stop sales when no valid registration exists. Private sellers can be affected too, once the selling activity takes on a commercial character.
Yes. OTTO Market requires all partners to hold a valid LUCID number and proof of system participation. The details are checked during onboarding and spot-checked afterwards.
The same LUCID number that covers Amazon, eBay or your own shop applies here. Make sure the company name on file with OTTO matches your LUCID entry character for character — differences such as "GmbH" versus "GmbH & Co. KG" cause rejection.
Your own online shop is subject to exactly the same obligations as marketplaces — with one difference: there's no platform checking and reminding you. The responsibility sits entirely with you.
You need registration in the LUCID register, participation in a dual system, and the annual quantity report. Every part of the shipping packaging counts: box, filler material, tape, poly bags. More detail in LUCID vs packaging licensing.
Yes, as soon as you physically deliver packaged goods to German customers. The sales channel is irrelevant — a sale via direct message or Instagram Shopping triggers the duty just as much as any other.
What matters is not the marketplace but who first places the packaging, filled with goods, on the German market. Instagram doesn't currently verify compliance actively, but that doesn't remove the legal duty. Use the same LUCID number as your other channels and add up the volumes together.
Shopify is shop software, not a marketplace — it doesn't request EPR data or share any responsibility. The obligations fall on you in full, with no platform reminder if something is missing.
In practice: register with LUCID before your first sale, sign a contract with a dual system, and file the quantity report by 15 May of the following year. It's worth stating your LUCID number in your legal notice or terms — it makes checks easier and builds trust.
You only need one LUCID registration — it applies across all channels. What you actually need to organise is bringing the volumes together cleanly.
A workable approach: determine packaging weight per item once (box, filler, product packaging, split by material), then export unit counts from every channel monthly and multiply by weight. Amazon's EPR category report in Seller Central already gives you pre-calculated figures — for Shopify and Etsy you'll need to calculate it yourself. Report the combined total identically to LUCID and to your dual system.
Yes. Etsy requires sellers who ship to Germany to hold a LUCID number and hides listings from German buyers without one.
The law makes no exception for handmade sellers, small businesses or individuals, and there's no de minimis threshold — the duty starts with the first packaged shipment. For small volumes the licensing cost is modest and often runs in the low double digits per year with most providers.
The process mirrors other marketplaces: your LUCID number is requested at seller sign-up, checked automatically against the public LUCID register, and then rechecked periodically.
Both the number and the company name are verified. The most common cause of rejection isn't a missing registration but a mismatch in spelling between the marketplace account and the LUCID entry. Check both for character-exact agreement before contacting support.
Yes. Zalando's partner programme requests the LUCID number and proof of system participation, and as a marketplace operator it shares responsibility.
For textiles there's an additional point: once a textile EPR scheme is introduced in Germany, a further registration may apply. The packaging duty under VerpackG already exists independently of that — for shipping boxes, poly bags and filler material.
Global Selling doesn't change the German obligations. Once you activate amazon.de and goods reach German end customers, the same VerpackG duties apply as for a German company.
What matters is not the marketplace but who first places the packaging, filled with goods, on the German market. The company's location doesn't matter. Amazon checks the registration under Account Health → Regulatory Compliance; without a valid number, listings for the German marketplace are deactivated. Details in Amazon Germany for foreign sellers.
Yes — but not by product category, by waste stream. A single LUCID number covers all your packaging regardless of product group.
Additional numbers arise from separate systems though: WEEE (Stiftung EAR) for electronics, a battery registration for products containing batteries, and DIVID for certain single-use plastic products. A marketplace can rightly ask for several numbers — but it's asking about different systems, not several LUCID numbers.
Use the public LUCID register. Enter the company name or the 13-digit number and you'll see the registration status, brand names on file, and registration date.
The register is deliberately public: it lets marketplaces, business partners and competitors verify compliance. Use it for your own checks too — for example, before placing an order, to confirm your dropshipping supplier is actually registered.
It depends on where the packaging ends up as waste. System participation is required for packaging that typically reaches a private end consumer.
Pure B2B chains supplying business customers, with disposal handled commercially, don't trigger system participation. Registration in LUCID is still required since 1 July 2022 though — it covers all packaging, including transport packaging that isn't subject to system participation. Be careful with mixed models: as soon as even part of your customers are private individuals, that portion becomes licence-liable.
Yes. Since expanding into Germany, Bol.com counts as an electronic marketplace under VerpackG. Sales to German buyers trigger the standard obligations: LUCID registration, system participation, quantity reporting.
Note: a Dutch registration with Verpact does not cover Germany. EPR registrations are country-specific — if you sell into both markets, you need both. More in EPR numbers in EU countries.
Shopify Markets is a localisation tool for currency, language and tax — it doesn't change your EPR obligations.
Once you use Markets to serve the German market and ship packaged goods there, the standard LUCID duty applies. Since Shopify doesn't run any compliance check, there's no warning if something is missing — enforcement, if any, happens later via the ZSVR or a competitor's cease-and-desist letter. Set up registration before activating the German market, not after.
Yes, for physical delivery of packaged goods to German buyers. TikTok Shop doesn't yet run EPR verification as strict as Amazon's or eBay's — the legal obligations remain unchanged regardless.
Expect this to change: marketplace operators are legally required to check, and enforcement is tightening incrementally. Reacting only once the request comes costs you sales time — system participation and data reporting both need lead time.
With Click & Collect, what matters is whether shipping packaging is created at all. If the customer picks up in-store and receives the item in its product packaging, no extra shipping packaging arises — though the product packaging itself remains subject to system participation.
If the item gets additional packaging or a carrier bag for pickup, that counts too. Bags filled only at hand-over qualify as service packaging — here licensing can shift to the supplier under § 7(2) VerpackG, though registration cannot.
No — as long as the platform is purely a referral tool. Idealo, billiger.de or Google Shopping send the user to your shop; the sales contract forms with you, and you ship the goods.
The LUCID duty therefore doesn't come from the comparison platform, but from your own fulfilment. It's different if a platform runs its own checkout with direct purchase — then it functions as a marketplace and must check registration.
D2C sales are subject to the same duties as any other direct shipment to German end consumers — with the difference that you're typically moving larger volumes under one brand.
Two practical consequences follow: all brand names you sell under must be listed in the LUCID register; launch a new brand without updating it and you're formally unregistered for that brand. And growing D2C brands eventually reach the thresholds for the declaration of completeness — 80 t glass, 50 t paper, or 30 t other materials per calendar year.
Yes, as soon as you sell to German customers via Cdiscount. Cdiscount is primarily a French marketplace — the German LUCID duty arises from delivery, not from where the platform is based.
Important for your planning: if you also sell via Cdiscount into France, you'll need a separate registration with Citeo there. EPR registrations are country-specific; no single-window process exists.
Indirectly, but noticeably. A missing or incorrect EPR registration doesn't affect star ratings or buyer reviews directly — but it does hit your account health.
Typical consequences are compliance warnings in the seller account, deactivated listings, and — on repeat occurrences — account restrictions. Since deactivated listings lose their sales history and ranking, the damage can linger for weeks even after compliance is restored.
Yes, for delivery to German end customers. Galaxus operates in the German market via galaxus.de and acts there as a marketplace that admits third-party sellers.
Note the Swiss background: a Swiss registration doesn't replace the German one. What matters is simply that packaged goods are placed on the German market for the first time — that triggers the LUCID registration and system participation duty.
It depends on the contractual model. If Lidl buys the goods and sells them under its own name, packaging responsibility for the sales packaging sits with Lidl — you're supplying B2B in that case.
If instead you sell as a third-party seller through Lidl's marketplace directly to end customers, you are the first placer on the market and need your own registration and licensing. Clarify the role contractually before you start — the classification isn't negotiable, it follows the actual arrangement.
Limango, as a shopping club, is part of the OTTO Group and mostly operates on a buy-in model. In that model you supply Limango B2B, and responsibility for the sales packaging towards the end customer sits there.
Your own registration duty remains, though, once you deliver packaged goods to Germany — transport packaging has been registration-liable since 1 July 2022, even where it isn't subject to system participation. Check the individual contract to see who counts as the first placer.
On REWE Online, REWE itself typically acts as the seller and buys the goods in. In that case REWE carries responsibility for the sales packaging towards the end consumer.
For you as supplier that means: system participation for the sales packaging isn't required, but LUCID registration remains mandatory as soon as you place packaged goods on the German market. It's different if REWE opens a marketplace model with third-party sellers — then the full set of obligations falls on you.
Yes. Wish is an electronic marketplace; sales to German buyers trigger the full LUCID duty regardless of where the seller is based.
For sellers from third countries there's an additional point since 12 August 2026: anyone without a German establishment who supplies end consumers directly must also appoint an Authorised Representative. Without one, compliance is incomplete even with a valid LUCID number and licence. Details in VerpackDG 2026.
Check first whether the classification really is wrong. In the vast majority of cases it isn't: even where the product itself falls outside VerpackG, the shipping packaging almost always triggers the duty — box, filler and tape all count.
A genuine exception only applies if you sell exclusively unpackaged goods or pure services. If that's the case, dispute it via Account Health → Regulatory Compliance and explain why no system-participation-liable packaging arises. In every other case, registering is faster than contesting.
The sales format is irrelevant. What matters is physical delivery of packaged goods to a German end consumer — whether the purchase happens during a livestream, via direct message or through a standard checkout changes nothing.
What matters is not the marketplace but who first places the packaging, filled with goods, on the German market. One practical note for live formats: orders often arrive in bursts, which makes quantity tracking harder. Record shipments continuously rather than compiling them at year-end.
Yes, once a pin turns into a purchase with physical delivery to Germany. Pinterest Shopping doesn't currently run strict EPR verification — the legal duty exists regardless.
Since Pinterest mostly links out to your own shop, the obligation arises from your own direct shipping anyway. No separate registration is needed for the channel: one LUCID number covers all channels.
Here two systems can apply at once. The sales and shipping packaging falls under VerpackG with LUCID registration and system participation.
The Single-Use Plastics Fund (DIVID) can additionally apply — for example to takeaway containers, cups or film packaging for immediate consumption. Since 3 November 2025 there's relief here: packaging containing more than 500 grams is no longer subject to the levy. Which products are affected is explained in EWKFonds for food sellers.
No. One LUCID registration covers your entire company, not a single sales channel. The same 13-digit number applies to Amazon, eBay, Kaufland, OTTO and your own shop.
What must be brought together across channels is the quantity data: the annual report covers the sum of all packaging from all channels. A common mistake is reporting only the Amazon volume because that report is already available.
EPR responsibility follows the goods, not the listing. If a product's seller changes, whoever actually places the packaging on the market is responsible — for their own shipments.
On shared listings (multiple sellers on one ASIN), each seller reports their own volumes. Taking over another seller's reported data isn't possible or permitted. Make sure that when you exit a listing, you stop including the affected volumes in your own reporting.
Yes. ManoMano admits third-party sellers and requires a valid LUCID number for the German market.
For the DIY and garden range, one point matters especially: bulky goods carry high packaging weight — cardboard, wooden crating, strapping, cushioning. Licence costs are based on weight, not product value. Careful weight tracking per item pays off financially here in particular.
Three sources reliably get you there: the marketplace's seller help pages (search "EPR", "packaging law", "LUCID"), the account health or compliance section of the seller account, and the seller terms and conditions.
Regardless of the platform's own policy: if a marketplace doesn't ask for the number, that doesn't release you from the duty. Legal responsibility sits with you, not the platform — the check is only the control layer.
Tchibo mostly operates on a buy-in model: goods are purchased by Tchibo and sold under its own name. In that model, responsibility for the sales packaging towards the end customer sits with Tchibo.
You as supplier remain registration-liable regardless, once you deliver packaged goods to Germany. If Tchibo opens a marketplace model for your range with direct sales to end customers, the full obligations — including system participation — fall on you.
Yes. ABOUT YOU runs a partner programme for third-party sellers alongside its own retail, and requests EPR data there.
Check which model you're selling under: in the wholesale model, ABOUT YOU buys in and is responsible for the sales packaging; in the partner model, you ship yourself and are the first placer. Only in the second case do you need system participation for the shipping packaging — LUCID registration is required either way.
Loyalty boxes are demanding from a packaging-law perspective because several packaging layers come together: the shipping box, the individual product packaging of each item, filler material, and often printed paper inserts.
All of it counts in the quantity report. Two things stand out: first, the volumes recur — with monthly shipping, the weight per customer multiplies by twelve across the year. Second, you're also responsible for the packaging of bought-in products if you bundle them for the first time and deliver them to end consumers.
Netto Online runs a marketplace model and admits third-party sellers; EPR data is requested from them. Sell there as a third-party seller and you're the first placer, requiring LUCID registration and system participation.
Supply Netto as a wholesale supplier instead, and responsibility for the sales packaging sits with the retailer. Clarify the role in the contract — it determines who reports and who licenses.
Selling through another company's online shop depends on the contractual model. If the company acts as buyer and reseller, responsibility for the sales packaging sits there.
If it's a marketplace model where you sell and ship under your own name to end customers, you are the first placer — with full registration, licensing and reporting duties. What matters is not the marketplace but who first places the packaging, filled with goods, on the German market.