Detailed answers for sellers and companies working with the German market.
Reporting happens in two steps: by 31 December you report the planned volume for the coming year, and by 15 May of the following year you file the year-end report with the actual volumes for the previous year.
Both reports go to your dual system and to the LUCID register — the figures must match exactly in both systems. Discrepancies between the two reports are the most common trigger for follow-up questions during checks.
Track weight separately by packaging material — paper/board, plastic, glass, metal, composites each on their own, since licence costs are material-dependent.
A workable approach: weigh one empty packaging unit (box plus filler plus any outer wrap) on a precision scale, multiply by the number of units sold per product, and total by material. If the same product uses several packaging variants, track each variant separately.
For a large range, a packaging matrix pays off: a table listing item number, packaging type used, and weight per material. Once set up, you only need to update it when the range changes.
For ongoing reporting, link this matrix to your monthly sales figures from your inventory system or Amazon Seller Central — that lets you calculate the total automatically instead of manually per order. Above a few hundred items, a spreadsheet or specialised software beats manual tracking by a wide margin.
"First placing on the market" means the moment packaging filled with goods first reaches the German market commercially — usually the point of shipping to the end customer.
What matters isn't manufacturing but who places that packaging on the market first. For imported products, you as the German seller are the first placer, even if the foreign manufacturer produced the packaging months earlier.
There's no explicit statutory minimum retention period for packaging documentation, unlike tax record-keeping rules — but in practice, keeping records for at least six to ten years is advisable, in line with general commercial retention periods.
Keep in particular: weight determinations per item, dual system invoices, LUCID reporting confirmations, and — for service packaging — proof of pre-licensing. During a ZSVR check, records going back several years can be requested.
Seasonal fluctuations don't change the reporting process — you report the actual annual volume regardless of whether it's spread evenly or concentrated into a few months.
What matters practically is the advance report due 31 December: estimate realistically here, since a forecast that's significantly too low can leave you underfunded with your dual system if the season is strong. Most systems allow adjusting the advance report during the year if it becomes clear the actual volume diverges sharply.
A missed deadline doesn't resolve itself — file the report immediately once you notice, rather than waiting for the next regular deadline.
The sooner you correct it, the more leniently the ZSVR and your dual system tend to judge it. Repeated or prolonged failures risk fines under section 36 VerpackG; a one-off, promptly corrected delay is rarely sanctioned in practice, but shouldn't become a habit.
Returns don't automatically reduce the reported volume — what matters is that the packaging was actually placed on the market at the point of shipping, regardless of whether the customer later returns the goods.
It's different if you reship returned goods using the same original packaging: that packaging was only placed on the market once and is only reported once. If new packaging is used for the reshipment, that counts as an addition.
Yes, as long as the samples are shipped packaged to recipients in Germany — the law doesn't distinguish between sold goods and free samples. Both count as placing packaged goods on the market.
For large sample shipments, such as in B2B distribution to trade partners, the volume can add up noticeably. Track sample shipments separately so they aren't overlooked in the annual report.
With multi-country FBA, Amazon distributes your stock across warehouses in several EU countries. For the German reporting duty, only the volume actually delivered to German end customers counts — regardless of which warehouse country the shipment came from.
Amazon's extended producer responsibility report typically breaks volumes down by destination country. Make sure you report only the Germany volumes to LUCID — shipments from German warehouses to customers in other countries belong to that country's own EPR report instead.
Reconstruct the volumes as accurately as possible from available secondary sources: Amazon sales reports, customer invoices, supplier invoices for packaging materials, or accounting exports from before the data loss.
Document how you reconstructed the figures in writing, in case the estimate is questioned later. A plausible, traceable estimate is generally accepted by the ZSVR and dual systems — complete silence citing lost data is not.
Extra gift wrapping — paper, ribbons, special boxes — counts as its own packaging volume and should be tracked separately from standard packaging, where it goes beyond the regular shipping packaging.
If you offer gift wrapping as an optional add-on, it's worth determining weight separately for that variant, since its material mix differs from the standard shipment and would otherwise skew the annual report.
No. As long as the goods haven't left the warehouse and no packaging has actually been placed on the market, no reporting duty arises for that shipment — for example, for cancelled or not-yet-shipped orders at the balance date.
What matters is actual shipment, not the completed sale. For the year-end report, only shipments that actually left the warehouse packaged during the reporting year count.
If you use several warehouses within Germany, volumes are combined under one LUCID registration — registration is company-based, not warehouse-based.
In practice: export shipping data separately from each warehouse system, total the weights by material across all warehouses, and report the combined figure. Separate reports per warehouse location are neither required nor useful.
For custom builds, there's no standard value — you need to determine the weight individually, ideally by weighing an empty sample box on a precision scale.
Alternatively, ask your box manufacturer for the technical data sheet; reputable manufacturers state area weight and material thickness there, from which total weight can be calculated. For recurring use, the one-time precise determination pays off since it feeds into every future report.
No, generally not — as long as test packaging isn't filled with goods and handed to end consumers, no placing on the market under VerpackG occurs. Pure sample production or internal testing doesn't trigger a reporting duty.
As soon as first test buyers or a pilot group actually receive the goods packaged — for example, a crowdfunding campaign with fulfilment — the reporting duty starts with that first shipment, even if regular distribution hasn't begun yet.
For product bundles, the entire bundle packaging counts: the outer wrap holding the bundle together, plus the individual packaging of each included product, where that packaging remains present.
If you pack several individual products together for the first time in new outer packaging, you're the first placer for that outer packaging — even if the individual products already carry packaging licensed by their manufacturer.
Volume tracking for the new calendar year begins on 1 January. The actual reporting to LUCID and your dual system is forward-looking though: the advance report for the coming year is due by 31 December of the prior year, and the final report with actual figures is due by 15 May of the following year.
It's best to track volumes continuously, month by month, rather than compiling them shortly before the deadline — that reduces errors and surfaces deviations from the advance report early.
If a supplier change alters the packaging's material or weight, report both periods separately: the volume with the old packaging up to the switch date, and the volume with the new packaging afterwards.
If material and weight stay identical and only the supplier changes, that has no effect on reporting — combine the volumes normally for the full year. Keep material data sheets from both suppliers in case your dual system requests proof.
The year-end reconciliation is the comparison between the forecast volume reported at the start of the year and the actual volume placed on the market, which you report by 15 May of the following year.
If the actual volume diverges significantly from the forecast, the licence fee is adjusted accordingly — an overage triggers additional payment, an underage sometimes a credit, depending on your dual system's terms. This year-end figure must be filed with the identical value in LUCID as well.
Sanity-check your method with a spot test: fully weigh five to ten ready-to-ship parcels and compare the result with your calculated figure from individual weights times unit count. Larger discrepancies point to an error in your base data collection.
If unsure, the ZSVR publishes guidance on quantity determination on its website, and many dual systems will spot-check individual material categories on request. A documented, traceable methodology also protects you in later audits.
No. Only packaging that was actually filled with goods and placed on the market is reportable — packaging material still sitting unused in the warehouse doesn't count towards the annual volume.
That leftover material only enters the report for the year it's actually used to pack a shipment. For larger stock, run a simple inventory calculation to avoid confusing purchase with actual use.
Even with zero sales, an existing LUCID registration stays active and doesn't need deregistering if you expect to continue trading. For the affected reporting period, simply enter a volume of zero.
If you're permanently closing the business, you should properly deregister to avoid later confusion and unnecessary reminders from the ZSVR.
For subscriptions, track packaging per delivery cycle and multiply by the number of deliveries in the reporting year — twelve for monthly shipping, four for quarterly.
The entire box counts: shipping carton, filler material, individual packaging of the included items, and printed inserts. If the box composition changes during the year, determine weight separately for each variant and weight it proportionally.
If prior-year data is missing, keep reporting correctly for the current year and file a retrospective estimate for the gaps as soon as you've prepared one — don't wait for full reconstruction before taking any action at all.
Use available secondary sources such as sales figures, supplier invoices or bank statements to derive plausible values. Document the calculation basis in writing — a traceable estimate is accepted in practice, an unexplained absence of reporting is not.
Business gifts shipped packaged to recipients in Germany count towards the regular annual volume — report them together with your other shipments, split by packaging material as usual.
Since gift shipments are often packaged more elaborately than standard goods — premium boxes, extra filler, ribbons — their weight can contribute disproportionately to the total. Tracking this category separately makes for a more accurate report.
Packaging for rewards or prizes from loyalty programmes is subject to the same duties as regularly sold goods, once shipped packaged to a German end consumer — regardless of the fact that no purchase price was directly paid.
Track these shipments as their own category in your volume calculation, since reward items often come in different packaging sizes than the core range and are otherwise easily overlooked.
No. If the customer cancels before actual shipping, no packaging was placed on the market — no reporting duty arises for that order, regardless of whether the goods were already picked and packed.
If the goods were already packaged but hadn't left the building, the same applies: only actual shipment to the customer triggers the reporting duty. If that same packaging is later used for a different order, it counts for that shipment.
If you source finished, pre-packaged goods from a manufacturer and resell them unchanged, the packaging may already be licensed by the manufacturer — but that doesn't automatically release you from your own duties.
Ask for written proof of the manufacturer's licensing. If you add your own elements — shipping box, extra filler, an outer wrap for dispatch — you're the first placer for those additional elements and reporting- and licence-liable accordingly.
If product variants differ in packaging size or weight — for example, different bottle sizes or clothing sizes needing different boxes — track each variant separately with its own packaging weight.
Averaging across all variants is inaccurate and can be challenged during a check. Set a packaging weight for each SKU and multiply by that variant's sales volume.
Yes, this is possible with most dual systems and worth doing where the divergence is significant. If it becomes clear during the year that actual volume diverges substantially from the original forecast, you can usually request an adjustment to the advance report.
That avoids a large year-end top-up payment or shortfall and makes your cash-flow planning more accurate. Contact your dual system directly — options for mid-year adjustment vary by provider.
In genuine dropshipping — where your supplier packs and ships directly to the German end customer — the supplier, not you, has the reporting duty, since they're the first placer on the market.
You still need to submit your supplier's LUCID number and system participation proof to the marketplace — as their data, not your own. If you pack part of the orders yourself, you're independently reporting-liable for that portion. More in Who really needs LUCID registration?.
VerpackG reporting always follows the calendar year (January to December) — regardless of which financial year your company uses internally.
If your financial year differs, you'll need to analyse packaging volumes separately by calendar year for reporting purposes, even if your other accounting follows a different rhythm. There's no provision to convert or prorate the financial year onto the calendar year.
For large single deliveries — say, a full year's production imported in one batch — report the volume at the point of actual placing on the market, not at the point of import or warehousing.
That means the goods are reported across the period they're actually shipped packaged to end customers — not as a lump sum on arrival. For very large volumes, this can quickly reach the declaration-of-completeness thresholds (80 t glass, 50 t paper, 30 t other materials).
What's reported is the packaging originally used — transit damage at the customer's end doesn't change the already-reported volume, since the packaging was correctly recorded at the point of shipping.
The damage only becomes relevant if it leads to additional packaging use, for example a replacement shipment. Track that extra volume separately and add it to the regular annual total. It's worth tracking replacement shipments continuously so they aren't missed in the annual report.
A product's price category has no bearing on packaging reporting — what matters is purely the physical characteristics of the packaging: material and weight.
If only the sale price changes, the reported volume stays the same. It's different when a price change comes with a packaging change — say, a premium relaunch with upgraded packaging. Then weight changes and so does the report, regardless of the new price.
No. The LUCID report covers the total volume of all packaging placed on the German market — regardless of whether the sale happened online or through physical retail.
If you run both channels, add up the packaging volumes from both into one combined annual report. A separate registration or report per sales channel is neither required nor necessary.
Once your calculation methodology has been validated — for example through a spot-check comparison — reuse it consistently going forward rather than rebuilding it from scratch each period. Apply the same per-item weights and the same monthly export process for future reports.
Keep the validated methodology documented so new team members or a future dual system audit can follow the same logic. A confirmed, repeatable process also makes it far easier to catch anomalies quickly if a future report suddenly diverges from the established pattern.