EPR requirements: packaging in Germany

In Germany, when selling products on Amazon, sellers need to comply with Extended Producer Responsibility (EPR) regulations in two product categories: packaging and electrical and electronic equipment (EEE). This information focuses on the requirements for packaging in Germany:

**1. Registration on the LUCID Packaging Register:**

- Sellers must register as a "producer" on the LUCID packaging register.

- During registration, provide your brand names.

- After registration, you will receive a LUCID number, which is needed to enter into a system participation contract with a producer responsibility organization (PRO).

**2. System Participation Contract:**

- Determine the packaging volumes you sell in Germany by type.

- If your packaging is subject to system participation, you need to enter into an agreement with one or more PROs.

- Provide the PROs with your LUCID number.

**3. Reporting Packaging Volumes:**

- Sellers are required to submit data reports and pay system participation fees to the PROs regularly.

- Sign in to the LUCID packaging register to submit the same data report provided to the selected PROs.

**4. Provide Your LUCID Number to Amazon:**

- Go to the Compliance Information for Extended Producer Responsibility (EPR) portal on Seller Central.

- Submit your LUCID number.

- Amazon will validate your LUCID number with the German packaging authority, Zentrale Stelle Verpackungsregister (ZSVR). Validation may take up to five business days.

- Amazon reserves the right to contact you for additional information, such as a system participation certificate if required.

**Format of a LUCID Number:**

- A LUCID number follows the format DE (in capital letters), followed by a 13-digit number without spaces (e.g., DE1111111111111).

**Determining Producer Status:**

- You are considered a producer if you are the first to place packaging filled with goods in Germany on a commercial basis.

- This includes manufacturers, retailers distributing own brands, importers, online retailers using shipment packaging, and those responsible for FBA packaging used for shipping products.

**Packaging Subject to System Participation:**

- Packaging subject to system participation includes packaging that typically accumulates as waste with private final consumers, such as retail packaging, grouped packaging, service packaging, and shipment packaging.

**Differences Between Transport Packaging and Retail Packaging:**

- Transport packaging is used for protecting or securing products during transport and storage but is not intended to be used by private final consumers.

- Secondary packaging used for shipping products to private final consumers does not count as transport packaging.

**Drop Shippers and System Participation:**

- Drop shippers may need to register and enter system participation contracts if they are considered producers of secondary packaging used for shipping products.

- Fulfillment services that involve warehousing, packing, labeling, and shipping may lead to producer status.

**Validation of LUCID Numbers:**

- Amazon validates LUCID numbers with ZSVR, and the status can be checked on the Compliance Information for Extended Producer Responsibility (EPR) portal.

**Deactivated Listings and Reinstatement:**

- If sellers cannot prove EPR compliance by submitting a valid LUCID number, their listings will be deactivated.

- After submitting a valid LUCID number, selling privileges will be reinstated, but listings may remain inactive in Seller Central.

- Sellers can reactivate listings individually or in bulk using Seller Central tools.

**Incorrect Deactivation or Non-Producer Status:**

- If listings are incorrectly deactivated or if sellers are not producers, they should contact Selling Partner Support for assistance.

**Costs Related to Secondary Packaging:**

- Typically, the costs related to secondary packaging are a few euro cents per item.

- Details on costs can be provided by the selected PRO.

**Authorized Representatives:**

- International companies without a branch in Germany can appoint an "authorized representative" to fulfill packaging requirements on their behalf. This representative takes on all obligations under VerpackG.

This information is a comprehensive guide to complying with packaging EPR requirements in Germany when selling on Amazon. Sellers must adhere to these requirements to avoid listing deactivation and remain in compliance with German law.