Overview

Amazon is actively enforcing Extended Producer Responsibility (EPR) compliance across its German marketplace, requiring all sellers to register with the LUCID packaging system or face immediate listing suspensions. The mandate applies universally — whether you use FBA or fulfill orders yourself — and failure to submit a valid 13-digit LUCID registration number through Amazon's EPR compliance portal will result in deactivated listings on Amazon.de.

What's Changing

• LUCID registration is now mandatory — Every seller on Amazon.de must obtain a 13-digit LUCID registration number through Germany's central packaging register, regardless of fulfillment method.
• Listings are being suspended — Amazon is already deactivating listings for sellers without valid EPR registration numbers, with enforcement covering all European marketplaces where EPR rules apply.
• FBA does not cover compliance — Even though Amazon handles fulfillment logistics, sellers remain legally responsible for their own EPR registration and reporting obligations.
• Portal submission is required — Sellers must enter their LUCID number directly through Amazon's dedicated EPR compliance portal to maintain active listings.
• Electronics sellers face extra requirements — Those selling electrical and electronic equipment must also register separately under Germany's WEEE regulations through stiftung ear.
• Ongoing reporting is mandatory — EPR compliance requires continuous reporting to a licensed Producer Responsibility Organization (PRO) and payment of environmental contributions based on sales volume.

Why EPR Applies to Nearly Every Amazon Seller

Extended Producer Responsibility is a European environmental framework that holds producers accountable for the entire lifecycle of their products, including disposal and recycling. Under German law, the definition of "producer" is broad: if you manufacture products in Germany, import products into Germany, or sell into Germany from another country, you qualify as a producer.

This means the vast majority of third-party Amazon sellers fall under EPR obligations. Germany implements these requirements through separate legislation for different product categories, with packaging and electrical equipment being the two most relevant for marketplace sellers. The specific obligations vary by product type, sales volume, and business structure, so sellers should not assume they are exempt based on what they sell.