Overview

Amazon has alerted sellers that any product shipped in packaging to German buyers must comply with the country’s Extended Producer Responsibility (EPR) packaging law, or risk having their listings removed from Amazon.de. The requirement applies to every seller, regardless of where the business is located, and non‑compliance can trigger fines of up to €200,000. Meeting the German packaging obligations is therefore essential for preserving sales and avoiding costly penalties.

Key Points

• Mandatory LUCID registration — Every seller must create an account in Germany’s central packaging registry before any packaged item reaches the German market.
• Dual‑system contract required — Sellers need a binding agreement with an authorized recycling scheme such as Der Grüne Punkt or Interseroh to fund collection and recycling of their packaging.
• Annual volume reporting — The Zentrale Stelle Verpackungsregister (ZSVR) expects a yearly declaration that details the exact amount and type of primary and secondary packaging used.
• FBA adds extra layers — Fulfillment by Amazon sellers must also account for Amazon‑provided secondary packaging—boxes, poly‑mailers, air pillows—when calculating their total packaging footprint.
• Continuous compliance — Registrations, contracts, and reports must be kept up to date; a one‑time filing does not satisfy the law.

How EPR Compliance Works for Amazon Sellers

1. Create a LUCID account — Register on the ZSVR portal using your business details; for example, a U.S. seller of cosmetics would enter the company name, VAT ID (if applicable), and contact information, then receive a unique LUCID number that must appear on all packaging declarations.
2. Select and bind a dual‑system provider — Choose a licensed recycling operator, sign a service contract, and pay the fees that correspond to the weight and material composition of your packaging; a Chinese electronics exporter might partner with Interseroh to cover cardboard, plastic, and metal components.
3. Calculate packaging volumes — Use Amazon’s internal EPR reports or your own inventory data to total the kilograms of primary packaging (the wrapper directly around the product) and secondary packaging (the box or pallet used for shipment). A seller of 10,000 units of kitchen gadgets might report 1,200 kg of cardboard and 300 kg of plastic film.