If you sell packaged goods to customers in Germany, you need to be registered in the LUCID packaging register, and the LUCID registration Amazon checks is a 13-digit number entered in its EPR compliance portal. Since 12 August 2026 the rules behind that number have changed: the EU Packaging and Packaging Waste Regulation (PPWR) and Germany’s VerpackDG replaced the old VerpackG. Most importantly for UK and other non-German brands, foreign producers who ship directly to German end users must now appoint an authorised representative.
This guide explains what changed, who counts as the producer, what Amazon expects and the steps to take now.
Key dates
- 1 July 2022: marketplaces and fulfilment providers in Germany must check sellers’ packaging compliance.
- 17 July 2026: VerpackDG published in the Federal Law Gazette (BGBl. 2026 I Nr. 207).
- 12 August 2026: PPWR and VerpackDG replace VerpackG. Authorised representatives become mandatory for foreign producers selling directly to German end users.
- 12 February 2027: deadline for EU Member States to set full PPWR sanction regimes.
- 31 October 2027 and 31 December 2027: transitional periods end for certain ZSVR authorisations.
What changed on 12 August 2026
According to the Central Agency Packaging Register (ZSVR), the PPWR and VerpackDG replaced the Verpackungsgesetz on 12 August 2026. The three basic obligations remain: registration, system participation and data reporting. What changed is who is obligated and what new responsibilities apply.
You may have read earlier reports that VerpackDG would start later than the PPWR because of an EU notification procedure. The ZSVR’s own page now states that both took effect on 12 August 2026, so that is the date to work from.
Who must register in LUCID
Any business that first places packaging or packaged goods commercially on the German market must be registered in LUCID. The ZSVR is clear that this includes companies based abroad. Registration is free of charge, and the ZSVR publishes the names of registered companies.
The new producer definition
Under the new rules, a foreign company is the “producer” only if it ships directly from abroad to a private or commercial end user in Germany. Separately, a company whose name or brand appears on the packaging is treated as both manufacturer and producer. The ZSVR calls this the brand principle.
| Your situation | What it means | What to do |
|---|---|---|
| You ship from abroad directly to German end users | You are the producer under the new rules | Register in LUCID, join a system and appoint an authorised representative |
| Your brand is printed on the packaging | Treated as manufacturer and producer | Register under your own company name |
| You were registered before 12 August 2026 | Your registration needs updating | Log in to LUCID and add your authorised representative when prompted |
Whether Amazon Remote Fulfilment from a UK warehouse, or your own merchant-fulfilled shipments, count as shipping directly from abroad for your business is a question to confirm with a compliance adviser. It is safer to assume the obligations apply and check the detail than to discover a gap after an offer is blocked.
The authorised representative requirement
Foreign companies with no German branch that sell empty packaging or packaged goods directly to end consumers in Germany must now appoint an authorised representative. Before 12 August 2026 this was voluntary.
- The authorised representative takes on your extended producer responsibility (EPR) obligations.
- LUCID registration itself remains your own responsibility as the manufacturer.
- The representative must be named in LUCID when you first register, and registration cannot be completed without these details.
- Foreign producers who were already registered are prompted to add one when they log in.
What Amazon requires
Amazon asks for the 13-digit LUCID number for German packaging in its EPR compliance portal, labelled “Konformitätsinformationen für erweiterte Herstellerverantwortung”. Packaging and paper are a single EPR category with one unique identification number (UIN).
Amazon states it is legally required to enforce producer obligations. It may deactivate non-compliant offers or meet requirements on your behalf, and missing or invalid EPR data can lead to restricted or removed offers.
Since 1 July 2022, electronic marketplaces have had to check that sellers comply, and block goods from sellers who are neither registered nor participating in a system. Fulfilment service providers may only serve compliant companies. Check with your adviser how this marketplace duty is worded under the new law.
Other German EPR categories on Amazon.de
Amazon.de’s second EPR category is electrical and electronic equipment, which requires registration with stiftung ear. Batteries are covered by Germany’s BattDG, in force since 7 October 2025, which requires companies without a German seat to use a German-based authorised representative. If you sell in France as well, Amazon.fr lists 19 EPR categories, each with its own UIN.
Penalties for getting it wrong
The ZSVR quotes these maximum fines: up to €100,000 for breaching the registration obligation, up to €200,000 for system participation and up to €10,000 for data reporting. Profits from cost savings can be confiscated, and non-compliant goods are subject to a sales ban.
These are the levels stated by the ZSVR. Whether VerpackDG keeps exactly the same maximums is worth confirming with your adviser, as Member States have until 12 February 2027 to set full sanctions under the PPWR.
Enforcement does not only come from the authorities. The ZSVR refers cases to the state enforcement authority where the company has its seat, and because LUCID is public, competitors can check your registration and take civil action.
Step-by-step: getting compliant
- Map your packaging. List every product, its packaging materials and the shipping packaging you or your fulfilment provider add.
- Confirm your role. Work out whether you ship directly from abroad to German end users and whether your brand is on the packaging.
- Appoint an authorised representative if you are a foreign producer with no German branch selling directly to German consumers.
- Register in LUCID under your own company and brand names, naming your representative.
- Join a packaging system and keep your data reporting up to date.
- Enter your LUCID number in Amazon’s EPR portal and in the equivalent settings on other German marketplaces. Our Amazon account management team maintains this data for clients.
- Set reminders for data reporting and for the 2027 transitional deadlines.
Beyond Amazon: Otto, Kaufland and the Netherlands
The packaging obligations apply to the goods, not the sales channel, so the same LUCID registration supports your sales on Otto and Kaufland. Each marketplace collects compliance data in its own way, so keep your registration details consistent everywhere.
For the Netherlands, Amazon’s EPR page lists no Netherlands-specific requirements. That does not mean there are no Dutch packaging obligations, and bol has flagged the PPWR from 12 August 2026 to its sellers. Ask your adviser about Dutch packaging EPR before you launch there.
Our checklist for selling on Amazon Germany from the UK covers how LUCID fits alongside VAT and GPSR.
Frequently asked questions
Is LUCID registration free?
Yes. Registration in LUCID is free of charge. System participation and data reporting are separate obligations, and joining a packaging system normally involves fees, so budget for them.
Do UK companies need a German authorised representative for packaging?
From 12 August 2026, foreign companies with no German branch that sell packaged goods directly to end consumers in Germany must appoint one. The representative must be named in LUCID at registration.
Where do I enter my LUCID number on Amazon?
In Amazon’s EPR compliance portal in Seller Central, under the German packaging category. Amazon asks for the 13-digit LUCID number, and packaging and paper share one UIN.
What happens if I sell without a LUCID registration?
Amazon may restrict or remove your offers. The ZSVR quotes fines of up to €100,000 for breaching the registration obligation, and non-compliant goods face a sales ban.
Not legal or tax advice. Packaging rules are changing during 2026 and 2027, so confirm your obligations with a qualified adviser.
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