Do I need to register for EPR in Germany if I sell on Amazon.de?

Yes. If you place packaged goods on the German market — including via Amazon FBA or Merchant Fulfilled — you must register in the LUCID Packaging Register, regardless of whether your company is based inside or outside Germany. Non-EU sellers must additionally appoint an Authorised Representative.

What is EPR registration and who needs it?

Extended Producer Responsibility (EPR) is a legal obligation that requires manufacturers, importers, and brand owners who place packaged goods on an EU or UK market to fund the collection and recycling of their packaging waste. Under the EU PPWR (Regulation 2025/40), EPR applies to any business selling packaged goods to consumers in EU member states.

Am I obligated under the German Verpackungsgesetz (VerpackG)?

Germany's Packaging Act (VerpackG) applies to any company — domestic or foreign — placing packaged goods on the German market for the first time. This includes online sellers, Amazon FBA sellers, and drop-shippers. Registration in LUCID and licensing through a PRO (e.g. Der Grüne Punkt) is mandatory before placing products on the German market.

Does EPR apply to Amazon FBA sellers outside the EU?

Yes. If you ship packaged products to buyers in EU countries, you are considered the first placer of that packaging on the market and are subject to EPR obligations in each country where you sell. The EU PPWR (from 2030, with 2025 transition measures) requires all sellers — including non-EU marketplace sellers — to register and report packaging tonnage.

Free tool

Am I Obligated?

Answer 5 questions to find out which countries require EPR registration for your products — and which regulations apply.

Details: EPR-Pflicht prüfen / Verpackungsgesetz Compliance

EPR-Pflicht (EPR obligation): Under the EU PPWR (Regulation 2025/40) and national laws such as Germany's Verpackungsgesetz (VerpackG), producers, importers and brand owners who place packaged goods on the market must register with a national PRO (e.g. LUCID) and report packaging tonnage annually.

Verpackungsgesetz (Packaging Act): Germany's national implementation of EPR for packaging, in force since 2019. Requires registration in the LUCID public register and licencing of all packaging placed on the German market — even for non-EU sellers on marketplaces like Amazon.de.

Hersteller / Erstinverkehrbringer (Producer / first placer): The legal entity responsible for EPR obligations — typically the brand owner or importer, not the marketplace. PPWR extends this to all online sellers targeting EU consumers.

Bevollmächtigter Vertreter (Authorised Representative): Non-EU sellers must appoint an EU-based Authorised Representative (AR) who assumes legal responsibility for PPWR/EPR compliance on their behalf. Mandatory in all 27 EU member states under PPWR.

Q1: Where is your company registered?

Now in force: PPWR marketplace verification guide →

Am I Obligated?

Q1: Where is your company registered?

Q2: Where do you sell products? (multi-select)

Q3: What do you sell? (multi-select)

Q4: Do your products contain packaging?

Q5: Approximate annual revenue?