Since July 1, 2022, operators of electronic marketplaces in Germany are legally obligated to ensure their sellers comply with the Packaging Act (VerpackG). This legislation shifted the burden of proof, forcing platforms like Amazon and eBay to delist any retailer lacking a valid LUCID registration number. The rules expanded on January 1, 2023, to include electrical and electronic equipment (EEE) under the ElektroG. This change affects thousands of international sellers, many of whom are still unaware of their obligations. Failing to provide a valid EPR number now results in an automatic sales ban. You can ensure marketplace compliance by acting immediately. These regulations are not optional; they are a mandatory prerequisite for market access.

Every company placing packaged goods on the German market must register with the ‘Zentrale Stelle Verpackungsregister’ (ZSVR) in the LUCID register. There are no sales thresholds or quantity exemptions; the rule applies from the very first item sold. A successful registration yields a unique EPR number for packaging. You can check the public register on the ZSVR website with your company details to confirm your status. Over 700,000 producers are currently listed in the LUCID database.

To check your status or register, follow these steps:

• Visit the official LUCID registration portal online.
• Provide your company details, including your VAT or taxpayer reference number.
• List all brand names under which you sell products in Germany.
• Declare the types of packaging material you will use (e.g., cardboard, plastic, glass).
• Conclude a contract with a dual system provider to pay recycling fees.
• Report your packaging volumes at least once per year.

A LUCID ID alone is not enough; you must also have a valid dual system contract. Without both, marketplaces will block your account. This verification process is now a standard part of selling on Amazon.de and other platforms.

If you sell any electrical or electronic equipment, you fall under Germany’s Electrical and Electronic Equipment Act (ElektroG), the national implementation of the EU’s WEEE Directive. Compliance requires registration with the Stiftung Elektro-Altgeräte Register (EAR), which issues a WEEE-Reg.-Nr. DE (WEEE registration number). This number is distinct from your packaging EPR number and is also verified by marketplaces. There are 6 categories of devices that require registration, from large appliances to small IT equipment.

For non-German companies, appointing a German-based authorised representative is mandatory for registration. This requirement adds a layer of complexity that many sellers are unprepared for. You can get your registration number quickly by working with a dedicated service provider. Verifying your WEEE status involves checking the official EAR database for your company’s or your representative’s name and corresponding WEEE number.

The German Battery Act (BattG) adds another critical compliance layer for many products. If you sell batteries, or products that include batteries (like toys or remote controls), you must register them separately. This registration is also managed by the Stiftung EAR but is a distinct process from the ElektroG registration. A single product could require compliance under all three EPR categories: packaging, electronics, and batteries. Many businesses successfully register for packaging and WEEE but forget their obligations under the BattG. This oversight can still lead to a sales ban for the affected products. The process requires detailing the battery chemistry, weight, and brand names. You can get a full analysis of your specific product requirements to close this compliance gap.

Ignoring your EPR obligations in Germany carries severe consequences that extend beyond a simple warning. The financial penalties alone can be crippling for a business. Fines for non-compliance with the VerpackG can reach up to €200,000 per case. For ElektroG violations, penalties can be as high as €100,000.

The immediate operational risks include:

1. Marketplace De-listing: Your products will be blocked from sale, cutting off your revenue from the German market entirely.
2. Destruction of Goods: Fulfilment providers may be prohibited from shipping your goods, potentially leading to their disposal.
3. Legal Warnings: Competitors can issue formal legal warnings for unfair competition, leading to additional costs.
4. Reputational Damage: Being de-listed for environmental non-compliance can harm your brand’s image with German consumers.

These risks make it essential to avoid EPR fines by proactively managing your status. The time for waiting has passed, as enforcement is now active and automated across all major platforms.

The complexity of German EPR law, with its multiple registers and specific requirements, makes DIY compliance a significant risk for any business located outside of Germany. You are not just registering once; you are committing to ongoing reporting and legal responsibilities. This is where seeking expert help becomes a strategic business decision. A single mistake in your data reporting can trigger an audit or penalties. Partnering with a specialist ensures 100% legal conformity and frees you to focus on your core business. Deutsche Recycling offers a full-service solution, managing all your registration and reporting duties across packaging, WEEE, and batteries. We act as your single point of contact to navigate the German regulatory landscape. If you have not yet taken action, you must do so now. Contact Deutsche Recycling today to comply with all regulations as quickly as possible and secure your access to German marketplaces. Learn more about our services for managing EPR from abroad.