Recent amendments to EU directives place 100% of the liability on marketplace operators like OTTO to ensure seller compliance. Since July 1, 2022, for packaging and January 1, 2023, for electronics, OTTO must suspend any seller who fails to provide valid EPR registration numbers. There is no grace period; this is a strict, legally mandated obligation affecting thousands of sellers. Failing to act results in an immediate sales ban. These German regulations are precursors to the EU-wide Packaging and Packaging Waste Regulation (PPWR), which will soon enforce these rules across all 27 member states. You must check your EPR status today. This shift makes proactive compliance essential for maintaining market access.

Extended Producer Responsibility in Germany covers three main categories, each with its own registration process. You are considered a ‘producer’ for any of the 3 categories if you are the first to place such goods on the German market, even as an international online seller. There are no de minimis thresholds for packaging compliance; the rules apply from the very first item you sell.

Your obligations fall into these areas:

• Packaging (VerpackG): You must license all packaging materials (product, shipping, and filling) with a dual system and register in the LUCID portal, which has over 1 million registered producers.
• Electronics (ElektroG/WEEE): Sellers of electrical and electronic equipment must register with the Stiftung EAR foundation and provide a WEEE number.
• Batteries (BattG): If your products contain batteries, you must also register with Stiftung EAR under the Battery Act.

Ignoring even one of these 3 areas can halt all your sales. A complete guide to German EPR can clarify these distinct requirements. Understanding these categories is the first step toward securing your business.

The financial and operational risks of ignoring EPR duties are substantial. Authorities can impose fines of up to €200,000 for each violation of the Packaging Act or Electrical and Electronic Equipment Act. Beyond fines, OTTO is legally obligated to delist 100% of your products, leading to a total loss of revenue from a platform with over 11 million customers. Competitors can also issue legal warnings under unfair competition laws, leading to costly legal battles that can exceed €10,000 per case. The primary risk is not a fine, but the complete stop of your sales activities. You need a full EPR compliance solution to mitigate these severe risks. These consequences underscore the urgency of addressing your compliance status.

Achieving compliance requires a systematic approach across all relevant EPR categories. Following these four steps will ensure you meet all legal requirements for selling on OTTO. This process involves interacting with at least two separate German regulatory bodies.

Here is your action plan:

1. Register with LUCID: First, register your company with the ZSVR’s LUCID Packaging Register to obtain your EPR number for packaging. This is a mandatory first step for all sellers.
2. Secure a Dual System Contract: License your projected annual packaging volumes with a German dual system. This fee covers the cost of recycling your packaging.
3. Register with Stiftung EAR: For electronics and batteries, register with the Stiftung EAR. International sellers must appoint a German-based authorized representative for WEEE registration.
4. Submit Numbers to OTTO: Provide your LUCID number and WEEE number to OTTO through your seller portal to prove your compliance and prevent account suspension.

This process can take several weeks, so it is critical to begin immediately. The next section explains how to accelerate this process with expert help.

Navigating Germany’s complex regulatory landscape requires significant time and expertise. Deutsche Recycling offers a comprehensive service that manages 100% of your EPR obligations. We handle the entire registration and reporting process, ensuring you meet every legal deadline and requirement. Our team acts as your single point of contact, eliminating the need for you to deal with multiple German agencies. We guarantee 100% legal conformity for your business. By partnering with us, you save dozens of administrative hours and can focus on your core business of selling. A guide for international sellers can provide more context. Contact Deutsche Recycling now to get your compliance handled swiftly and professionally.

Beyond EPR, OTTO enforces its own set of seller standards to maintain a high-quality marketplace. These are non-negotiable requirements for every partner on the platform. All sellers must have a German business entity, a German VAT ID, and ship from a warehouse located in Germany. This ensures fast, reliable delivery for the 94% of German customers who prioritize it. Furthermore, every seller must agree to OTTO’s “Business Partner Declaration on Sustainability,” which prohibits materials like real fur and PVC in packaging and mandates fair production conditions. Adherence to these standards is checked during onboarding and is mandatory for all 4,000+ sellers. Our checklist for selling in Germany covers these points in detail. These rules demonstrate OTTO’s commitment to a responsible and trustworthy e-commerce environment.

The requirements to ensure compliance for selling on the OTTO marketplace are not suggestions; they are legal mandates with immediate consequences. With enforcement now fully active, any delay directly translates to lost sales and potential fines exceeding €100,000. The regulations in Germany are a clear indicator of the direction all EU marketplaces are heading. Taking decisive action today not only protects your current business on OTTO but also prepares you for future EU-wide laws. More than 1,000,000 producers are already registered in LUCID alone. Do not wait for your listings to be suspended. Contact Deutsche Recycling immediately for a consultation and let our experts handle the complexities of EPR compliance for you. Our full-service compliance ensures you remain operational and secure.