The German Packaging Act, or Verpackungsgesetz (VerpackG), became effective on January 1, 2019, replacing the previous Packaging Ordinance. This legislation applies to any company that is the first to place packaged goods on the German market, which includes international eBay sellers shipping to German end-consumers. The law’s primary goal is to increase recycling rates, making producers financially responsible for the collection and recycling of their packaging waste. There are no volume thresholds; the law applies even if you only ship one package to Germany. This legislation is a key part of Germany’s Extended Producer Responsibility (EPR) framework, which holds you accountable for the entire lifecycle of your packaging. The regulations cover not just the product’s own packaging but all shipping materials, including boxes, tape, and bubble wrap. Understanding these foundational requirements is the first step toward securing your business operations in Germany.

To legally sell to Germany, every online retailer must fulfill three specific duties without delay. These obligations form the basis of your packaging license for selling on German eBay. First, you must register with the ‘Zentrale Stelle Verpackungsregister’ (Central Agency Packaging Register) via its public database, LUCID. This process is free of charge and generates your unique EPR number, which is required for all subsequent steps. Second, you must sign a contract with a state-approved dual system. This involves paying a license fee that covers the cost of collecting and recycling the packaging volumes you will place on the market. Third, you are required to report your packaging volumes and the name of your dual system to the LUCID register. These three actions must be completed before your products are shipped. You can find guidance on the entire process in our guide for international sellers.

The regulatory landscape shifted significantly on July 1, 2022. From this date, online marketplaces like eBay and Amazon are legally obligated to verify that their sellers are compliant with the VerpackG. This means they must check if you have a valid LUCID registration number and are participating in a dual system. If you cannot provide this proof of compliance, eBay will restrict your selling privileges for the German market. This is not a future possibility; it is an active enforcement measure. Your LUCID ID number must be added directly to your eBay seller account to avoid interruption. This enforcement makes compliance a direct prerequisite for market access, shifting it from a background legal issue to an immediate operational necessity. To ensure you remain compliant, review our German marketplace regulations overview.

Obtaining your packaging license for selling on German eBay involves a clear, three-step process. You must complete these steps personally, as third-party registration is not permitted for the initial LUCID setup.
1. Register with the LUCID Packaging Register: Visit the ZSVR’s LUCID portal. You will need to provide your company name, address, contact details, and tax ID to receive your unique EPR number. This registration is mandatory for every single business.
2. Contract with a Dual System: With your LUCID number, you must select and sign a contract with a licensed dual system in Germany. You will need to estimate the volume and type of packaging materials (e.g., cardboard, plastic) you expect to ship to Germany over a one-year period.
3. Report Your Data: After contracting with a dual system, you must log back into your LUCID account. Here, you will report the name of your chosen dual system and the licensed packaging volumes.
4. Add LUCID Number to eBay: The final step is to enter your LUCID number into the designated field in your eBay account settings to prove your compliance.
This process ensures you are fully covered, but it requires immediate attention. For a detailed breakdown, use our VerpackG compliance checklist.

Ignoring the VerpackG requirements carries substantial financial and operational risks. German authorities can impose severe penalties for violations, with fines reaching up to €200,000 for failing to participate in a dual system. Failure to register with LUCID can result in a fine of up to €100,000. Beyond monetary penalties, authorities can issue an immediate sales ban, effectively halting all your business activities in Germany. Competitors can also report non-compliant sellers, leading to investigations. Since July 2022, the most immediate consequence is action from eBay itself, which will delist products or suspend accounts of non-compliant sellers to meet its own legal obligations. These risks make proactive compliance the only secure path forward. Understanding the German dual system is key to avoiding these penalties.

The regulations surrounding the packaging license for selling on German eBay are not new, but their enforcement by marketplaces is a critical development. The grace period is over, and compliance is checked automatically. Every day you operate without a valid license is a day you risk account suspension and financial penalties. The EU continues to strengthen its environmental directives, and Germany’s strict enforcement is a clear indicator of the direction of regulation across Europe. Waiting for a warning is not a viable strategy, as the first notification may be the suspension of your listings. Immediate action is the only way to guarantee uninterrupted access to your German customers. If you have not yet taken these steps, your business is currently at risk. To secure your operations, you must begin the compliance process today. A yearly packaging license is your ticket to continued sales.

Navigating the complexities of the VerpackG can be a significant administrative burden, especially for international sellers. Deutsche Recycling offers a comprehensive service to manage all your EPR obligations efficiently and reliably. We handle the entire process, from calculating your packaging volumes to managing your dual system participation and ensuring all reporting is completed accurately and on time. Our service guarantees 100% legal conformity, giving you the peace of mind to focus on your core business. Instead of deciphering complex legal texts and managing deadlines, you can rely on our expert team. Don’t let regulatory hurdles block your access to one of Europe’s largest e-commerce markets. Contact Deutsche Recycling today for a consultation and ensure your business is fully compliant without delay. Our full-service compliance solutions are designed for sellers like you.