Why Germany is different from your home market
In the Netherlands, the packaging declaration threshold at Verpact sits at 50,000 kilograms per year. Stay below it and there is nothing to declare and nothing to pay. Germany has no such threshold. The German packaging act — the Verpackungsgesetz — puts the obligation on anyone supplying packaged goods to German end consumers, starting with the very first parcel.
That difference catches out many sellers. A shop that started on a home marketplace and expands to Amazon.de, Kaufland or OTTO carries its home logic along: 'we are small, this does not apply yet'. In Germany that assumption is wrong from day one — and it is not a regulator who eventually points it out, but the marketplace that blocks your listing.
What you actually need: two steps
The German obligation has two parts that are often confused.
Step one is registration in LUCID, the public register of the Zentrale Stelle Verpackungsregister (ZSVR). You do it yourself, online, free of charge. You receive a registration number — your EPR number — which is publicly verifiable.
Step two is the contract with a dual system. Germany organises the collection and recycling of consumer packaging through private schemes. As a seller you buy participation for the volume of packaging your parcels put into German households. This part is paid: the fee depends on material and weight.
Both steps must be completed before your first shipment. A LUCID number without a dual-system contract is not sufficient; the register entry and the contract belong together.
The marketplace is the enforcer
The German system has one feature that makes it more immediately felt than most legislation: marketplaces are legally obliged to check that their sellers are registered. Amazon.de, Kaufland and OTTO ask for your EPR number and verify it against the public LUCID register.
Without a valid number, the marketplace may not offer your products. In practice that means your listing gets blocked, or your account is closed for the German market, until your registration is in order. Enforcement is not a letter that arrives months later — it sits inside the sales flow itself.
On top of that, violations carry fines of up to 200,000 euros per case, alongside a sales ban. A small seller is unlikely to face the maximum — but the listing block hits everyone, including the shop with ten orders a month.
Does the European PPWR change any of this?
Since 12 August 2026 the European packaging regulation, the PPWR, has applied directly across all member states. A fair question is whether it replaces or softens the national registrations.
The answer, for now: no. The PPWR confirms that producers register per member state for extended producer responsibility. More harmonisation is coming in labelling and reporting, but registration in your customer's country — LUCID for Germany — remains the rule. Nor does the PPWR introduce any EU-wide minimum threshold exempting small sellers.
For cross-border sellers the PPWR mainly adds requirements on the packaging itself, such as the rule that an e-commerce parcel may contain at most forty percent empty space. The national registrations do not go away.
A practical checklist
One: determine whether you supply German end consumers — now or soon. If so, register in LUCID before the first shipment. Registration is free and you can do it yourself; agencies charging hundreds of euros add little for a standard webshop.
Two: contract a dual system for your expected German packaging volume. For small volumes the annual cost is modest; the contract is a requirement, not an option.
Three: file your EPR number with every marketplace where you serve German customers, and keep the confirmation. The marketplace verifies the number against the public register.
Four: track your volumes. Dual-system fees are based on material and weight, and your order data is the natural source. A seller whose orders and shipments per country are well administered already has these numbers in hand.