Continue selling to Germany under the new packaging rules

Continue selling to Germany under the new packaging rules

What to do

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Step 1: Appoint an authorized representative in Germany

If your company is located outside Germany and does not have a branch there, you must appoint an authorized representative based in Germany. Start here, because you will be asked for their details when you register for LUCID ID.

As long as your contract with them runs, they will arrange the following:

  • Signing a system participation agreement with one or more dual systems

  • Reporting of your packaging volumes

  • Submitting completeness declarations

  • Comply with the packaging return obligations under Article 39 of VerpackDG

  • Participate in the national deposit scheme, which involves deposit-bearing disposable beverage packaging

The LUCID registration itself is the only task they cannot take on. You have to do that yourself.

Step 2: Register for LUCID under your own company name

Go to packagingsregister.org and register as a producer. That is the only official register.

What does the form ask for:

  • Your login. The activation email will expire after 24 hours. Please check your spam folder.

  • Master data. Company address, telephone number, VAT number or national taxpayer reference and national identification number.

  • A packaging category. For orders that Printful fulfills, choose packaging subject to system participation. If you ship something yourself or use another provider, it is worth checking whether that packaging belongs in the other category.

  • Any brand name on your packaging. A store name that differs from your company name counts as a brand. Multiple stores means multiple listings.

  • An explanation that you meet the system participation requirement, which is step 3.

Step 3: Sign an agreement with a dual system provider

Your LUCID entry is just a statement. Not a single parcel is collected or recycled, nor is anyone paid for it to do so.

That is A’s job dual system: a recognized company that arranges the collection and recycling for youwhich calculates how many packages you put on the market and what they are made of.

The Green Dot is one of the best-known providers in Germany. The full list of approved providers can be found on the ZSVR website.

Depending on the terms of your agreement with your authorized representative, they may register with a dual system provider and submit your packaging details to them on your behalf. Make this clear when choosing a representative to avoid duplicating work or skipping essential steps.

Stopping after step 2 is the most common mistake. Registration in itself is not compliance.

Step 4: Report your packaging volumes

Your dual system provider will ask you to report how many packages you have placed on the German market and what they are made of. If you have previously used Printful’s LUCID number, you will need to declare the packaging starting August 12. The obligation has then shifted from Printful to you. The dual system provider then invoices based on the reported quantities.

For Printful-fulfilled orders, we prepare the technical packaging information you need for these reports. We will keep you informed as soon as it becomes available.

Step 5: Provide your LUCID number to each sales channel

This last step is manual. You must add your EPR number for each sales channel.

  • Etsy: Dashboard → Finances → Legal and tax information → Government registrations → Add LUCID ID → Send

  • Amazon: Switch to the Amazon.de marketplace in Seller Central, follow the banner asking for your LUCID number, and then submit it under the Germany section of the Compliance Portal. Validation takes up to five business days and your listings may remain blocked until it is completed.

  • eBay: My eBay → Account → Business Information → Business Details → select Add, next to LUCID ID → Save. Business accounts only, so switch from Individual first if necessary.

  • TikTok store: Seller Center → My Account → Qualification Center → Extended Producer Responsibility (EPR) → enter your LUCID ID

  • Somewhere else: Please contact that platform’s support team.

Platforms may revise these requirements, so it’s worth confirming the current process every now and then.

Submission rejected? Check the number for spaces and ensure your company name and VAT details match your LUCID entry. TikTok Shop also requires that the number matches the name of your legal entity.

What’s changing

Germany came up first

PPWR, formally known as Regulation 2025/40, has applied across the EU since 12 August 2026. It brings one set of packaging rules to all member states, aimed at reducing waste and making packaging more sustainable and recyclable.

Germany has transposed the PPWR through national legislation PackDG. Elsewhere in the EU, the older EPR rules still apply until PPWR-specific changes are implemented. We will keep you informed as the legal landscape changes.

You now have to register for LUCID yourself

Until August 12, 2026, sellers who fulfilled all their German orders through Printful could provide Printful’s LUCID ID to their marketplace instead of registering themselves.

Unfortunately, that is no longer the case. Now every company must register with LUCID under its own name, even if all its German orders are fulfilled through Printful.

Your customers’ location matters here, not yours

Sales destinations determine your EPR obligations, not your business address. For example, a US seller without an EU legal entity still counts as a producer under the PPWR. Ship to Germany and these rules all apply to you, even if EPR has never been thought of for you before.

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