Legal Requirements and Documents in Germany for Amazon Germany FBA Private Label
LUCID Packaging Registration
When shipping products to the German market through Amazon Germany FBA private label, full compliance with environmental legislation and product conformity rules is required. Since 2023, platforms such as Amazon are also obliged to verify that sellers meet these legal requirements. Below are the key legal requirements in Germany related to the LUCID system that deserve particular attention. You can also read our related article, What is Amazon SPN? What are its advantages?
Packaging EPR Registration (LUCID system):
Germany applies the VerpackG Packaging Act, which makes producers responsible for the recycling of packaging waste. Under this law, every company selling products in Germany must complete LUCID packaging registration and participate in a recycling financing system for its packaging waste. LUCID is the online registration portal operated by the (ZSVR)Zentrale Stelle Verpackungsregister. Registration is free of charge, and you receive an EPR registration number (LUCID registration number).
How do you register in the LUCID system?
First, you register by entering your company details in the ZSVR's LUCID portal. You then sign an agreement with an authorized "dual system" company that collects packaging waste in Germany, and pay a recycling fee based on the amount of packaging you place on the market.
For example, an annual packaging license is purchased from a dual system such as Der Grüne Punkt, or Landbell. After obtaining the license, you declare the contracted packaging quantity in the LUCID system. This registration and licensing process shows that you cover the recycling costs of the waste generated by your product packaging.
Sellers without a LUCID EPR registration are not permitted to sell in Germany. If you sell without registering, German authorities may stop your sales and impose administrative fines of up to €100,000.
Similarly, placing packaging on the market without a dual system license can lead to fines of up to €200,000. For this reason, it is important to complete your LUCID registration and share your EPR number with Amazon before entering the German market.
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After August 12, 2026: authorized representative requirement
The sequence above changed in 2026. The EU Packaging and Packaging Waste Regulation (PPWR) and Germany's implementing act, VerpackDG, entered into force on August 12, 2026, replacing the 2019 VerpackG. The obligations for registration, dual system participation and quantity reporting remain the same; what changed is who fulfills them. According to the ZSVR, every business without a branch in Germany that ships directly to German consumers must now appoint an authorized representative (Bevollmächtigter) established in Germany; this was previously optional, and there is no exemption.
The sequence works as follows: 1) The authorized representative opens its own separate account in LUCID; a producer cannot list the representative in its registration until the representative is registered. 2) The producer completes its own registration and enters the representative's name or LUCID ID in the "Authorized Representative" field; the registration cannot be transferred and remains in the producer's own name. 3) The representative confirms the appointment through LUCID; according to the ZSVR, the authorization takes effect only after this confirmation. 4) After confirmation, the dual system contract, packaging quantity reports and the declaration of completeness become the representative's obligation.
While the third step is pending, the registration may look complete to the seller, even though the packaging side has not yet started and the listing may remain inactive. The full picture of the German market, including VAT and GPSR, is in our guide to selling on Amazon Germany.
Germany LUCID Registration and the VerpackG Packaging Act: Frequently Asked Questions (FAQ)
Q: What is VerpackG (the Packaging Act)?
A: VerpackG is a law that places the recycling cost of all product packaging shipped to Germany on the seller. It entered into force on January 1, 2019, and covers all e-commerce sellers selling in Germany.
Q: Why was this law introduced?
A: The goal is to protect the environment and make sure packaging waste is recycled professionally. Sellers cover the cost of disposing of or recycling the packaging they place on the market.
Q: Who has to comply with VerpackG?
A: Every company that ships packaged products to Germany, Amazon and other online marketplace sellers, in short anyone whose packaged products reach the end consumer.
Q: What is LUCID registration?
A: LUCID is Germany's official Zentrale Stelle Verpackungsregister system. Sellers register there and receive an "EPR (LUCID) registration number".
Q: How do you register in LUCID?
- Create a free account on the LUCID Packaging Register website.
- Enter your company details and brand name.
- Declare your packaging types and quantities.
- Sign an annual license agreement with a dual system company (for example Der Grüne Punkt or Landbell).
- Report your license number in the LUCID system.
- Add the logo you are given to your packaging, where applicable.
Q: What is a dual system?
A: Dual systems are licensed companies that organize packaging recycling in Germany. Examples include Der Grüne Punkt, Landbell and Interseroh+. You pay an annual license fee based on the type and quantity of your packaging.
Q: Which packaging requires a license?
A: Glass, paper, cardboard, plastic, metal, beverage cartons, composite packaging and so on. In short, any packaging that protects your product.
Q: How do you pay the Der Grüne Punkt license fee?
A: Using the License Calculator on the official Der Grüne Punkt website, you can calculate quantities by packaging material and pay the annual license fee.
- If you use packaging other than paper and plastic, click the "Add Category" button to see and add all material types.
- The system calculates the price automatically based on the packaging types and quantities you select.
- After the calculation, you can pay by credit card or bank transfer.
Q: What happens if you do not comply with VerpackG?
A:
- Fines of up to €100,000,
- Fines of up to €200,000 for not participating in a recycling system,
- A sales ban on Amazon.de,
- A halt to the distribution of your products in Germany.
Q: Why does this matter for Amazon sellers?
A: Since July 1, 2022, Amazon.de does not allow sellers without a LUCID number to sell. If you are not registered, your listings may be deactivated. We cover the topic in more detail in our Amazon Europe selling article.
In summary, for every seller who wants to sell in Germany, VerpackG compliance and LUCID registration is one of the most important steps of market entry. Managing this process correctly not only reduces legal risk, it also helps your sales on platforms like Amazon.de continue without interruption.
At Export Partners, we support sellers entering the German market end to end, starting with the required documentation and registration processes and continuing through private label brand development, Amazon FBA operations management and product listing optimization. From LUCID registration to CE documentation, and from trademark registration to product strategy, we work with you at every stage to help you build a strong and sustainable brand presence in Germany.
📞 Get in touch with us today and start your journey in the German market with confidence.
Last updated: September 22, 2026
