Selling on Amazon Europe: Extended Producer Responsibility (EPR) and LUCID

Extended Producer Responsibility (EPR) is the principle by which anyone placing a product or its packaging on a country's market finances the management of the waste it generates. Each country implements this with a public register of producers and an identification number that proves registration.

Amazon does not request this due to internal policy: the law obliges marketplaces to verify that their sellers have this number. In Germany, from 1 July 2022 the VerpackG (the German Packaging Act) prohibited platforms from allowing sales by anyone not registered in LUCID and participating in a dual system. Since 12 August 2026, with the general application of the European Packaging and Packaging Waste Regulation (PPWR), the VerpackG has been replaced by the German act implementing the Regulation (VerpackDG), which keeps LUCID registration and participation in a dual system; marketplace verification remains under the European framework. In France, the AGEC law makes the marketplace itself responsible for the EPR obligations of its sellers if they do not provide their unique identifier.

This is why the requirement is identical on eBay, Kaufland, Cdiscount or any other platform: without an EPR number, the marketplace breaks the law if it lets you sell.

Yes. The obligation applies to any seller who ships products to the final consumer in that country, regardless of where they are established and with no minimum volume. The German register (ZSVR) states this expressly: distance selling to Germany always requires registration, even if the company is outside the country and the volumes are small. The shipping packaging (box, filling, tape) is almost always subject to participation in a dual system.

The same happens in France: foreign distance sellers who sell to French consumers must have their unique identifier for each product category. If they do not provide it, the marketplace assumes the obligation as the de facto producer and passes the cost on to you.

And do not forget Spain: anyone who is the first to make a packaged product available in Spain (even if only selling online) must appear in the packaging section of the Register of Product Producers of the MITECO, created by Real Decreto 1055/2022 (the Spanish Royal Decree on packaging). Distributors can only sell products from producers who have this number (article 30(a) of RD 1055/2022).

In Germany there are 3 linked obligations for packaging. First: registering in LUCID, the public register of the Zentrale Stelle Verpackungsregister (ZSVR). Registration is online and free: you create an account and immediately receive an activation email with a link that expires in 24 hours; after activating it, you have 7 days to complete the company details, packaging types and marketed brands. You obtain a 13 digit registration number which is public and which Amazon cross-checks. Important: German law (section 5.1 of the VerpackDG, as previously section 9 of the VerpackG) does not allow commissioning a third party to carry out this registration or the packaging data reports (Datenmeldungen), so the LUCID registration must be done by the producer themselves. In addition, if you have no establishment in Germany and sell directly to German consumers, the VerpackDG (section 5(2) and (4)) requires you to appoint, before the first shipment and by a written authorisation in German, an authorised representative for extended producer responsibility (Bevollmächtigter), who is notified within the LUCID registration itself and takes on the producer's other obligations in Germany, except the registration.

Second: signing a contract with a dual system (Duales System), the entity that licenses your packaging and finances its recycling in Germany. The fee depends on the material and the kilos you declare, and the contract requires you to already have the LUCID number: the order matters.

Third: declaring the volumes. The same data of kilos per material is reported to the dual system and replicated in LUCID (initial declaration and adjustment with the actual data for the year). Selling without registration or without participating in a system leads to a sales ban and fines of up to €100,000 for failing to register and up to €200,000 for failing to participate in a system (section 66 of the VerpackDG).

If you also sell electrical or electronic equipment in Germany, you need a different registration: the WEEE number from the Stiftung EAR, which is also uploaded to Seller Central.

Since 1 January 2022, every producer subject to a French EPR scheme (filière REP) needs a unique identifier (UIN) issued by ADEME, the French agency for ecological transition (article L541-10-13 of the French Environmental Code, introduced by the AGEC law).

The key is that the UIN is not one per company but one per category: household packaging, paper, textiles, electrical and electronic equipment, batteries, furniture, toys, etc. Amazon France currently distinguishes 19 product categories subject to EPR. If you sell packaged clothing, for example, you will need at least the packaging UIN and the textile UIN.

The UIN is obtained by joining the eco-organisation (the French equivalent of a collective scheme) for each category: for household packaging, Citeo or Adelphe; for textiles, Refashion; for electronics, ecosystem or Ecologic, among others. The eco-organisation registers you in SYDEREP (the ADEME platform) and provides you with the number. You pay an annual eco-contribution based on the units, kilos and materials declared.

The UIN must appear in your general terms and conditions of sale and be provided to anyone who requests it. Non-compliance is penalised with administrative fines of up to €30,000 plus coercive fines of up to €20,000 per day, according to ADEME.

Yes. Since 12 August 2026 Regulation (EU) 2025/40 prevails, and Real Decreto 1055/2022 on packaging and packaging waste (the Spanish Royal Decree) continues to apply where it does not conflict with it until the new Royal Decree is approved. The producer is whoever is the first to make the packaged product available in Spain: a manufacturer established outside Spain is the producer only if it sells directly to end users in Spain; otherwise, it is the importer, intra-EU acquirer or distributor who first makes it available in Spain. The producer registers in the packaging section of the Register of Product Producers (article 15 of RD 1055/2022) electronically at the MITECO e-office and receives a number (ENV/YEAR/XXXXXXXXX) that appears on its invoices and that Amazon also requests for selling on Amazon.es. If your company is established outside Spain and sells directly to end users in Spain, it must appoint an authorised representative in Spain (Article 45.3 of Regulation 2025/40 and article 17.2 of RD 1055/2022). A third party can register you and file your annual declaration with a power of attorney recorded in the Spanish Electronic Register of Powers of Attorney (REA); a foreign company needs a Spanish tax ID (NIF) starting with N to record that power of attorney.

Financial obligations are normally met through a SCRAP (a collective extended producer responsibility system, like those existing for household packaging), with a recurring fee based on the kilos of each material placed on the market. In addition, the packaging declaration for the previous year must be submitted to MITECO every year before 31 March (article 16 of RD 1055/2022); producers of less than 15 tonnes per year may declare in a simplified manner.

In Germany, Amazon deactivates the listings of any seller who does not provide a valid LUCID number, and does not reactivate them until the number is uploaded and validated against the public register. In France, where the Pay on Behalf service exists, Amazon declares and pays the eco-contribution on your behalf and charges the amount to your seller account, without you controlling the applied rate.

The new development for 2026 is the Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR), published on 22 January 2025, in force since 11 February 2025 and generally applicable from 12 August 2026. It generalises the German and French model for the whole EU: producer registration in each Member State where packaging is sold and reinforced control by marketplaces. In Germany, that same date marks the replacement of the VerpackG by the new implementation law (VerpackDG): anyone already registered in LUCID remains registered, but has until 12 November 2026 to report changes to their registration data, and dual system contracts signed under the previous law remain valid until 31 December 2026 at the latest. Amazon is extending the verification of the packaging number to all countries where the seller sells or stores.

Recovering an already blocked account takes time: you have to register, contract the system, upload the number and wait for validation. It is best to act in advance. Managora prepares your LUCID registration and accompanies you step by step in its submission (German law requires the producer themselves to formalise this registration), and manages for you the contract with the dual system, the French UINs for each category and the Spanish MITECO registration with its SCRAP, leaving the numbers uploaded in the Seller Central compliance portal. You can see the updated amount on the page for the EPR / LUCID Registration for Selling on Amazon procedure.