Germany EPR Compliance (packaging)

[romeo b]

I've had an email today from eBay stating that I need to register for the German packaging system which essentially accounts for what packaging you use, and distribute, into Germany. I only send hard-backed recyclable envelopes with small value items (usually <£10-20). I worked out I sent about 2.5kg combined weight of cardboard to Germany in the last 365 days.

Message from eBay states:

As you sell goods to German customers on eBay, we are writing to let you know that there are important requirements for your listings. These are due to the German Packaging Act (VerpackG) and your Extended Producer Responsibility (EPR). These regulations focus on sustainability and help to prevent and manage waste.

To comply with the Packaging Act you’ll need to license your packaging with a dual system and register with the LUCID packaging register. We have brought in our experienced partner company Lizenzero to help you make the changes that are required.

eBay has a legal obligation to make sure that its commercial sellers are compliant with these regulations by 1 July 2022. If you do not take the necessary steps by the deadline, we will be legally required to restrict your selling privileges for the German market.

I managed to register on the LUCID dashboard and obtain a license number without much trouble using our company information etc on the LUCID packaging register (https://lucid.verpackungsregister.org) but now it looks like I have to submit the actual weights etc to some sort of secondary company - and eBay recommend Lizenzero (https://www.lizenzero.de/en).

This looks to cost me €39/year for my paper weight I send via Lizenzero.

On the LUCID dashboard (main register), it looks quite involved. You have to submit weights, planned forecasted volumes of mixed recycled stocks and cardboards/packaging for the next year etc that you intend to use.

Basic overview of the requirements: https://www.verpackungsregister.org...ic-paper_Information-for-retail-companies.pdf

Anyone managed to register somewhere where it's free? Is this such a thing? This is going to be a headache and financial burden if each country adopts this procedure.

You can also appoint people to do it for you - again will cost extra money too.

Far too much involved nowadays for a small one/two man business shipping minor items around the world. It's utterly ridiculous in fact.

Getting harder and harder to actually get things sent from UK to Europe nowadays.

Anyone have any experience or knowledge on this? I believe it's been around for a while in some form of another but the first I've really heard about it today.

Cheers.

 

[fallschirmjaeger]

Romeo - I also had this and have also registered with LUCID. I found this site that compares as you call secondary companies - verpackungslizenz24.de

Yes you need to pay one of these companies and the one recommended by eBay is on this list and also seems to be the most expensive.

If other countries bring this in there is probably no way i can administrate all this!

I too would like to know if anyone can recommend 'secondary' or dual companies before i pay for one!?

 

[romeo b]

Romeo - I also had this and have also registered with LUCID. I found this site that compares as you call secondary companies - verpackungslizenz24.de

Yes you need to pay one of these companies and the one recommended by eBay is on this list and also seems to be the most expensive.

If other countries bring this in there is probably no way i can administrate all this!

I too would like to know if anyone can recommend 'secondary' or dual companies before i pay for one!?

Thanks - checked on that website, seems to be that "verpackgo.de" are €25/year, and then the one above I listed (ebay recommended) come in next at ~€36.

Looking at the main LUCID portal, it makes absolutely no sense to me in there with regards to what you submit. When you go to the "Submit data report" option, then "Initial planned volume report" (to supply it for 2023, for example), it lists a few "System Operators" which you choose from - no idea what or who these are. And from there you provide a weight in KG. Presume this is all I would do? Or does the appointed company above do that bit?

Are we supposed to do this now for the current 2021/2022 year?

Very confusing stuff this.. and not long to get it right now ?

Keep me posted if possible with your discoveries!

 

[WaveJumper]

Have a read here then scroll down to the how to register for free + the link:

The German Packaging Act (VerpackG): How to get your online shop compliant

The German Packaging Act, known as VerpackG in Germany, is one of the most important laws for e-commerce in Germany. No matter whether you are a start-up, SME, or big player – if you sell in Germany, the laws are applicable, and the price of non-compliance is high.

ecommercegermany.com

 

[Jenni384]

Do we know what other EU countries also have something similar? I suspect I'm going to have to stop shipping to the EU, the administrative burden is getting too high, what with compliant packages being returned by customs all too frequently as well.

Saying that, I found one for Eur6.95 for the year, as my packaging is less than 1kg a year, via this link

Verpackungslizenz Vergleich 2026 - günstigste Anbieter ab 13,50€!

Günstige Verpackungslizenz finden ✓ Kostenloser Vergleichsrechner ✓ Alle dualen Systeme ✓ Bis zu 300% sparen ✓ EPR-Nummer für Amazon & eBay ✓ Lösungen für alle EU-Länder

verpackungslizenz24.de

 

[romeo b]

Do we know what other EU countries also have something similar? I suspect I'm going to have to stop shipping to the EU, the administrative burden is getting too high, what with compliant packages being returned by customs all too frequently as well.

Saying that, I found one for Eur6.95 for the year, as my packaging is less than 1kg a year, via this link

Verpackungslizenz Vergleich 2026 - günstigste Anbieter ab 13,50€!

Günstige Verpackungslizenz finden ✓ Kostenloser Vergleichsrechner ✓ Alle dualen Systeme ✓ Bis zu 300% sparen ✓ EPR-Nummer für Amazon & eBay ✓ Lösungen für alle EU-Länder

verpackungslizenz24.de

What type of packaging is that using? We use card-backed envelopes and the cheapest I can see is the €25 option from Veolia.de

I don't even know how it's monitored, as they can't weight your package as that is inclusive of the product inside it.

 

[NWH]

This note arrived from Etsy. The details might be of some assistance>

Hello, We’re getting in touch because our records show you may have delivered to Germany in the past or may have delivery profiles that include Germany. We want to make you aware of some changes to German law and help ensure that your shop is prepared before those changes take effect in July. In 2019, the German government enacted new packaging laws to reduce the negative impacts of packaging waste on the environment and increase recycling rates in Germany. These laws state that if you deliver to Germany – whether you’re based in Germany or elsewhere – you’ll need to register your tax ID and information with the LUCID Packaging Register, the German government database. If you don’t register, you could face fines from the German government up to €200,000 and a prohibition in sales, and your goods could possibly be confiscated during delivery. Fortunately, you can make sure your shop is compliant in three easy steps. Here’s what you need to do: If you haven’t already, register your business in Germany’s LUCID system to receive your LUCID identification number. Once you’ve received your LUCID identification number, click on the button below. You can reach the same destination by going to your Shop Manager > Finances > Legal and tax information. Scroll down to the section titled Government registration and click on the Add LUCID ID number button to enter your LUCID identification number. Submit your LUCID ID ​

 

[LHow]

(Expletive deleted) This is news to me! I found this post accidentally. @romeo b and @Jenni384 I am starting to agree with you about the administrative burden shipping to the EU with yet another legal requirement. I have done a quick bit of research & found this https://www.lizenzero.de/en/packaging-licence-fees/packaging-licenceweight-calculator/
which might be useful to anyone needing to calculate their packaging. I am now trying to figure this out. Anyone else got any further with this?

 

[Andrew_D]

I believe you can appoint an "Authorised Representative" to do all the submissions on your behalf. I have contacted a couple and the costs of the packaging are low, but they charge an admin fee so for occasional orders to Germany that can work out expensive. One was wanting 400 Euro admin fee annually, another 98 Euros plus a miniumum packaging payment of 98 Euros.

Has anyone found an "Authorised Representative" without admin fees?

Alternatively, if I pay a company like lizenzeo.de then is it straightforward to just type my submission into the LUCID dashboard myself?

 

[Mister B]

Has anyone found an "Authorised Representative" without admin fees?

Alternatively, if I pay a company like lizenzeo.de then is it straightforward to just type my submission into the LUCID dashboard myself?

Absolutely no need to use an authorised representative at all.

We file our own submissions for Germany and find it to be a very straigh forward process.

 

[zefeena]

I've just come across this, clicked on the Lizenzero, and it appears even if I send 1 package a year I will be paying a minimum of £39 euros? It also had dates for 2019, 2020, 2021, so has this been in operation for a few years? If I am correct that the minimum charge is £39 euros (presuming there are no other minimum fees elsewhere), then for such as myself, its really not worth it (can EU think up any more ways to stop us trading!!). (I literally send 2-3 packages to Germany a year (probably no more than 12 international per year), and as its generally fabric, its in a plastic mailing bag, so not even close to a kilo of weight.

 

[Andrew_D]

This one claims to have no minimum... https://activate.reclay.de/activate_germany_english/

 

[zefeena]

This one claims to have no minimum... https://activate.reclay.de/activate_germany_english/

Does it seem then that is all you complete? I presume if I send 10 packages my 'plastic bags' won't equate to more than 1kg, so it calculated to about £8. I pay the £8, then what?? do you get a licence number and put it somewhere? It does look like some more unnecessary hassle and paperwork (erm will I have to include any paper that I stick to my plastic mailing bag - postage sticker, customs sticker, invoice, as 'paper' and pay a licence for that too?)

 

[Andrew_D]

My understanding is that you need to have registered for a LUCID number and enter details of what you have paid for into your LUCID dashboard.

Not sure whether you ever need to quote your LUCID ID on shipping documentation?

 

[zefeena]

My understanding is that you need to have registered for a LUCID number and enter details of what you have paid for into your LUCID dashboard.

Not sure whether you ever need to quote your LUCID ID on shipping documentation?

Ah, okay. I wonder who's going round Germany collecting used packaging and making sure we all got it right! lol

 

[zefeena]

Well I've just read the info https://www.verpackungsregister.org...ic-paper_Information-for-retail-companies.pdf
and how threatening is that!
I had ever even heard of it until today.
Interesting, how I can be fined thousands for my couple of plastic bags, but the boxes that have arrived to me from Germany are not subject to their laws and my responsibility to dispose of!

 

[Andrew_D]

It is just the normal binmen collecting rubbish, nothing changes on the ground. This is just an exercise is shifting the costs from consumer to business.

As for enforcement, that will certainly get interesting!

 

[zefeena]

It is just the normal binmen collecting rubbish, nothing changes on the ground. This is just an exercise is shifting the costs from consumer to business.

As for enforcement, that will certainly get interesting!

The enforcement is probably like ever other official rubbish. they know only what you tell them, and the only people who will be penalised are those trying, but failing to navigate the ridiculous rules correctly. I won't be bothering. It simply not worth my time. Life is too short for international sales! lol