EPR for online sellers: Germany and France explained

Amazon asks for your EPR numbers in Germany and France. Its EPR page says it may deactivate listings it considers non-compliant, or comply on your behalf. In Germany the law makes the marketplace check you first.

What EPR is

EPR stands for extended producer responsibility. The European Commission puts it in one line: businesses placing packaged goods on the market must help cover the cost of collecting and recycling that packaging when it becomes waste.

Each country runs its own version. Amazon’s EPR page says the categories differ by country, and names the most common:

• packaging
• electrical and electronic equipment
• batteries

You register, pay into a national scheme, report what you sold and show your number when the marketplace asks.

The EU’s Packaging and Packaging Waste Regulation has applied since August 12, 2026, the Commission says. Germany’s packaging register now explains its rules for online sellers in terms of that regulation.

Germany: LUCID, electronics, batteries

Germany splits EPR between two registers: the LUCID Packaging Register for packaging, and stiftung ear for electrical goods and batteries.

EPR in Germany: what the official sources say

	What the official source says	Where you register
Packaging, shipped to Germany from abroad	If your company is outside Germany and you ship packaged goods directly to end users in Germany, you are the producer of the shipping packaging you use, boxes included. You must register in the LUCID Packaging Register and appoint an authorised representative.	LUCID Packaging Register (Zentrale Stelle Verpackungsregister)
Packaging, every other online seller	Packaging used to ship goods to end users in Germany must always be covered by a recycling scheme. Since August 12, 2026, an online seller has to work out whether it is the producer who must register in the LUCID Packaging Register and pay for that.	LUCID Packaging Register, if you are the producer
Electrical and electronic equipment	A company outside Germany that sells electrical or electronic equipment to end users in Germany counts as its producer under German law. A producer’s obligations start with registration at stiftung ear.	stiftung ear
Batteries	A company outside Germany that sells batteries, including ones built into appliances, at a distance directly to end users in Germany is their producer under EU law. It may sell them there only if it, or its authorised representative, is registered in Germany.	stiftung ear

Packaging. Shipping packaging means the box or bag plus the labels, adhesive tape and filler that go with it. Germany’s packaging register lists three steps for a producer: register in LUCID, sign a system participation agreement with a system operator before your goods first reach the German market, and report your packaging volumes. If your shipping packaging carries your name, logo or brand, you are its manufacturer and producer, wherever your packaging supplier is based. The register notes one narrow exception for micro-enterprises whose supplier is in the same country.

A producer not established in Germany must also appoint an authorised representative. The representative takes over your packaging obligations, except the LUCID registration.

Electrical goods. Registration at stiftung ear comes first among a producer’s obligations. A registration there is valid only in Germany. Producers also include brand owners selling in Germany and importers placing goods there for the first time.

Batteries. The batteries rule covers batteries built into appliances too. stiftung ear adds that a seller outside Germany who sells batteries at a distance directly to end users there has to mandate an authorised representative.

France: the unique identifier

France has 21 producer-responsibility schemes, called REP, the French government’s business portal says. Its list includes these:

• household packaging
• electrical and electronic equipment
• batteries
• furniture
• toys
• sports and leisure goods
• DIY and garden goods
• new clothing, shoes and household linen sold to consumers

Companies subject to a French producer-responsibility (REP) scheme, which can include sellers and importers, must be registered and hold a unique identifier for each scheme. Household packaging is one of them. The eco-organization you pay into registers you with the environment ministry, which issues the identifier (IDU). It goes in your terms of sale and on your website.

Whether a scheme covers your shop depends on what you sell and your role in the chain.

The portal says the environment minister can fine a company that is subject to REP and has no IDU up to €30,000. If you sell in France and you are not sure, ask before you list.

What a marketplace checks

Germany. Before an online platform lets you use its services, Germany’s packaging register says, it must obtain and verify two things: confirmation that you are registered in LUCID, and your self-certification that you meet your producer obligations. Without them, your packaged products may not be offered. A fulfillment service provider that is not the manufacturer of your shipping packaging has to run the same check. The LUCID register is public, so platforms can look up your status.

Amazon. Amazon’s EPR page asks for your 13-digit LUCID number to prove packaging compliance in Germany, and a stiftung ear registration for electrical goods. In France it asks for your unique identification numbers.

France. A marketplace can be spared REP for the goods it sells when a third party, such as the manufacturer, has already met the obligations for them. To use that, it keeps a register for the ministry with each seller’s details and the IDU behind each product.

Across the EU. The European Commission says platforms are not yet required to ask for an EPR registration number. Once the new harmonized national registers are in place, you will have to give the platform your national number before you use it.

What you report and when

Germany, packaging. You must also file each volume report you send your system operator in LUCID yourself, straight away. How often depends on your agreement, anywhere from monthly to yearly. Last year’s actual volumes are due in a year-end report by June 1. Under 10 tonnes of packaging in Germany last year, you may skip the in-year copies and file only the year-end report by June 1. LUCID charges nothing for registering or reporting. Your system operator charges for system participation.

France. Each year, before a date your eco-organization sets, you report what you put on the market the year before, for each category of each scheme. Some eco-organizations offer a flat-rate declaration for small quantities.

What changes next. The European Commission will set uniform EU rules for registration and reporting, and countries then have 18 months to adapt their national registers. The authorised representative requirement for packaging has applied in every EU country since August 2026. The Commission has proposed to suspend it for small businesses, and has asked countries not to sanction sellers while the proposal is examined.

The five-question checker shows which of these rules your answers trigger, and says so when your case needs a closer look.