Germany’s EPR Packaging Requirements

Extended Producer Responsibility (EPR) regulations are designed to reduce waste and encourage recycling. Starting July 1, 2022, Germany’s revised EPR Packaging Law will affect both AbeBooks and its sellers.

We encourage you to become familiar with these EPR regulations.

Who is a producer?

Producers are not just manufacturers. Germany requires producers to mitigate the environmental impact of their products and packaging. A producer is anyone who first introduces a product to the market on a commercial basis. Anyone who ships products in packaging to customers located in Germany is considered a producer.

These regulations require all producers to register with the LUCID Packaging Register and enter into an agreement with a Producer Responsibility Organization (PRO). In Germany, PROs are also referred to as Dual Systems.

The LUCID Packaging Register is run by the Zentrale Stelle Verpackungsregister (ZSVR) which implements German packaging laws.

If you need assistance with EPR, there is a list of authorized third-party companies offering support services.

You can also refer to the following resources:

LUCID Registration Numbers required

To comply with the regulations, AbeBooks is required to collect German EPR registration numbers (also known as LUCID Registration Numbers) from sellers.

You will need to provide your LUCID Registration Number before June 27, 2022. In order to comply with the EPR legal requirement that comes into effect on July 01, 2022, we will prevent customers in Germany from purchasing your items starting June 28, 2022. Please note that this will not impact your sales into other countries.

If you register with LUCID and provide AbeBooks with your LUCID registration number at a later date, you will be able to sell to customers in Germany again.

You can obtain a LUCID Registration Number from LUCID (the website is available in German and English). LUCID registration is free.

The LUCID registration number starts with “DE” followed by 13 digits.
Example: DE1234567891011.

In addition, you need to determine whether your packaging is subject to system participation. If it is, you must select a PRO to whom you pay eco-fees for the collection and recycling of your packaging after use. You will need to make regular declarations to LUCID and the PRO you registered with about the packaging and/or products you ship to customers in Germany.

Registration and system participation

For an overview of Germany’s EPR responsibilities, refer to this summary for online retailers. For more information about registration and system participation, refer to this checklist.

German EPR requires the following steps:

Step 1: Register with LUCID

After registration, you will need to provide your LUCID Registration Number to AbeBooks.

Step 2: Enter into a system participation agreement

You will then need to enter into an agreement with a PRO and provide them with your LUCID Registration Number. Refer to this list of PRO partners.

Step 3: Report packaging volumes

You will need to submit reports and pay eco-fees to your PRO on a regular basis. You will also need to submit the same reports to LUCID via the LUCID website. For more information, refer to this summary of reporting requirements.

Frequently Asked Questions

How do I know if my packaging is subject to system participation?

Shipping packaging is subject to system participation. Refer to this guide for detailed information.

How much are PRO eco-fees for handling shipping packaging?

Typically, a fraction of a Eurocent per package. Contact PROs for price lists.

What does AbeBooks do with my LUCID number?

AbeBooks will validate your number with ZSVR. We will notify you if there is a problem. Please make sure that the information submitted to LUCID, including your VAT ID/Tax ID, business name and address matches the information on file with AbeBooks.

Can I appoint an authorized representative to handle my EPR obligations?

If you need assistance with EPR, there is a list of authorized third-party companies offering support services.

If you are based in Germany, you can appoint an authorized representative to fulfill some obligations on your behalf. However, authorized representatives cannot complete your initial LUCID registration and cannot submit data reports on your behalf.

Only international companies without a branch in Germany can appoint an “authorized representative” to fulfil packaging law regulations for them.

With the exception of registering in the LUCID Packaging Register, the authorized representative assumes responsibility for all of your obligations under the German packaging law and fulfills them in their own name.

The one-time registration requirement in LUCID is a personal obligation that rests with you, the original party under obligation. For more information, visit ZSVR.

How do I determine the total order value of sales to a specific country?

  1. Sign in to your seller account.
  2. Go to the My Payments section of the Members Menu and click Statements & Reporting.
  3. Go to the Downloads tab.
  4. Select the Custom Date Range option and enter the Start Date and End Date.
  5. Click Download. The report is provided in .CSV file format and you can open it using Microsoft Excel.
  6. Filter your sales by Order Country (Column H). The Order Country Column of the report allows you to filter sales by buyer country. The Order Country is indicated in 3 letter ISO country codes. Use FRA for France and DEU for Germany.
  7. Add the values in Column N (total price) to calculate the total value of your sales for that country.