Many Amazon sellers believe they are legally compliant in Germany – but they are not.
Many Amazon sellers believe they are legally compliant in Germany – but they are not.
Many international Amazon sellers believe they are already compliant in Germany.
They have an Amazon account.
They sell via FBA.
They may even have entered an EPR number somewhere.
And yet, it can still happen that Amazon suddenly demands proof, restricts listings, or deactivates products.
Why?
Because many sellers do not fully understand what is actually required in Germany.
Germany inspects more closely than many sellers expect
Germany has one of the stricter packaging systems in Europe.
Anyone who sells packaged goods to German end consumers must deal with the Packaging Act (Verpackungsgesetz) in many cases.
This includes not only large manufacturers, but also:
Amazon FBA Sellers
Online retailers
Private label sellers
International merchants
Sellers outside Germany
Sellers delivering products to Germany
The official registration is done via the LUCID packaging register.
Official source:
https://lucid.verpackungsregister.org
Information from the Central Agency Packaging Register (ZSVR):
https://www.verpackungsregister.org
Many sellers believe: "Amazon takes care of it"
This is one of the most common misconceptions.
Amazon provides the platform.
Amazon can request certain EPR data.
Amazon can alert sellers to missing proof.
But the responsibility for correct registration and compliance with packaging obligations lies, in many cases, with the merchant.
Amazon itself writes that for packaging in Germany, the LUCID number is relevant as proof.
Amazon EPR Information:
https://sellercentral.amazon.de/help/hub/reference/external/G6SQMSCSKWJQEPJQ
Why sellers run into trouble anyway
In practice, we see increasingly often that international sellers only react when a problem already becomes visible.
Typical situations:
Amazon suddenly requests an EPR number
A listing is removed
A product loses its selling permission
Sellers are given a deadline to submit proof
The seller does not know which registration is meant
The LUCID registration exists, but the packaging license is missing
The data in LUCID and with the dual system operator do not match
The problem is often not just "no registration."
The problem is frequently:
The seller has done something, but not completely or not correctly.
LUCID alone is often not enough
Many merchants think:
"I have a LUCID number, so I'm done."
That is dangerous.
For packaging subject to system participation, pure registration is often not sufficient.
In many cases, the merchant additionally needs:
Registration in the LUCID packaging register
A packaging license with a dual system
Data reporting to LUCID
Correct quantity declarations
Consistency between LUCID and the system operator
Submission of the correct number on Amazon
The Central Agency points out itself that data reporting is important and that details in LUCID and with the system operator must match.
Source:
https://www.verpackungsregister.org
Why this topic is so difficult, especially for international sellers
For German sellers, the Packaging Act is already complicated.
For international sellers, it is even harder because several layers come together:
German law
Amazon EPR requirements
LUCID registration
Dual system
Packaging volumes
Brand names
FBA structures
Language barriers
Incorrect information in forums
Many sellers search online for simple answers.
But reality is often more complex:
A seller from China, the UK, or the USA can still be affected if their goods are sold to German end customers.
What matters is not only where the company is based.
What matters is whether packaging is generated at the end consumer in Germany.
The LUCID register is growing rapidly
This topic has long ceased to be a niche issue.
The Central Agency Packaging Register reported in 2024 that the LUCID packaging register has surpassed the milestone of 1 million registrations.
This clearly shows:
Packaging compliance is no longer a small side issue in Germany, but a central element for retailers, manufacturers, and online sellers.
Amazon is getting better and better at detecting a lack of compliance
Another point is underestimated by many sellers:
Marketplaces are working increasingly with automation.
Amazon can compare data, trigger warnings, detect missing numbers, and automatically restrict listings.
AI-supported systems and automated compliance checks are also becoming increasingly important.
This means:
In the past, an error might have gone unnoticed for a long time.
Today, a missing or incorrect proof can be detected much faster.
For sellers, this means:
It is no longer enough to be "roughly compliant."
The data must be correct, complete, and verifiable.
Typical mistakes we see with Amazon sellers
Many problems arise from small misunderstandings.
For example:
1. The seller registers with LUCID but forgets the packaging license
LUCID is the registration.
The packaging license is done through a dual system.
Both are often confused.
2. The wrong company is registered
Sometimes a service provider, a brand, or an incorrect legal entity is entered.
This can cause problems later when Amazon or business partners check the data.
3. The brand is missing or misspelled
Brand names play an important role in the LUCID register.
If brand details are missing or do not match Amazon listings, this can lead to inquiries.
4. Quantities are not reported correctly
Many sellers underestimate packaging quantities.
Others only report shipping boxes but forget product packaging or filling material.
5. Sellers think FBA automatically means compliance
FBA does not automatically solve all packaging obligations.
Even if Amazon stores and ships the items, the seller may still be responsible for certain packaging.
Why "I only sell a small amount" is not a safe defense
Many small sellers believe:
"I only sell a few products, this doesn't affect me."
But the Packaging Act does not simply have a general exemption just because a seller is small.
Even small quantities can be relevant.
That is precisely why smaller sellers should check early on whether registration and licensing are necessary.
What can happen if sellers are not compliant?
Possible consequences can include:
Deactivation of listings
Sales stop in Germany
Request to submit evidence
Problems with Amazon Account Health
Legal risks
Fines
Sales bans
Official ZSVR documents indicate that violations of obligations under the Packaging Act can constitute administrative offenses and fines of up to 200,000 euros are possible.
Source:
https://www.verpackungsregister.org/fileadmin/files/Erklaermaterialien/Checklist_three-Steps.pdf
Why many sellers only react too late
The problem is psychologically understandable.
As long as Amazon does not send a warning, everything feels normal.
The products sell.
The account functions.
The listings are online.
Then suddenly a message arrives:
“EPR number required”
“Listing removed”
“Approval required”
“Action required”
And only then does the search for help begin.
But that is exactly when the pressure is highest.
Better to check in advance than rescue later
From our perspective, the most important advice is:
Do not wait until Amazon reports something.
It is better to check early:
Do I have a valid LUCID registration?
Is the correct company registered?
Are the correct brands registered?
Do I have a packaging license?
Does the data in LUCID match that of the dual system operator?
Is the correct EPR/LUCID number stored on Amazon?
Are packaging quantities realistically recorded?
An early check is usually much simpler than reacting later under time pressure.
More and more international sellers are seeking support
We notice that more and more international sellers are looking for support with German compliance issues.
Most frequently, they ask about:
LUCID registration
Packaging license
Amazon EPR requirements
German Packaging Act (Verpackungsgesetz)
Uncertainty regarding Amazon alerts
Questions about FBA and packaging obligations
Many sellers do not want to read long legal texts.
They just want to know:
What do I need to do so that my Amazon business in Germany is not unnecessarily put at risk?
Conclusion: Compliance is no longer just paperwork — it is part of the Amazon business
Many Amazon sellers believe they are compliant in Germany.
But often an important step is missing.
Perhaps LUCID is there, but the license is missing.
Perhaps the license is there, but the data report is not correct.
Perhaps everything is registered, but Amazon has not received the number correctly.
Perhaps the wrong company or brand is registered.
In a market where Amazon and authorities are increasingly relying on data, automation, and verification, a half-finished compliance status is no longer enough.
Anyone selling in Germany should not treat LUCID, packaging licensing, and EPR as a side issue.
Because a small mistake can be enough for a listing to suddenly become a problem.
Need help with LUCID, EPR or German Packaging Law?
We support international online sellers with:
LUCID registration
German packaging license
Amazon EPR requirements
Packaging Act compliance in Germany
More information:
https://www.packaging-compliance.de
Chinese page:
https://www.packaging-compliance.de/zh/