PPWR and online selling: authorised representative in Germany, LUCID, BDO and EPR numbers on marketplaces

We run seller accounts on Amazon, Kaufland and Allegro, so questions about the PPWR come up regularly, usually when a marketplace asks for a number the business does not have. That is why this guide brings together in one place what the German Central Agency Packaging Register (ZSVR), the European Commission, the Polish BDO register and the platforms themselves say, as of 2 November 2026, with links to the sources. Registrations and ongoing EPR compliance for businesses are handled by the EPRzone team, which belongs to the same group as Raise Your Sales, and its procedures were the starting point for this article.

What is the PPWR and what applies from 12 August 2026

The PPWR is Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste. It entered into force on 11 February 2025 and has applied since 12 August 2026. It replaced the 1994 Packaging Directive and, as a regulation, it is directly applicable in all Member States, although each country is aligning its own legislation and registers with it. In Germany, the PPWR, together with the new VerpackDG, has replaced the previous Packaging Act (Verpackungsgesetz). The core obligations, namely registration, system participation and data reports, remain in place, but the rules on who has to meet them, and on what terms, have changed.

Not everything took effect on the same day. Some requirements, for example those on packaging recyclability, recycled content and labelling, are being phased in over the coming years, as Kaufland, among others, points out in its guide for sellers. For a business selling online, however, the most urgent obligations today are those relating to registration, because they decide whether a marketplace will accept your listings at all.

Does the PPWR apply to your business?

The PPWR separates two roles which, in an ordinary shop, often belong to the same business but can be split between different businesses once you sell abroad. The manufacturer is responsible for ensuring that the packaging meets the requirements, which covers the technical documentation and the declaration of conformity. The producer bears extended producer responsibility (EPR) in the country where the packaging becomes waste, so it registers there, finances recycling and reports volumes. According to Germany’s packaging register, the ZSVR, the producer in a given country is the first business in the domestic supply chain, and a foreign business is the producer only if it ships goods from abroad directly to the end user, whether private or commercial.

Your shipping parcel counts as packaging too

The PPWR treats the packaging you ship an order in as e-commerce packaging, which is a type of transport packaging. This covers the cardboard box and the mailing envelope, but also labels, tape and fillers such as plastic film, paper or packing peanuts. The ZSVR stresses that shipping packaging is always subject to system participation, without exception, because it becomes waste as soon as the customer unpacks it. If you put a parcel together yourself from a box, tape and filler, you are both its manufacturer and its producer, which means you pay for its recycling.

A brand on the packaging makes you the producer

The key rule here is the brand principle. If you order packaging or packaged products bearing your own name, logo or brand, then according to the ZSVR you are their manufacturer and producer, regardless of where the company that made them for you is based. This holds even if the supplier’s name is printed on them as well. There is a narrow exception for micro-enterprises, meaning businesses with fewer than ten employees and a turnover of up to €2 million: where the supplier of ready-made shipping packaging is based in the same country as the micro-enterprise, the manufacturer and producer obligations pass to that supplier.

Authorised representative in Germany: who needs one and by when

Since 12 August 2026, a business based abroad that has no branch in Germany and sells empty packaging or packaged products directly to end users in Germany, without an intermediary seller, has had to appoint an authorised representative for extended producer responsibility there. Previously, this was voluntary. The representative has to be appointed and entered in LUCID before the goods are placed on the German market for the first time, and a new LUCID registration cannot be completed without their details. Businesses registered before 12 August see a message about the missing authorisation when they log in. The German VerpackDG requires changes to registration data to be reported, including those concerning the authorised representative (Section 6(1)), and allows businesses registered before 12 August until 12 November 2026 to make such changes (Section 68(2)).

Three typical scenarios for a seller based in another country

If you sell on Amazon.de using FBM or through your own online shop and ship parcels from another country, for example from Poland, straight to customers in Germany, you meet the conditions described by the ZSVR, so you need a LUCID registration, a contract with a dual system and an authorised representative. The same applies when you sell on Kaufland.de or Otto and ship from outside Germany, because the marketplace acts here as a technical intermediary and, as far as the customer is concerned, you remain the seller. Stock held in an Amazon warehouse in Germany (FBA) is less clear-cut, because the parcel then travels to the customer from within Germany, and the rule on shipping from abroad described above does not settle this case on its own. What usually settles it is the brand principle: if you sell products under your own brand, you are the producer of their packaging regardless of where the parcel ships from, and since you sell to customers yourself, without a German intermediary, you also need an authorised representative. The ZSVR does not explicitly address goods without your brand stored in an FBA warehouse, so it is worth confirming such a case with an adviser or directly with the ZSVR. By contrast, a business that sells its goods exclusively to a German wholesaler or retailer has no obligation to appoint a representative, because that intermediary then becomes the producer in Germany.

What the representative does and what stays with you

The authorised representative takes over almost all of the producer’s obligations in its own name: it concludes the system participation contract (in Germany, with what is known as a dual system, or “duales System”), submits the data reports on packaging volumes and the declarations of completeness to LUCID, and fulfils the take-back obligations. The only exception is the LUCID registration itself, which the ZSVR describes as a personal obligation of the producer, so you register and change the details of your entry yourself, even once the representative is already acting for you.

How to choose an authorised representative

The representative can be a person or a company with its registered office or a branch in Germany that is not affiliated with your business and has a separate authorised representative account in LUCID with its own ID. You can have only one authorised representative for packaging, and the contract must be in writing, in German (the German version is the binding one), and signed by both parties either by hand or with a qualified electronic signature. The ZSVR does not publish a list of representatives, and their fees depend on each provider’s price list, so you have to choose a partner yourself. At EPRzone, we find such a partner in Germany for our clients and enter the representative in the client’s LUCID account.

European Commission proposal: suspending the obligation for small businesses

The authorised representative obligation is not limited to Germany. The European Commission states that the obligation has applied in all Member States since August 2026, but in December 2025 the Commission proposed suspending it for small businesses that sell directly to consumers in other EU countries. Until the European Parliament and the Council have considered this proposal, the Commission is asking Member States to ensure “constructive and pragmatic” enforcement of the obligation and to refrain from penalising businesses. This is only an appeal, however, and it does not change German law, so the ZSVR still requires an authorised representative at registration, and the platforms keep asking for a LUCID number.

Germany step by step: LUCID, system participation, data reports and your number on the platform

In Germany, the route to selling packaged goods legally consists of five steps, which you need to complete before the first parcel reaches a customer:

1. Registering your business and brands in the LUCID Packaging Register. It is free of charge and you complete it yourself. We cover the details in our guide to registering with LUCID step by step.
2. Appointing an authorised representative and entering them in LUCID, if you have no branch in Germany.
3. Concluding a contract with a dual system, which finances the recycling of your packaging, before your first sale.
4. Submitting data reports on packaging volumes to LUCID and to the dual system, broken down by weight and type of material.
5. Entering your LUCID number (DE followed by 13 digits) in the seller accounts of the marketplaces you sell on.

Skipping these steps can lead to heavy fines. Under Section 66 VerpackDG, failing to register, or registering incorrectly or late, can cost up to €100,000, and failing to take part in a dual system up to €200,000. We cover the cost side of the expansion as a whole in our article on selling to Germany.

What marketplaces check: Amazon, Kaufland and Allegro

German law also places obligations on the platforms. According to the ZSVR, before a marketplace allows a seller onto the platform, it must obtain and verify proof of the seller’s LUCID registration and the seller’s declaration that it complies with its EPR obligations, and without this evidence packaged products may not be offered. The same applies to fulfilment service providers that are not the manufacturers of the shipping packaging: if the information is incomplete, they must ask the seller to supply what is missing and, if the seller fails to do so, stop providing services to that seller.

On Amazon, you enter your LUCID number, which Amazon describes as a 13-digit registration number, in the “Compliance Information for Extended Producer Responsibility” portal, as described on Amazon’s page on extended producer responsibility. In its PPWR guide, Kaufland gives the LUCID number, in the format DE followed by thirteen characters, as the identifier for Germany and reminds sellers that those with no registered office in a given country must appoint an authorised representative there. On Amazon, listings without an approved number stop being displayed in the country concerned, and once the number has been approved, they usually have to be reinstated manually.

In its help centre for sellers, Allegro states that a missing EPR number does not block sales today, because EU countries are still adapting their registers. Once they have done so, Allegro will start checking the EPR number for every country you ship goods to before allowing you to sell there, which follows from the Digital Services Act (DSA). In Sales Center, you already enter a separate number for each shipping country on the “Account Details” tab, in the “PPWR number (EPR PPWR / BDO)” field, and tick the declaration of conformity of packaging with EU requirements. If you sell through Allegro to the Czech Republic, for example, and have no registered office there, or if your business is based outside the EU, you also provide the EPR numbers of your authorised representatives in those countries. This is consistent with what the European Commission says: at EU level, platforms do not yet have to require an EPR number, but they will have to once new, harmonised national registers are in place.

Poland: BDO for businesses that place packaging on the Polish market

This section describes Polish rules, which mainly concern businesses based in Poland and businesses that place packaged products on the Polish market. In Poland, the producer register is BDO, the Database on Products and Packaging and on Waste Management. Registration is mandatory for, among others, businesses that place packaged products on the market, producers and importers of packaging, and businesses that buy packaging in other EU countries, and in some cases also for sole traders. The easiest way to check whether your business needs to register is the questionnaire on the BDO website.

According to the BDO registration rules, the registration fee is 200 zł for a micro-entrepreneur and 800 zł for other businesses, and in subsequent years the same amount is payable as an annual fee by the end of February. Operating without the required registration and, separately, failing to show the registration number on documents can each result in an administrative fine of up to 1,000,000 zł. You also enter your BDO number on Allegro, in the same field as the numbers from other countries, and the EPRzone team can prepare the registration itself and the annual reports for you.

Other EU countries: a separate number for each market

The PPWR harmonises the rules, but it does not create a single European register. A registration in Germany is therefore not enough to sell in France or the Czech Republic, because each country has its own register, and numbers are issued separately for packaging, electronics and batteries. If you ship parcels to several countries, you need a registration, and usually an authorised representative, in each of them, and the marketplace will ask for a number for each market separately. Countries also differ in their thresholds, fees and number formats, so before entering another market it is worth checking its rules, for example the EPR rules in the Czech Republic if you sell there through allegro.cz, among other channels.

Other PPWR changes that will affect e-commerce

Beyond registration, the PPWR also changes the packaging itself. According to the European Commission, by 2030 all packaging on the EU market must be recyclable in an economically viable way, the share of recycled content in plastic packaging is set to rise, and in food-contact packaging the regulation restricts PFAS above certain thresholds. These PPWR requirements mainly concern packaging producers and suppliers, but sellers have a part to play as well. The manufacturer is responsible for the technical documentation and the declaration of conformity, and the packaging supplier must provide it with all the data this requires, an obligation the ZSVR derives from Article 16 of the PPWR. One of the regulation’s aims is to keep packaging to a minimum, including empty space in shipping parcels, and the requirements on recyclability, recycled content and labelling are being phased in over the coming years. So rather than waiting for the final deadlines, it is worth reviewing your packaging and your suppliers’ data now, for example as part of a PPWR audit, and following packing guidelines such as the Allegro Packaging Standard.

Checklist before selling to Germany

Before you send your first parcel to a customer in Germany or ship stock to an FBA warehouse, check these points:

1. You know whether you are a packaging producer: whether your brand is on the packaging and whether you pack the parcels yourself.
2. You are registered in LUCID with all the brands you sell under.
3. If you sell directly to customers in Germany and have no branch there, you have an authorised representative based in Germany, a written contract in German and the representative’s confirmation in LUCID.
4. If you registered before 12 August 2026, you add your authorised representative by 12 November 2026.
5. You have a contract with a dual system, concluded before your first sale.
6. You know the weights and materials of your packaging, including shipping packaging, because you cannot submit your reports without them.
7. Your LUCID number is entered on Amazon, Kaufland and Allegro if you ship to Germany through them.
8. You have a BDO number if you place packaged goods on the market in Poland.
9. You know which other EU countries you sell in and what registers they have.
10. You have the documentation from your packaging suppliers that you need for the declaration of conformity.

How to handle this when launching on Amazon.de or Kaufland.de

The most common mistake we see when businesses enter the German market is launching listings before the paperwork is sorted, followed by downtime when the marketplace suspends sales until the numbers are provided. That is why, when we plan a launch on Amazon in Germany, we start with a list of legal obligations, meaning EPR for packaging and, for electronics, also WEEE and batteries, plus GPSR and VAT, and only then move on to listings and advertising. If you would like to draw up such a plan for your business, book a consultation before launching on Amazon.de, and if you are entering several markets at once, we can help as part of an international expansion plan.

Frequently asked questions

When does the PPWR apply?

Regulation (EU) 2025/40 entered into force on 11 February 2025 and has applied since 12 August 2026. Some requirements, for example those on packaging recyclability and labelling, are being phased in over the coming years.

Does a business from another country selling to Germany need an authorised representative?

Yes, if the business has no branch in Germany and sells packaged products directly to end users in Germany, for example through Amazon.de, Kaufland.de or its own online shop, with goods shipped from outside Germany. Businesses registered in LUCID before 12 August 2026 must add an authorised representative by 12 November 2026. For goods that do not carry the seller’s own brand and are stored in an FBA warehouse in Germany, the ZSVR does not settle the question explicitly, so it is worth getting such a case confirmed.

Will the authorised representative register me in LUCID?

No. Registration in LUCID and changes to the registration details are a personal obligation of the producer, while the authorised representative takes over the other obligations, such as the contract with a dual system and the data reports on packaging volumes.

Can I sell on Amazon.de without a LUCID number?

No. Amazon requires a LUCID number in its EPR compliance portal, and German law obliges platforms to verify registration before admitting a seller, so listings without a number cannot be displayed in Germany.

Does Allegro require an EPR number?

Allegro already collects EPR numbers in Sales Center, separately for each shipping country, but for now a missing number does not block sales. Allegro will start verifying the numbers before allowing sales once EU countries have adapted their registers.

Does an online shop need to be registered in the Polish BDO?

BDO registration is mandatory for, among others, businesses that place packaged products on the Polish market, including importers of such products, as well as producers and importers of packaging. The easiest way to check is the questionnaire on the BDO website.

Is one registration enough for the whole EU?

No. Each country has its own register, so an EPR number has to be obtained separately for each market and separately for packaging, electronics and batteries.

Summary

The PPWR has not changed the principle that packaging is paid for by the business that places it on the market, but it has clarified which business that is and has made an authorised representative a condition for mail-order sales directly to customers in another country. For a business that ships orders to customers in several EU countries, this means three things today: a registration and an authorised representative in every country it ships parcels to directly, a registration in the country where it places packaging on the market itself (in Poland, that is BDO), and EPR numbers entered on every marketplace it sells on. The next deadline is 12 November 2026, by which date businesses already registered in Germany must add an authorised representative.

If you are not sure which of these obligations apply to your business, or a marketplace has just asked you for a number you do not have, book a free consultation call. We will review your sales channels and the countries you sell to, and the EPRzone team will prepare the registrations for you, so that your sales are not halted by a missing number.