Table of contents

Germany's new packaging law requires that your LUCID registration be listed under your own business name. Printful's number no longer covers you.

This applies to every Printful merchant shipping to customers in Germany, regardless of your volume or where you're based.

What you actually need to do
Jump to the steps

Your deadlines

Germany already had a packaging register before PPWR, and which deadline applies to you depends on whether you were registered under your own name or using Printful’s LUCID ID.

Relying on Printful's LUCID ID, or never registered?
Register with LUCID by September 12, 2026.

Already registered under your own name?
Update that registration by November 12, 2026.

PPWR (Packaging and Packaging Waste Regulation) 

 

The EU-wide regulation No. 2025/40 went into effect on August 12, 2026. Its aim is more sustainable packaging, less waste, and a functioning circular economy, under a single set of rules for all EU countries.

 

EPR (Extended Producer Responsibility) 

 

Whoever puts packaging on the market pays for its collection and recycling. This principle predates PPWR, and most EU countries still run on their older EPR rules.

 

VerpackDG 

 

The German law implementing PPWR nationally also took effect on August 12, 2026. It sits alongside VerpackG, Germany's existing packaging act. 

 

LUCID 

 

Germany's Central Packaging Register, managed by the Central Agency Packaging Register, known as ZSVR. Your entry there is a declaration to the authorities that you're placing packaging on the German market. Recycling is handled separately, by a dual system.

 

Dual system 

 

One of a handful of licensed companies that collect and recycle packaging for a fee. For example, Der Grüne Punkt is the name most merchants recognize.

 

Authorized representative 

 

A German-based person or company you appoint to carry your packaging obligations if your business has no office or branch in Germany. See more in the step-by-step guide below.

 

Producer

 

The party that puts a product into the market of an EU member state, such as Germany – that’s you. The producer is responsible for registration and reporting. Some producer duties may be handled by Printful instead, depending on national law. See more in the Producer or manufacturer section below.

 

Manufacturer 

 

Whoever makes the packaging or has it made. On the current EU guidance, that's Printful, and the conformity paperwork comes with it. See more in the Producer or manufacturer section below.

What you need to do

a flowchart of a flowchart

Step 1: Appoint an authorized representative in Germany

If your business is located outside Germany and has no branch there, you need to appoint a German-based authorized representative. Start here, because you will be asked for their details when you register for LUCID ID.

For as long as your contract with them runs, they'll handle:

  • Signing a system participation agreement with one or more dual systems

  • Reporting your packaging volumes

  • Submitting declarations of completeness

  • Meeting the packaging return obligations under section 39 of VerpackDG

  • Taking part in the national deposit scheme, where deposit-bearing single-use beverage packaging is involved

The LUCID registration itself is the one duty they can't take on. You must do that yourself.

Step 2: Register for LUCID under your own business name

Go to verpackungsregister.org and register as a producer. That's the only official register.

What the form asks for:

  • Your login. The activation email expires after 24 hours. Check your spam folder.

  • Master data. Company address, phone number, VAT number or national taxpayer reference, and national identification number.

  • A packaging category. For orders Printful fulfills, pick packaging subject to system participation. If you ship anything yourself or use another provider, it's worth checking whether that packaging belongs in the other category.

  • Every brand name on your packaging. A store name that differs from your company name counts as a brand. Several stores mean several entries.

  • A declaration that you're meeting the system participation requirement, which is step 3.

Step 3: Sign an agreement with a dual system provider

Your LUCID entry is just a declaration. It doesn't collect or recycle a single parcel, and it doesn't pay for anyone else to do so.

That's the job of a dual system: a licensed company that handles collection and recycling for you, charging by how much packaging you put into the market and what it's made from.

Der Grüne Punkt is one of the best-known providers in Germany. The full list of approved providers is on the ZSVR site.

Depending on the terms of your agreement with your authorized representative, they may register with a dual system provider and report your packaging details to them on your behalf. Clarify this when choosing a representative to avoid doing double work or skipping vital steps.

Stopping after Step 2 is the most common mistake. A registration on its own isn't compliance.

Step 4: Report your packaging volumes

Your dual system provider will ask you to report how much packaging you've put on the German market and what it's made of. If you used Printful’s LUCID number before, you need to declare the packaging starting from August 12th, as this is when the obligation shifted from Printful to you. The dual system provider will then invoice based on those quantities reported.

For Printful-fulfilled orders, we will prepare the technical packaging information you need for these reports. We’ll update you as soon as it’s available.

Step 5: Submit your LUCID number to every sales channel

This last step is manual. You need to add your EPR number to each sales channel.

  • Etsy: Dashboard → Finances → Legal and tax information → Government registrations → Add LUCID ID → Submit

  • Amazon: Switch to the Amazon.de marketplace in Seller Central, follow the banner asking for your LUCID number, then submit it under the Germany section of the Compliance Portal. Validation takes up to five business days, and your listings can stay blocked until it’s complete.

  • eBay: My eBay →  Account → Business Information → Business details → select Add, next to LUCID ID → Save. Business accounts only, so switch from Individual first if you need to.

  • TikTok Shop: Seller Center → My Account → Qualification Center → Extended Producer Responsibility (EPR) → enter your LUCID ID

  • Anywhere else: Contact that platform's support team.

Platforms may revise these requirements, so it's worth confirming the current process every so often.

Rejected submission? Check the number for stray spaces, and ensure that your business name and VAT details match your LUCID entry. TikTok Shop also requires that the number match your legal entity name.

What's changing

Germany moved first

PPWR, formally known as Regulation 2025/40, has applied across the EU since August 12, 2026. It brings one set of packaging rules to all member states, aimed at cutting waste and making packaging more sustainable and recyclable.

Germany has incorporated the PPWR into national law via the VerpackDG. Elsewhere in the EU, the older EPR rules still apply until PPWR-specific amendments are implemented. We’ll keep you updated as the legal landscape changes.

You must now register for LUCID yourself

Until August 12, 2026, merchants fulfilling all their German orders through Printful could provide Printful's LUCID ID to their marketplace instead of registering themselves.

Unfortunately, that’s not the case anymore. Now, each business must register with LUCID in its own name, even if all of its German orders are fulfilled through Printful.

Your customers’ location matters here, not yours

Sales destinations set your EPR obligations, not your business address. For example, a US seller with no EU legal entity still counts as a producer under the PPWR. Ship to Germany, and these rules all apply to you, even if EPR has never come up for you before.

Producer or manufacturer: Which one are you?

Producer: That's you

Whoever invoices the end customer is the producer, and for orders going to German customers, that's you. 

VerpackDG lists five requirements for producers:

  1. Having an authorized representative in Germany if you are not located there.

  2. Registering with LUCID in your own name

  3. Contracting for a dual system provider for collection and recycling

  4. Reporting packaging weight by material

  5. Paying the associated fees

How much of that must be done by you depends on national law. We're working through which producer duties Printful can take over for you, country by country, and will share more as the picture becomes clearer.

Manufacturer: That's us

Whoever makes the packaging, or has it designed and made, is the manufacturer. That role owns packaging conformity, which means the technical documentation and the EU Declaration of Conformity. On the European Commission's guidance as of July 21, 2026, Printful is considered the manufacturer.

Asked for packaging documentation by a marketplace or an authority? Email [email protected] and we'll provide it.

What happens if you don't comply

Marketplaces are acting on this independently of us. If a seller does not have a valid EPR number, platforms are legally required to restrict their sales.

This can lead to:

  • Removed product listings

  • Blocked shipping to Germany

  • A suspended account

German authorities can impose fines of up to €100,000 for failing to register, and up to €200,000 for other offences under section 66 of the VerpackDG.

None of this happens if you register and follow the steps described above. Follow the steps above, and you're covered.

What you need to do
Jump to the steps

More resources

Official German sources

Notice something that's not covered here, but should be? Email [email protected].

FAQ

Yes. From August 12, 2026, the registration is personal to your business and must be filed under your own name. It doesn’t matter who fulfills the orders.

Yes, you must register even if you only receive a single German order per year.

Yes, absolutely. The country your customers live in is what determines whether these rules apply to you, not the country you are based in. A US seller without an EU legal entity is still considered a producer under the PPWR.

Not quite. The register knows about your packaging, but nothing has been arranged for its collection or recycling. For that, you need a system participation agreement with a dual system provider. They will handle collection and recycling on your behalf for a fee.

You have until November 12, 2026, to update that registration if there have been any changes.

The conformity paperwork, since the manufacturer role falls to us on the European Commission's guidance as of July 31, 2026. The technical documentation and EU Declaration of Conformity are ours to issue. We are also responsible for the packaging information you'll need for reporting on orders we fulfill. Beyond that, we're working out which producer duties we can take on instead of you, country by country.

No. LUCID registration must be completed by you in your own business name. We may be able to handle other producer duties for you, depending on national law. We will keep you updated on what those are as more info becomes available.

Laws related to EPR are continuously developing, and while we will do our best to share these updates with you in a timely manner, you should actively be monitoring for any changes to their requirements.

Your registration follows your business, not your providers, so a single registration covers all your packaging, and adding or switching providers doesn't require re-registration. Just make sure that what you report includes your packaging for all orders, not just those fulfilled by Printful.

Amazon validates it first, which can take up to five business days, and listings may remain blocked in the meantime. If it comes back invalid, check for stray spaces in the number and confirm your seller account's business name and VAT details match LUCID exactly.

Only business accounts accept one. Switch yours over from individual, and the LUCID ID field will appear.

Any brand name visible on your packaging. If your store name and company name differ, the store name is also considered a brand. Multiple stores, multiple entries.

In 2030, more regulations on packaging composition and limits on empty space in boxes will go into effect. Printful's packaging already meets those requirements, and we're continuing to improve it.

That's your call to make. Registration incurs ongoing dual system provider fees, and with no volume threshold, even a single German order puts you on the hook for all these requirements. Review your order history from Germany to determine if continuing to sell there is the best move for your business.

That's your call to make. Registration brings ongoing dual system provider fees, and with no volume threshold, even one German order puts you on the hook for all these requirements. Review your order history from Germany to determine if continuing to sell there is the best move for your business.

This information is for guidance only and shouldn't be considered legal advice. EPR requirements differ between jurisdictions and continue to evolve. Consult your legal counsel with questions about the laws and regulations that apply to your business.

Printful Team

By Printful Team

Printful is an on-demand printing and fulfillment service that helps businesses create and ship custom products.