German Packaging Act Amendment: What you can do if your marketplace suspends your account
- What could be the reason for a suspension of my seller account?
- Here's what you need to do to get your account suspension lifted
Since July 1, 2022, marketplaces have suspended many seller accounts. What is the reason for this and how to prevent it, you can read in this article.
Retailers who put packaging on the market in Germany must take responsibility for the waste it generates. This is what the Packaging Act requires. To this end, retailers must contribute to the costs of recycling and disposal processes. The aim is to reduce waste, make recyclable materials usable again and in this way protect the environment. In the course of the first amendment to the German Packaging Act, a control obligation was imposed on marketplaces. Retailers who sell via marketplaces such as eBay or Amazon have had to provide their marketplace with evidence of proper compliance with the German Packaging Act requirements since July 1, 2022. If this evidence cannot be provided, marketplaces may no longer allow sales to Germany.
What could be the reason for a suspension of my seller account?
If it is already too late and you missed uploading your proofs before July 1, it may be that your marketplace has already blocked your seller account. Or maybe you uploaded proof and your account was still suspended? We take a look at what the reasons may be and what you can do to get unblocked:
1. No obligations fulfilled:
You have not yet fulfilled any obligations under the Packaging Act?
The obligations of the Packaging Act include, in addition to a registration in the register of the Central Packaging Register Office (LUCID), a system participation (also called licensing) of the individual packaging quantities with a dual system. Once you have fulfilled these obligations, you can deposit the LUCID registration number (also called EPR number by many marketplaces) and the proof of your dual system in your seller account. Once you have done this, your marketplace will re-enable sales to Germany for you.
2. No proof deposited:
You have fulfilled the obligations of the German Packaging Act, but have not yet deposited any proof?
Your marketplace can only verify that you have met all obligations if you have uploaded your personal LUCID registration number and proof of your dual system in your seller account. You will find the LUCID number in your LUCID dashboard after successful registration, the proof of system you will receive from your dual system (at Lizenzero you can easily get it via download in your customer account).
3. Not fulfilled all obligations:
You have not fulfilled all three obligations of the packaging law?
It is not enough to just register with LUCID. The elementary part is the system participation with a dual system (like Interseroh+ via Lizenzero). If you have also fulfilled this obligation, make sure that you also report your packaging quantities to LUCID at the end. You do this via "Data reporting" under the item "Intra-year quantity reporting" if your obligation is already for the current year, or under the item "Initial planned quantity reporting" if you do not have to license until next year.
4. Incorrect registration:
Did you not register as a "producer" in the LUCID registry?
If you did not register as a producer, your marketplace will not recognize the LUCID number. Make sure you have registered with LUCID as a manufacturer without fail and not, for example, as an inspector, third party agent or authorized representative.
5. The data does not match:
Have you used a different name/spelling or tax number?
The data reconciliation between the Central Packaging Register Office (LUCID) and your marketplace can only be carried out successfully if your data at LUCID and your marketplace match. Be sure to check all data provided for spelling and accuracy. The publicly viewable register with all data can be found here.
6. Wrongly blocked:
You do not distribute packaging in Germany and your account has been blocked anyway?
If you only sell digital products, for example, you have no obligations under the German Packaging Act. In this case, you must inform your marketplace that you are not affected by the requirements and ask for a suspension of the obligation to provide proof.
If you use dropshipping, you have no obligations according to the German Packaging Act, but you still have to provide your marketplace with a registration number. On the topic of dropshipping and evidence, also read this post in our help center.
Here's what you need to do to get your account suspension lifted
The first thing you need to do is make sure you have registered as a producer with the Central Packaging Register (ZSVR) in the LUCID register: Register Now. After successful registration you will receive your personal LUCID registration number (EPR number). You will receive this number by e-mail, but you can also view it at any time in your LUCID dashboard. You save this number in your seller account.
At Etsy: Open the "Shop Manager" go to "Finance", "Legal and Tax Information", "State Registration" and then "German LUCID number".
On Ebay: Open "My eBay" go to "Account settings" and then "LUCID number".
On Amazon: Log in to your seller account and enter "packaging licence EPR" in the search bar at the top right. Then click on the link "Information on complying with the legal guidelines for Extended Producer Responsibility (EPR)". Alternatively, click here to go directly to the desired page on Amazon.
If you still sell through other marketplaces, they will also inform you where to file the proofs.
Once you have completed the registration in LUCID, you have already fulfilled the first obligation. Next, you need to sign a license agreement with a dual system: Sign up with Lizenzero now. You will also give the LUCID registration number to your dual system. You will then receive a certificate of participation, which, in addition to the EPR number (LUCID number), serves as proof of compliance with the German Packaging Act obligations for your marketplace. How and whether you have to submit this proof to your marketplace varies. Pay close attention here to what evidence your marketplace requires from you.
Note: At Lizenzero, you can download your certificate of participation quickly and easily in your customer account.
You then enter your licensed packaging quantities and your selected dual system (Interseroh+, if you opt for Lizenzero) in your LUCID account. You do this via the "Data reporting" item under "Intra-year quantity reporting" in the dashboard. There you select the period 01.2022 - 12.2022 and enter Interseroh+ as your dual system if you license via Lizenzero.
If you have fulfilled all three obligations and deposited the LUCID number (and your system proof) in your seller account, you have fulfilled all obligations. If you are sure that you have fulfilled all requirements correctly and your marketplace has still blocked you from selling to Germany, please contact the marketplace support.