The German Packaging Act has been in force since 2019. It requires manufacturers and (online) sellers to purchase a paid licence for their sales packaging – i.e. all packaging that ultimately ends up with German private consumers – from a dual system and therefore comply with their Extended Producer Responsibility (EPR). In addition, registration with the Central Agency Packaging Register Authority (ZSVR) is mandatory. You will receive your LUCID number (EPR number) after registering with LUCID.

As of July 2022, eBay as a marketplace operator is obliged to check the compliance of its merchants with these requirements.

Important: These above-mentioned requirements apply from the first packaging put into circulation and for all materials.

Do you ship to German costumers? Then you need to do the following if you are not yet legally compliant:


German Packaging Act: Your To Do's


Start by licensing your packaging with a dual system provider, e.g. Interzero Recycling Alliance via Lizenzero (and claim your 10% discount!) –
go here to enter your packaging volumes

✔ You’ll receive your system participation certificate to pass on to eBay

Registration the LUCID Packaging Register run by the Central Agency Packaging Register.

✔ You’ll receive your LUCID registration number (EPR number) from LUCID to add to your eBay-Seller-Account.

Data reporting

Enter the volumes you licensed and your dual system into the LUCID Packaging Register.

✔ You're done!

Packaging law, EPR, licensing & registration
The most important questions at a glance

What does EPR mean?

EPR stands for "Extended Producer Responsibility". The underlying principle makes merchants and manufacturers responsible for the entire life cycle of their products and related components, including their disposal, in the service of environmental protection.

In Germany, packaging, electrical appliances and batteries are covered by the Extended Producer Responsibility of those who put them into circulation in this country.

The current high level of attention on the EPR is essentially due to the amendment of two laws: the Packaging Act (VerpackG) and the Electrical and Electronic Equipment Act (ElektroG). In the future, both will oblige marketplaces to check the compliance of their dealers with regard to the requirements. In this context, marketplace operators speak of EPR as a collective term for all three aspects.

The marketplaces' obligation to monitor compliance with the Packaging Act is into effect since July 2022. The control obligation for electrical appliances followed in January 2023.

Which obligations do I have to fulfill according to the Packaging Law?

The Packaging Act imposes three obligations on sellers who ship packaged products to German end consumers:

  1. Licensing of your annual packaging volumes with a dual system (also called system participation). For this purpose, you can use Lizenzero, the online shop of the acknowledged dual system Interzero Recycling Alliance and preferred partner of eBay: Enter volumes now
  2. Registration in the packaging register LUCID
  3. Data reporting to the packaging register LUCID (name of the dual system and licensed packaging volumes)
Why do I have to prove to eBay that I fulfill my obligations with the German Packaging Act?

The Packaging Act was amended in July 2021. One of the changes in the law affects the operators of marketplaces such as eBay: In order to create an additional control mechanism, they will have to check from July 2022 whether all traders who ship to Germany comply with the requirements of the Packaging Act.

If the merchant is unable to provide proof of compliance, a sales ban will take effect and the marketplace operators will have to restrict sales to Germany. Violations of this will be punished with high fines for the marketplaces.

What proof do I need to provide to eBay?

You need to present two proofs to eBay:

  1. LUCID registration number (sometimes also called EPR number): You will receive this number after successful registration in the LUCID packaging register.
  2. Licensing/System Participation Certificate: You can download the Lizenzero-Participation-Certificate in your customer account after you have concluded your license agreement.
What is the difference between "license" and "register"?

The Packaging Act formulates a total of three obligations for merchants of packaging in Germany (also see question #1). These include the licensing obligation (also known as the system participation obligation) and the registration obligation.

Both obligations must be fulfilled at two different contact points:

  1. The licensing obligation refers to the fee-based participation of your packaging and must be carried out by you at a dual system such as Interzero Recycling Alliance (via Lizenzero). In return, Interzero Recycling Alliance takes over the disposal and recycling process of your packaging for you.
  2. The registration obligation, on the other hand, is carried out by you at the control authority Zentrale Stelle Verpackungsregister (LUCID).

The catalog of obligations is completed by the data reporting obligation: This simply means that you enter the name of your dual system and your licensed packaging volumes in LUCID.

What applies to fulfilment and dropshipping?

Since the amendment, there is an obligation to monitor and new responsibilities for fulfilment service providers. If commissioning traders cannot provide evidence of system participation, they are not permitted to neither sales nor other activities (offering products, packaging, shipping, etc.) may be provided. In addition, the commissioning trader is responsible for licensing without exception, and in no case the fulfilment service provider.

The special feature of dropshipping is that the goods are packed directly by the sender and shipped to the end customer. Traders themselves therefore have no physical contact with the product or the packaging. The sender of the goods is therefore obliged in terms of the Packaging Act - both for the primary sales packaging and for the shipping packaging.

Attention: In the course of the amendment to the Packaging Act, online traders who use marketplaces must be able to present proof of licensing from 1 July 2022. This means that traders who use dropshipping and do not have a licensing obligation themselves also need to take action! You must request the registration number (EPR number) from your sender. When depositing the EPR number with the marketplace, you must take care not to pass it off as your own, but make it clear that it is the number of a third party.

What our customers say about working with Lizenzero

Moritz Bauer- Managing Director
minjo Coffee

As a young start-up, the topic of packaging licensing was new to us. We compared different providers and ended up with Lizenzero. For us, Lizenzero simply made the most likeable and best impression. We liked the website and the design and the price-performance ratio was also right. The calculator was also very cool, it was all set up simply and went super easy. It just fit.

Viola Kukclinski-Hagewiesche - Owner

Lizenzero made the issue of packaging licensing totally easy for me. I clicked through the site, click click, and the licensing was done. This made this part super easy for me during the difficult time of founding a company. That was the decisive point why I chose Lizenzero.

Philipp Rodemann - Managing Director

Everything was just right for us with Lizenzero: From the price-performance ratio to the positive customer reviews to the easy handling through the calculator.

Cathrin Tach - Managing Director

We are a small company, so we can't make a doctoral thesis out of the Packaging Act. With Lizenzero we have landed a stroke of luck - manageable and the licensing does not require more time than absolutely necessary.

Anja Rausch - Business Development Manager
Pick-a-Pea Bio Food

What we like about Lizenzero, apart from the appealing structure of the website, is the simple handling of registering packages. It saves us a lot of time and is cost-efficient. The fact that we have found a partner from the region in Lizenzero makes us even happier!

Christian Koch - Owner

As florists, we surround ourselves with beautiful things every day - the appealing presentation of Lizenzero corresponds to this one to one. The fact that the store also keeps the office catie effort as narrow as possible and nice and simple, then gave the final tipping point for Lizenzero.

Katrin Lange - Owner
Naturzwerge Kidswear

Thanks to Lizenzero packaging licensing was very easy. With the self-explanatory documentation of how to license I was guided very quickly and easily through each step. All in all it took me only 10 minutes to complete the process and register my shop. Terrific!

Nico Meisner - Managing Director
Buster Surfboards

We can recommend Lizenzero without reservation. We have looked at several providers. We chose Lizenzero because they make it easiest for customers to see through the packagingG and the signup / registration on the website is very simple and fast.

Peitz -
Managing Director

Holzspielzeug Peitz

Interseroh has given me all the information I need about packaging licensing. The company’s long experience speaks for itself, and I can be sure that Interseroh will help me to fulfil my obligations from the German Packaging Ordinance and the new German Packaging Act. And I can also get everything done easily online!

Beatrice Rittelmeyer - Managing Director
Leithner's Shop

I have only a limited amount of time and cannot afford to spend day after day working out my packaging licensing. At Lizenzero, I was guided step-by-step through the registration procedure. Registration is completed in just a few clicks. And the price is very fair, too. The peace of mind from knowing my packaging is licensed means I can focus once again on my customers.

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