Frau Annette Mustermann
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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.
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. Interseroh+ via Lizenzero (and claim your 5% discount!) –
go here to enter your packaging volumes
✔ You’ll receive your system participation certificate to pass on to eBay
(Please note: eBay will inform you in due time where you can deposit the proof in your seller account)
...in the LUCID Packaging Register run by the Central Agency Packaging Register.
✔ You’ll receive your LUCID registration number (EPR number) to pass on to eBay
(Please note: You can already enter the LUCID registration number in your seller account.)
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
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.
Since the marketplaces' obligation to monitor compliance with the Packaging Act will come into effect as early as July 2022, eBay is currently communicating the relevant requirements to its sellers. The control obligation for electrical appliances will follow from January 2023.
The Packaging Act imposes three obligations on sellers who ship packaged products to German end consumers:
- 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 Interseroh+ and preferred partner of eBay: Enter volumes now
- Registration in the packaging register LUCID
- Data reporting to the packaging register LUCID (name of the dual system and licensed packaging volumes)
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.
Medium-term, you will need to present two proofs to eBay:
- LUCID registration number (sometimes also called EPR number): You will receive this number after successful registration in the LUCID packaging register. (You can already deposit this number in your seller account on eBay.)
- Licensing/System Participation Certificate: You can download the Lizenzero-Participation-Certificate in your customer account after you have concluded your license agreement. (eBay will inform you as soon as it is possible to deposit the proof of system participation in your seller account.)
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:
- 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 Interseroh+ (via Lizenzero). In return, Interseroh+ takes over the disposal and recycling process of your packaging for you.
- 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.
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
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Frau Annette Mustermann
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