eBay, Amazon – the wealth of online marketplaces that many retailers use as (additional) sales channels is now enormous, especially because of the easy access to cross-border shipping. Marketplaces use the term EPR (Extended Producer Responsisbility) to make their sellers aware of their obligations. The EPR also includes the obligation in the context of the Packaging law.

Find out what the German Packaging Act means for you as an international retailer selling goods to German end consumers via a marketplace in the following practical cases:

You use a fulfilment service provider

  • In fulfilment, the commissioning retailer/manufacturer is responsible for the licensing of the shipping packaging.
  • Exception: Who can be identified on the shipping packaging?*

a) only the fulfilment service provider
b) fulfilment service provider AND commissioning retailer OR
c) neither of them
>> In these cases, the fulfilment service provider is responsible for the licensing of shipping packaging.

  • You as an international retailer/manufacturer are also responsible for licensing the product packaging as soon as you ship it to German costumers.
  • If you import products from abroad and then sell them to German consumers via marketplaces, you as the importer are usually responsible for all packaging imported into Germany together with the goods. See also The German Packaging Act for Importers.

 

*Important: From July 2022 at the latest, this exception will also be eliminated, so that the commissioning retailer/manufacturer will always be obliged to license the shipping packaging. After a transitional period, the relevant aspects of the amendment to the German Packaging Act from July 2021 will apply. More information on the effects of the amendment for online trade in our blog.

You use dropshipping

  • In dropshipping, your service provider (wholesaler/producer) typically fills both the product packaging and the shipping packaging – so you are not responsible for licensing them.
    Important: As of July 2022, you as a merchant must still provide your marketplace with proof of packaging licensing. You must then request this from your service provider.
  • If you sell imported products to German consumers via marketplaces, you as the importer are usually responsible for licensing all packaging that together with your products are being imported into Germany. You can find more information on the German Packaging Act for Importers in our blog.

 

You use dropshipping

  • In dropshipping, your service provider (wholesaler/producer) typically fills both the product packaging and the shipping packaging – so you are not responsible for licensing them.

You sell goods from abroad directly to German end consumers

Since you are responsible for the goods when they are shipped directly to the German end user without the involvement of an intermediate retailer when crossing the border, you are responsible for the system participation of the following packaging:

  • all packaging and packaging components that are exported to the Germany

You sell via a marketplace

According to the Packaging Act, you are responsible for the participation (synonym: "licensing") of the following packaging in a dual system:

  • Product packaging including all components
  • Shipping packaging including all filling materials and packaging aids

 

Important: Within the framework of the Packaging Act Amendment, marketplaces must comply with a control obligation as of July 2022. As a marketplace trader, you will then have to provide proof of licensing with your dual system and registration in LUCID in order to be able to continue selling via marketplaces to Germany.

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From now on, we are available to all eBay merchants as a preferred partner of Germany's largest marketplace for questions about the Packaging Act amendment. What does that mean exactly?

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