Amendments to Germany’s packaging law will require global manufacturers and online retailers to register with the country’s LUCID packaging registry in order to continue selling on the German market.
While the amendment already affects some manufacturers and sellers in Europe, starting July 1, 2022, marketplaces such as eBay and Etsy will be required to confirm that their global sellers have a valid Extended Producer Responsibility (EPR) registration number. Otherwise, they will have to block sales to German addresses.
“Electronic marketplaces must verify that retailers and sellers of goods are registered with the LUCID packaging registry and meet the requirements for participation in the system. Only electronic markets that are registered and meet the requirements for participation in the system can offer their products.”
eBay has partnered with Lizzenzero to help sellers digitally license their packaging through Interseroh+. Lizenzero simplifies the process for merchants by making it easy to complete the three steps required to comply:
To learn more about how to obtain a packaging license and why one is required, as well as any other issues related to this new law applicable to sales on eBay, visit Lizenzero’s English website here.
After July 1, 2022, eBay sellers who have not completed this process will be prohibited from selling products to Germany.
Etsy also informed its sellers of the upcoming changes in a blog post, and like eBay, it will also require sellers to provide a valid EPR registration or sell wholesale to Germany.
But there is an ongoing discussion on community forums where Etsy sellers are providing advice and guidance to other sellers and service providers so they can comply with the new rules.
If you are planning to sell to Germany, the answer is yes. Even one sale requires registration.
Obviously, this doesn’t make much economic sense for some sellers. According to information provided by eBay and Etsy, these two marketplaces will automatically block orders to Germany if the seller does not provide proof of LUCID registration.
In an FAQ document provided by ZSVR, the agency said that a “national tax number” can also be used instead of a VAT number. For US self-employed sellers, this means your Social Security number.
Although Germany’s data protection laws are among the strictest in the world, providing your social security number may not be the best advice anyway.
Sole proprietors should consider applying for a free EIN from the IRS, which will further separate your business finances from your personal finances but will also change how you file your taxes. We recommend that you consult with an accountant before taking this step.
Unlike VAT rules, which are based on sales or declared amounts, eBay and Etsy know nothing about your packaging.
German packaging law places full responsibility on the manufacturer, which now also includes shipping materials used by international traders and retailers. Failure to comply with the new rules could result in hefty fines of up to €200,000.
Marketplaces that do not fulfill orders themselves cannot monitor or certify the packaging used by sellers, and this is recognized by law. German regulations require that the marketplace is only responsible for obtaining a valid EPR registration number from the seller.
These new rules affect all merchants around the world, regardless of whether they sell goods on a marketplace or through their own website.
There are several ways to achieve compliance and we recommend starting with the official ZSVR website (link to English version) to learn more about the requirements of the German Packaging Act.
Sellers can also check out this blog post from sustainable e-commerce consultancy Ecosistant which goes into more detail on these requirements and how the German regulations may even impact B2B sales.
This concern has arisen since the adoption of the EU Directive 94/62/EC on packaging and packaging waste, as it applies to all EU Member States.
Like many similar EU directives, each country reserves the right to implement its own actions to achieve the objectives of the directive, resulting in 27 different rules and regulations.
Additionally, some non-EU European states such as the UK, Switzerland and Norway will also have their own plans, which could complicate matters.
Packaging laws in Germany appear to be the strictest in Europe so far. Its rules apply even to a single shipment, since there is no minimum threshold at which compliance becomes effective.
How Germany complies with the EU directive will likely pave the way for similar rules in Europe that will impact sellers around the world. Stay tuned!
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Richard is the co-founder of eSeller365. He has over 17 years of experience at eBay, including tens of thousands of sales to buyers in over 100 countries, and even had experience implementing eBay’s VeRO intellectual property program for a former employer. Richard has been using Amazon FBA to sell products on Amazon in the US for about two years.
To take a break from the daily grind, he spends a few weekends each year working as a professional race official for IMSA.
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Post time: Jul-13-2024