Your products are ready. Your Amazon.de account is set up. Your first shipment is on its way to a European fulfilment centre. And then an email lands in your inbox: your listing has been blocked because your LUCID registration number is missing.
This happens to dozens of non-European sellers every week. And it is entirely avoidable — if you know what EPR is and what you are required to do.
What is EPR?
EPR stands for Extended Producer Responsibility. It is a European principle under which the producer or importer of packaging is responsible for the costs of collecting, sorting and recycling that packaging.
In practice, this means: if you ship a product in a box, bag or film to a European consumer, you are required to contribute to the recycling system of that country.
🗑️ Concretely: the consumer pays through their municipal waste collection. The producer pays through a mandatory contribution to an approved recycling scheme. As a non-EU brand, you are that producer — even if you have no European establishment.
Germany: the LUCID Verpackungsregister
Germany has the most developed EPR system in Europe. The Verpackungsgesetz (VerpackG) — Germany's Packaging Act — requires every seller delivering packaged goods to German consumers to:
- Register in the LUCID register — the central transparency register for packaging producers in Germany. Registration is free and is done via lucid.registrierung-verpackungsgesetz.de.
- Enter into a contract with a dual system — an approved recycling organisation such as Der Grüne Punkt, ALBA, Landbell or Interseroh. You pay an annual contribution based on the weight and type of packaging you place on the market.
- Declare your packaging quantities annually — you report how many kilograms of cardboard, plastic, glass or film you have sold into Germany each year.
What counts as packaging?
- The transport packaging of your product (the box)
- The retail or display packaging (the carton around your product)
- The shipping packaging if you deliver directly to consumers
Amazon enforcement
Amazon.de actively requests your LUCID registration number when you create or renew your seller account. Without this number, your listings will be blocked or your account suspended. Amazon also registers the packaging it uses on your behalf (such as FBA packaging) — but this does not exempt you from the obligation for your own product box.
The Netherlands: packaging levy and bol.com
The Netherlands works differently. There is no central register like LUCID, but the Environmental Management Act and a packaging contribution scheme apply to companies placing more than 50,000 kg of packaging on the market annually.
For smaller non-EU brands selling via bol.com, the practical situation is as follows:
- You as a foreign seller are the importer of your products into the EU
- The importer is responsible for the EPR contribution in the country of first entry (typically the Netherlands or Germany)
- bol.com currently does not actively request an EPR registration number, but this is changing in 2026 under new EU directives
Practical advice: if you are already registered in Germany and selling from there into the Netherlands, you will in most cases already comply with Dutch obligations via OSS and your LUCID registration. If in doubt, seek specific advice for your situation.
What happens if you don't comply?
- Amazon.de: listings blocked, account suspended, payments withheld until your LUCID number is provided
- Fines: the Stiftung Zentrale Stelle Verpackungsregister (ZSVR) can impose fines of up to €200,000 for serious or repeated violations
- Marketplaces in other EU countries: France, Spain and Poland have similar EPR systems. Brands planning to grow across Europe would do well to prepare for these early
Step by step: how to register
Step 1 — Register in LUCID
Go to lucid.registrierung-verpackungsgesetz.de. Register your company and receive your LUCID number. This is free and typically takes 1–3 business days.
Step 2 — Enter into a contract with a dual system
Choose an approved provider (Der Grüne Punkt, Landbell, ALBA, Interseroh, etc.) and provide an estimate of the packaging weight you place on the German market. You will pay an annual contribution.
Step 3 — Enter your LUCID number at Amazon
In Seller Central > Account Settings > Extended Producer Responsibility, enter your LUCID number per product category.
Step 4 — Declare annually
You are required to report your actual packaging quantities annually through your dual system. Keep track of your sales data.
How Crossello handles this for you
As Merchant of Record, we act as the legal importer and seller in Europe. That means we also manage EPR obligations on your behalf — LUCID registration, contracts with dual systems, and annual declarations.
You focus on your product and your home market. We make sure you comply with European regulations.
No European BV or GmbH needed. No LUCID headaches. No surprise blocks on Amazon.
Want to know how we handle this concretely for your situation? Get in touch — we're happy to walk you through it step by step.