What do online retailers and marketplace sellers need to be aware of as of 1.7.2022?

Electronic marketplaces such as Amazon and fulfilment service providers may no longer permit the offering of goods and/or provide services if proper registration and system participation has not been proven by their customers, i.e. electronic marketplaces such as Amazon will then be subject to verification obligations. Online traders must therefore prepare themselves for such enquiries and should be prepared.

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What do electronic marketplaces such as Amazon, eBay, Otto, Alibaba, Rakuten and others ask for?


In order to fulfil their inspection obligations, these platforms need to know whether their traders are registered in the packaging register LUCID of the Central Agency Packaging Register (ZSVR) and whether they have participated their packaging in a dual system - such as Der Grüne Punkt. You can obtain a system participation at www.verpackgo.de. Online traders must therefore be able to provide the LUCID registration number (also called Extended Producer Responsibility number) and confirm their system participation.


  • Every Green Dot customer with a valid participation contract can download their Green Dot participation confirmation for the current year from our online portal for sales packaging itself. Simply log in and "print out confirmation of participation" on the homepage.


What does Amazon require of its online retailers in particular?


Online retailers who sell to Germany and/or France and have been identified by Amazon, for example, as a "producer" within the meaning of the Packaging Act, must prove to the electronic marketplace operator that they comply with the respective national EPR (Extended Producer Responsibility) requirements. This is done by reporting the corresponding EPR registration number(s), the link to which is provided by Amazon.


This applies to Amazon offers in Germany for packaging, electrical and electronic equipment and batteries. For electrical appliances with batteries, Amazon currently only requires the registration number for electrical and electronic appliances.


The following registration numbers are currently to be indicated



Those selling to France have to comply with further registration obligations for the take-back and disposal of printing paper, furniture, textiles and tyres.


  • For system participation of sales packaging in France, CITEO from PRO Europe's international Green Dot family is a contact (www.citeo.com).    


New regulations also for fulfilment service providers


Fulfillment service providers (e.g. use of FBA) are no longer manufacturers in the sense of the Packaging Act for system-participating shipping packaging that they fill with goods. Rather, the distributor for whom the fulfilment service provider acts is considered the producer with regard to the shipping packaging, who must carry out the registration and system participation. The information required for this, such as quantities and types of material, must then be requested from the fulfilment service provider.


Detailed information on this can be found in the ZSVR topic paper "5. Issues and specific situations for mail order companies  and online retailers" under Subject-specific papers (verpackungsregister.org)