System participation contract for Amazon, eBay and other marketplaces

What obligations do I have as an online retailer?

As a commercial online retailer, you are obliged to report your packaging to a dual system such as Recycling Dual GmbH and to register in the LUCID packaging register.

Regular reports on the type and volume of packaging used are also required. Compliance with these obligations is essential in order to avoid fines and sales bans.

Marketplaces such as eBay, Amazon, Otto, Etsy, Temu and AliExpress are obliged to check your system participation.

If you do not submit this confirmation to your marketplace, your marketplace account may be temporarily blocked.

1. What does the system participation (EPR) contract cost?

The cost for small sales volumes is €23.89 per year. The exact costs depend on the type of packaging you use. You should ask yourself what material your packaging and filling material are made of.  (e.g. plastic bags or cardboard boxes with paper shreds).

You can find exact cost details in our calculator.

2. Which types of packaging is affected?

1. Your shipping packaging
2. If you manufacture a product yourself: The product packaging, if any
3. If you import products: The product packaging itself

3. What do online retailers need to consider?

a) If you sell products to Germany from abroad, you bear full product responsibility. This means that you must report all product packaging, not just the shipping packaging,

to a dual system such as Recycling Dual and the Central Agency Packaging Register (LUCID).

b) If you use a fulfilment service provider, they must inform you of the weights of the packaging sent. Please register the shipping packaging as a forecast in advance and licence it.

Please note that as the importer of the product, you must determine and licence all product packaging.

4. I’m starting my business in the future and can’t yet say how much I will sell.

You have your business plan, your company has been founded and you want to start selling your products soon?

Then you should observe the following steps according to VerpackG:

a) Registration in the LUCID Packaging Register, click HERE

b) After you have registered in the packaging register LUCID, you will receive a confirmation letter with your registration number.

This number is mandatory for registration with Recycling Dual and will be requested during the ordering process together with your tax number/VAT number.

c) After you have registered in our webshop, you must submit an initial forecast of your volumes, both to Recycling Dual, your system operator, and to the Packaging Register.

The forecast is an initial estimate of the volumes of which material you will send to your customers in the period of one year. It is important to determine the components of the packaging more precisely: What material is my packaging made of, what filling material do I use, do I use adhesive tape?

d) You report your planned volumes to the LUCID packaging register. We will send you instructions by e-mail!

Important: At the same time as you report your volumes to the LUCID packaging register, you must submit the volume report to Recycling Dual (licensing partner) and pay for it.

e) At the beginning of the following year, you can submit a “year-end volume report”. If you have sold more than stated in your first report, the difference will be recalculated to the exact kilogram.

5. Which system operator are on the market and which one should I choose?

You can find an overview of the authorised dual systems HERE.

Recycling Dual stands for low prices, accessible customer support and specialises in online retailers.

6. How often and to what extent do I have to report packaging?

You report your packaging volumes twice a year. As a forecast for the current or following year and the annual year-end report for the previous year.

The report is submitted via your customer account or our calculator and then to LUCID.

Don’t panic: We will send you instructions on how to report to LUCID and are also there for you by phone.

7. What happens if I do not fulfil my obligations?

If you do not fulfil your obligations under the Packaging Act, you could face fines of up to 200,000 euros, sales bans on marketplaces and formal warnings from competitors. This can also lead to considerable reputational damage and liability risks. It is therefore important to register with LUCID, conclude a system participation agreement and submit regular reports on the packaging used.

8. Are there exceptions for small online retailers?

The Packaging Act does not provide for any exceptions. Registration and system participation is already required for the first product sold.