EU Market Guide · Seller questions

What sellers are asking about the packaging rules

Collected from seller forums, communities and marketplace announcements – answered in plain language, with sources and dates. If your question is missing: the checker answers it for your specific situation.

• Amazon is asking for my EPR registration number – what do I do now?

  Since 12 Aug 2026, Amazon has been checking your packaging EPR registration in every EU country where you sell or store goods – missing numbers lead to listings being deactivated. You need to register in the respective destination country (or join a scheme there), obtain the number and store it in Seller Central under 'Compliance'. Beware: without proof, Amazon can pay the EPR fees on your behalf and bill you for them – usually more expensive than registering yourself.

• Do I really need an authorised representative in every EU country?

  If you sell at a distance directly to end customers in an EU country where your business has no establishment: under Art. 45 of the EU Packaging Regulation, in principle yes – since 12 Aug 2026, with no de-minimis threshold. Typical costs are €300–500 per country per year, regardless of shipping volume. There is no obligation for countries you do not ship to directly, and in some constellations another party (e.g. your local importer) already fulfils the producer obligations.

• I am registered in LUCID and have a dual system contract – isn't that enough?

  For Germany: almost – but since 12 Aug 2026 your registration may need an update (keywords: authorised representative, new legal basis VerpackDG), and existing system participation contracts remain valid until 31 Dec 2026 at the latest. For every other EU country: no. LUCID only works for Germany – France requires an IDU via SYDEREP, Austria requires Entpflichtung (discharge of obligations via an approved scheme) through a scheme there, and so on. 'I've got LUCID, that'll do' is this year's most expensive mistake.

• My box supplier says I am responsible – who has to license the shipping carton?

  In Germany the rule is: whoever fills the shipping packaging with goods and sends it to end customers counts as the producer of that packaging – so as a rule that is you as the seller, not your box supplier. Legally safe pre-licensed packaging exists above all for service packaging; for standard shipping cartons, do not rely on verbal assurances from your supplier. The industry is currently giving openly contradictory answers on this – get your supplier's role in writing.

• My dual system contract runs out at the end of 2026 – do I have to sign a new one?

  Under the German transitional rules, system participation contracts concluded before 12 Aug 2026 remain valid until 31 Dec 2026 at the latest. From 1 Jan 2027, contracts and volume reports must reflect the new allocation of responsibility – in many cases that means: conclude a new contract or have yours actively confirmed. Industry statements on this currently contradict each other; get written confirmation from your system on what applies to your contract.

• I only ship a few parcels to other EU countries – is there a de-minimis threshold?

  EU-wide: no – the Packaging Regulation has no de-minimis threshold; even a single delivery triggers the obligations in the destination country. Nationally, though, there is real relief: Austria has a flat-rate fee below 1,500 kg/year, in the Netherlands the 50,000 kg threshold for the Verpact contribution remains in place (SUP reporting still applies from the first kilo), Czechia even exempts the smallest volumes under 300 kg/year (plus a turnover cap) from registration entirely, and Denmark allows a simplified declaration below 8 t/year. Don't rely on blanket statements – the rules differ per country.

• Amazon reports 'EPR number invalid' for France – what is causing this?

  Usually one of these three causes is to blame: the wrong number was entered (France requires the IDU – Identifiant Unique – from the ADEME register, not your contract or customer number from the éco-organisme), the number was entered in the wrong format (FR identifiers start with 'FR' and end with a digit code per product category), or the registration is not yet active/updated in the ADEME register. Check the IDU in the open ADEME dataset and enter exactly that identifier.

• I do dropshipping – my supplier does the shipping, am I still liable?

  'The supplier takes care of shipping' does not protect you: what matters is who legally places the packaged goods on the market in the destination country – and when selling under your name to end customers, that is regularly you. If your supplier is based outside the destination country (or outside the EU), registration, system participation and, where applicable, an authorised representative land on you. Only rely on what your supplier proves to you in writing, with registration numbers.