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

Verified on 2026-09-01 · Packaging law (PPWR)

In short

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.

What to do now, concretely

  1. Request from your box supplier in writing (with a deadline): LUCID registration number, confirmation of system participation, EU declaration of conformity and a written clarification of which role they take on.
  2. Verify the details yourself in the public LUCID register – and document all the correspondence.
  3. Until this is resolved: keep your own system participation for shipping packaging running – double licensing is annoying, no licensing is dangerous.

This case comes from a real seller enquiry: a seller asked her box supplier for compliance evidence and for weeks received nothing but an acknowledgement of receipt. At the same time, one carton manufacturer claimed the obligation falls on 'whoever first fills the packaging', while the Händlerbund (a German e-commerce association) assigned neutral standard cartons to the supplier. Even the European Commission only sharpened its FAQ two weeks after the rules took effect. As long as such contradictions persist, only written form plus your own licensing protects you.

Related country guides

Germany

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Sources: Wortfilter: Händlerin-Frage zu Nachweisen vom Kartonlieferanten (accessed 2026-09-01) · ZSVR / Verpackungsregister LUCID (öffentliches Register) (accessed 2026-09-01)

Legal information, not legal advice. The linked official sources prevail; data marked “draft” has not been finally verified.

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