Germany's Packaging EPR: Amazon Requires a LUCID Number

In brief: Germany's Packaging Act makes anyone who puts packaged goods on the German market — product packaging and shipping boxes — register with the central packaging register (ZSVR) and get a LUCID number. From 1 July 2022 marketplaces had to check this, so Amazon asked every seller shipping packaged goods to Germany or selling on Amazon.de to submit their LUCID number by 14 June 2022, and began blocking non-compliant listings on 15 June 2022. Most sellers also had to join a packaging scheme (a "system participation contract") and pay scheme fees.

How to get a LUCID number for Amazon.de

Step	Detail
Register with ZSVR	Get a LUCID number (Amazon warned this could take up to four weeks)
Tell Amazon	Enter the LUCID number in Seller Central; Amazon took about five working days to check it
Join a scheme	If your packaging is subject to system participation, contract with one or more schemes
Report and pay	Declare packaging volumes to both the scheme and ZSVR, and pay the scheme's fees for each period

Tools Amazon added

• EPR reports (March 2022): downloadable data showing which of your sales fall under EPR rules — packaging and electrical goods for Germany, and seven categories for France. Amazon stressed that sellers remained responsible for checking the figures.
• FBA secondary packaging (September 2022): because Amazon can't declare the boxes and bags it uses to ship FBA orders, sellers must include them in their own German packaging declarations. The EPR report shows the paper and plastic weights for Amazon.de shipments from 1 July 2022.

A worked example

A seller ships 20,000 FBA orders a year in Germany. Their scheme declaration must include both their own product packaging and the paper and plastic Amazon used to send those orders, as shown in the EPR report. The scheme then bills a fee based on the declared weights — a cost that scales with German sales.

What it means for your bookkeeping

• Scheme fees are a business cost. Packaging scheme and registration fees are paid to third parties, not through Amazon. Record them as an overhead or a cost of selling in Germany, supported by the scheme's invoices.

• Declarations drive the bill. Under-declaring can mean back-charges later. Keep each EPR report you use, so the figures behind every declaration can be shown.

• Blocked listings mean lost sales. If a LUCID number lapsed or wasn't validated, German sales stopped. A sudden drop in Amazon.de revenue is worth checking against compliance status.

• VAT on scheme fees: take the treatment from the scheme's invoice.

• Keep it out of selling fees. Scheme fees are billed by the scheme, not Amazon — see Amazon FBA bookkeeping and reconciling an Amazon settlement.

How TrueBooks helps

TrueBooks keeps each Amazon marketplace in its own currency and shows profit by marketplace, so you can weigh German compliance costs against German sales. It doesn't handle EPR registrations or payments. See the Amazon Xero integration.