As a result of extended producer responsibility (EPR) within the european union (EU), retailers must register and make a contribution to waste management in the form of system participation. The implementation of the goals for reducing waste and its proper disposal should thus be promoted and monitored. Since July 2022, checking the proper and comprehensive registration of products and packaging for trading platforms has also been mandatory. In accordance with the EPR, online retailers should provide the relevant registration numbers in order to be allowed to sell at all.
LUCID packaging register: Online retailers - including small businesses - are required to register and provide an identity or LUCID registration number. These are also checked by sales platforms such as eBay or Amazon. Participation in the system (e.g. by using shipping boxes or wrapping paper) is associated with costs. This packaging usually ends up in the recipients' waste cycle. The type and weight of the future waste (packaging, filling material) must be stated here. The system participation contributions are calculated individually based on the information provided. Registration itself is free of charge. The LUCID number is only required for items bought or sold in Germany. The LUCID number can be applied for online from a wide variety of providers and a license can be purchased.
The LUCID number is only required for items sold in Germany. The LUCID number can be applied for online through various providers, and a license can be purchased.
Retailers with branches are also required to list the carrier bags/transport packaging they issue. Packaging materials generated during deliveries to these retailers are not expected to be disposed of by the consumer.
In Germany the official responsibility lies with the Central Packaging Register Foundation (ZSVR) >>> Stiftung Zentrale Stelle Verpackungsregister (ZSVR)
The "Zentrale Stelle Verpackungsregister" (ZSVR) is a foundation under civil law in Germany. It officially began operations on January 1, 2019 with the activation of the new Packaging Act (VerpackG). The ZSVR is entrusted with so-called sovereign tasks, such as implementing the provisions of the Packaging Act. It operates as an authority nationwide.
The Packaging Act (german VerpackG) distinguishes between the obligation to report for
- Packaging subject to system participation that is disposed of by the end consumer (e.g. shipping boxes, shipping cushioning material, disposable beverage cups, packaging that holds individual products together as a bundle).
- Packaging not subject to system participation that is not disposed of by the end consumer (e.g. pallets and their protective film, deposit bottles, beverage crates), but usually remains with the retailer.
As part of the EPR obligations, a registration number in accordance with the German Electrical and Electronic Equipment Act must also be provided when shipping electronic items. This WEEE number is only required for items bought or sold in Germany. This number is required for manufacturers or dealers who place electrical and electronic equipment on the market in Germany for the first time.
Traders who sell their products to France must provide or register an EPR FR number for certain categories.
EPR Number
Extended Producer Responsibility (EPR) and its registration apply to product manufacturers. Product manufacturers must register as part of the system participation process. EPR registration ensures that manufacturers and industry comply with legal regulations and, as a result of their activities, contribute to environmental protection. It promotes sustainable waste disposal management, supports recycling, and helps reduce environmental pollution.
WEEE Number
As part of the EPR obligations, a registration number according to the German Electrical and Electronic Equipment Act must also be provided when shipping electronic items. This number is required for manufacturers or retailers who place electrical and electronic equipment on the market for the first time. Here, too, the financial and mandatory system participation for the proper disposal of electronic waste takes place.
EPR FR Number
Retailers who sell their EPR-registered products to France must provide an EPR FR registration number or register for certain categories. So far, 12 categories have been created by the French authorities.
Obligations using the example of a retailer/mail-order company
The online retailer opens its online shop on January 2, 2025. It must promptly register in the LUCID packaging register and indicate how much packaging it expects to use (planned quantity). At the end of the year, it must register the actual quantity (actual quantity). It must select a system operator with whom it contributes financially based on its consumption (cardboard boxes, etc.). This also applies, of course, when opening a sales outlet, as the regulation applies not only to shipping, but also to means of transport in general (plastic/paper bags in supermarkets).
Typically, this includes:
- Shipping packaging/transport packaging, such as paper or cardboard mailing bags (PPK for short).
- Paper address labels for addressing goods
- Plastic adhesive tape for sealing the means of transport
- Bubble wrap made of plastic or other materials as a securing and filling material
Legally: The customer uses this packaging to ship their goods and is therefore the so-called "first distributor" of this packaging and its other components. If their items are in product packaging (supplied as such by the manufacturer/supplier), this product packaging is not included. It is assumed that the domestic manufacturer has already registered and declared this packaging quantity.
Weight information must be provided for packaging and packaging materials. Annual consumption is required here. If the supplier has not provided corresponding information on their delivery note or invoice, the packaging can be weighed and allocated according to consumption. These quantities must be reported regularly (during the year) to the system operator.
For very small businesses that occasionally ship goods, the minimum packaging weight is always 1 kg. Since July 2022, verification of proper and comprehensive registration of products and packaging has been mandatory. Online retailers are required to provide the relevant registration numbers in accordance with the European Product Registration Regulation (EPR) in order to be allowed to sell at all.
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Stiftung Zentrale Stelle Verpackungsregister (ZSVR) im Artikel: Das Verpackungsgesetz und die Pflichten – was gilt für Sie? | über uns (as of 10.10.2024)
https://www.verpackungsregister.org/ich-moechte-wissen-ob-ich-pflichten-habe-und-wie-ich-diese-erfuelle
Ebay. Aufruf zur Petition der EU-Richtlinie (as of 10.10.2024)
https://www.ebaymainstreet.com/de/petition/emea-epr
https://www.zmart.de - Verpackungslizenz für Mittelstand und Kleingewerbe (as of 10.11.2024)
Stiftung deutsche Recycling
https://deutsche-recycling.de/weee-full-service/weee-nummer-registrierung-bei-der-stiftung-ear/
Ecommerce Europe im Arikel: Extended producer responsibility policies that work for SMEs in Europe (as of 10.10.2024)
https://ecommerce-europe.eu/press-item/extended-producer-responsibility-policies-that-work-for-smes-in-europe/
Unternehmen deutsche Recycling im Artikel: Erweiterte Herstellerverantwortung Deutschland: Gesetze (as of10.10.2024)
https://deutsche-recycling.de/blog/erweiterte-herstellerverantwortung-deutschland/