Packaging EPR for Amazon.de sellers delivering to Germany and Austria

Example: you list a packaged product on Amazon.de and deliver it to customers in Germany and Austria. Keep two country checks. A German registration record does not establish Austrian coverage.

Confirm which destinations you actually serve in Seller Central. Then gather your business establishment details, who first makes the packaged goods available in each country, and the registration, representative and system records for that country. If the producer role is unclear, get it reviewed before relying on a checklist.

The VerpackDG replaced the VerpackG from 12 August 2026. For a producer in scope, check these separate steps:

• Register with ZSVR through LUCID before first making packaging available in Germany. Keep registration details current (§ 6(1)–(2)).
• Check dual-system participation. Packaging that typically ends up with private final consumers must participate in one or more dual systems before being made available (§ 7(1)). A registration number alone does not record that contract.
• Check whether you need a German EPR authorised representative. A producer covered by PPWR Article 45(3) without an establishment in Germany must appoint one before first making packaging available. The written mandate must be in German and the representative must be named to ZSVR (§ 5(2)–(6)).

The § 68 transition dates

Existing VerpackG registrations count as VerpackDG registrations. Required changes are due by 12 November 2026; newly obligated producers had a registration deadline of 12 September 2026. Existing VerpackG system participation continues until 31 December 2026 at the latest (§ 68(1)–(2)). Check your own contract and registration rather than treating the transition as a new start date.

For foreign distance sellers within AWG 2002 § 13g(1) Z 5, the VVO 2014 sets out separate packaging duties:

• Appoint an Austrian authorised representative. This applies to packaging placed on the Austrian market from 1 January 2023. Only one representative may hold that role at a time (§ 16b(1)).
• Plan around calendar quarters. Appointment, change or ending of representation takes effect only at the end of a calendar quarter; continuity must be maintained (§ 16b(1)).
• Arrange a collection and recovery system contract for household packaging. Primary obligated parties must conclude it within two months of first placing household packaging on the market (§ 8(1)). This timing does not replace the representative duty.

Keep the mandate and system contract together with their scope and dates. Do not substitute a German LUCID number for evidence covering Austria.

Amazon’s current packaging EPR expectations for Germany and Austrian delivery are unconfirmed in our source review. Reports that Amazon.de asks for a LUCID number, and that Amazon asks for EPR registration in every EU delivery destination from 12 August 2026, are secondary. Check current Seller Central help and your account notices before acting on those reports.

• Check the storefront, delivery destinations and packaging scheme named in the request.
• Check which business entity, number or document Amazon asks you to supply.
• Keep the request, your submission and Amazon’s resulting status as separate records.

We have not confirmed a universal Austrian identifier format or a universal Seller Central submission path. A marketplace status does not settle the separate country evidence check.

Country Market Access separates storefront from destination, keeps registrations and reviewed coverage within one country, and groups missing requirements into root actions with affected listing counts. Its packaging pilot covers Germany, Austria, France, Italy and Spain.

Record existing evidence, follow a country setup path or record a decision to stop selling into a destination after applying the restriction yourself. Supplier coverage is not offered as a resolution path in the pilot.

See how Country Market Access works, including the confirmation required for a market exit.

For the separate task of reviewing listing text, see the environmental claims guide.

For EU-established distance sellers, PPWR Article 3(1)(15)(d) defines the cross-border producer role and Article 45(3) requires a written EPR authorised-representative mandate in each other Member State where packaged products are first made available. France uses an IDU through ADEME/SYDEREP; Spain has a packaging registry and requires a Spanish authorised representative; Italy’s packaging system includes CONAI or an allowed alternative.

See France, Italy and Spain in Country Market Access.

Read the country checklists for France, Italy and Spain.

• Germany: VerpackDG — § 5(2)–(6), § 6(1)–(2), § 7(1) and § 68(1)–(2); source review 30 September 2026.
• Austria: VVO 2014 — § 8(1) and § 16b(1), with the distance-seller reference to AWG 2002 § 13g(1) Z 5; version reviewed 30 September 2026.
• Austria: official guidance on authorised representatives — the USP reference recorded in the same source review.
• EU: Regulation (EU) 2025/40 (PPWR) — Article 3(1)(15)(d), Article 45(3) and (4); applies from 12 August 2026; reviewed 1 October 2026.
• France: ADEME on the unique identifier (IDU) — reviewed 1 October 2026.
• Spain: Real Decreto 1055/2022 — Articles 15 and 17(2); reviewed 1 October 2026.
• Italy: D.Lgs. 152/2006 — Article 221; reviewed 1 October 2026.

This is a practical starting checklist. Resolve questions about your role and packaging scope with the relevant authority or a qualified adviser.

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