Checklist: Packaging / EPR Rules for France & Germany

If you're an e-commerce seller shipping products to France or Germany, you're likely subject to EPR (Extended Producer Responsibility) packaging laws — even if you're based outside the EU.

Non-compliance can result in:

• ❌ Sales bans on Amazon, eBay, and other marketplaces
• ❌ Fines up to €50,000+ per violation
• ❌ Customs holds at the border

This guide breaks down what you need to do.

What is EPR for Packaging?

EPR laws make producers (including importers and online sellers) financially responsible for the collection and recycling of packaging waste.

Covered Materials

✅ Cardboard boxes ✅ Plastic wrapping / bubble wrap ✅ Paper inserts ✅ Product packaging (bottles, jars, etc.) ✅ Shipping labels (if paper-based)

Even small amounts of packaging trigger EPR obligations.

France EPR Requirements

Who Must Register?

You must register if you:

• Ship products to France
• Use any packaging (shipping or product)
• Sell > €1 million/year in France (some thresholds)

This includes:

• Amazon FBA sellers with inventory in France
• Dropshippers using French fulfillment centers
• Direct-to-consumer brands shipping from outside France

How to Register

1. Choose a PRO (Producer Responsibility Organization):

   • Citeo (most popular, handles 90% of packaging)
   • Adelphe
   • Leko

2. Obtain a UIN (Unique Identification Number):

   • Format: FR123456_XXXXX
   • Required for marketplace listings

3. Report annually (due by February 28):

   • Tonnes of each packaging material type
   • Submit via your PRO's portal

4. Pay EPR fees (based on tonnage):

   • Cardboard: ~€50–100 per tonne
   • Plastic: ~€400–800 per tonne
   • Prices vary by recyclability (bonus/malus system)

France-Specific Rules

• Triman logo required on packaging (or online if not space)
• Info-tri logo required (sorting instructions)
• AGEC law (anti-waste): Stricter packaging reusability rules by 2025

Germany EPR Requirements

Who Must Register?

You must register if you:

• Place packaging on the German market for the first time
• Sell directly to end consumers (B2C)
• Ship from outside Germany (including from other EU countries)

How to Register

1. Register with LUCID (Stiftung Zentrale Stelle):

   • Free registration at www.lucid.verpackungsregister.org
   • You'll get a LUCID ID (starts with "DE")

2. Contract with a dual system (pick one):

   • Der Grüne Punkt (most popular)
   • Interseroh+
   • BellandVision
   • Noventiz
   • Veolia
   • Reclay (+ 3 others)

3. Report quarterly (via dual system portal):

   • Tonnes of packaging placed on market
   • Must match LUCID registration

4. Pay EPR fees (based on tonnage and material):

   • Cardboard: ~€30–80 per tonne
   • Plastic: ~€1,000–1,500 per tonne
   • Glass: ~€30–50 per tonne

Germany-Specific Rules

• VerpackG (Packaging Act): Mandatory participation in a dual system
• Minimum recycled content: 25% by 2025 for plastic bottles
• Deposit system (Pfand): Applies to beverage containers (€0.25 deposit)

France vs Germany: Key Differences

DSA (Digital Services Act) — New 2024 Requirement

Starting in February 2024, online marketplaces (Amazon, eBay) must verify that sellers comply with EPR before allowing listings.

What You Need

• LUCID ID (for Germany)
• UIN (for France)
• Proof of registration uploaded to marketplace seller dashboard

Amazon requires: EPR registration in every country where you have FBA inventory.

Common Mistakes to Avoid

1. Thinking EPR Only Applies to Manufacturers

EPR applies to anyone who places packaged goods on the market, including:

• Dropshippers
• Amazon FBA sellers
• Importers
• Retailers

2. Only Registering in One Country

If you sell in both France and Germany, you need separate registrations for each country.

3. Underreporting Tonnage

EPR authorities audit seller data. If you underreport packaging weight, you can face retroactive fines + interest.

4. Forgetting "Hidden" Packaging

Include ALL packaging:

• Shipping boxes
• Bubble wrap
• Void fill
• Tape (if paper-based)
• Instruction manuals (if paper)

How to Calculate Your Packaging Tonnage

Example Calculation

Average shipment to France:
- 1× cardboard box: 200g
- 50g bubble wrap
- 10g shipping label
Total per order: 260g = 0.26 kg

Annual shipments: 5,000 orders
Total tonnage: 5,000 × 0.26 kg = 1,300 kg = 1.3 tonnes

EPR fees (France, cardboard):
1.3 tonnes × €80/tonne = €104/year

Most small sellers pay €100–500/year in total EPR fees.

EPR Beyond Packaging

France and Germany also have EPR schemes for:

• Electronics (WEEE)
• Batteries
• Textiles
• Furniture
• Tires

Each requires separate registration if you sell those products.

Quick Compliance Checklist

For France

• Register with a PRO (Citeo, Adelphe, Leko)
• Obtain UIN
• Add Triman + Info-tri logos
• Report annually (by Feb 28)
• Upload UIN to marketplaces (Amazon, eBay)

For Germany

• Register on LUCID
• Contract with a dual system
• Report quarterly
• Upload LUCID ID to marketplaces
• Ensure compliance if using beverage packaging (Pfand)

Get Your EPR Checklist

Use our EPR Packaging Helper to:

• ✅ See which countries require EPR registration
• ✅ Calculate your packaging tonnage
• ✅ Get PRO and dual system recommendations
• ✅ Generate a compliance timeline

Next steps:

• File France/Germany via EPR & DSA Compliance
• Align footers/consent with GDPR basics
• Store UIN/LUCID evidence in the Readiness Wizard

Run EPR Check →

Last updated: October 2025 Source: VerpackG (Germany), AGEC Law (France), DSA Regulation (EU)