How to fulfil your obligations as a Marketplace seller in Germany
Watchout: marketplace obligation starting July 1st 2022
Seller obligation is already long-term in place!
How to fulfil your obligations in Germany
What urgently needs to be done from you now (if not already fulfilled):
Central Agency Packaging Register (LUCID) registration and Dual scheme (EASyShop contract)
Attention: both steps need to be completed, if you only register at LUCID or only at Landbell, your compliance is not completed. We have marked each step of the process that must be done.
The information provided in your registration must be correct and must correspond with the information provided to your marketplace. Please refer to the LUCID website for legal, financial and administrational consequences in case of provision of no or wrong data.
1. LUCID – Go to the LUCID registration page for producers*:
*Before starting the registration please ensure to have the following data available (or see the LUCID checklist):
- Responsible manager of the company
- Details of person submitting reports and contact (if possible, please also provide recovery contact for case of PTO, leaving company or just sick leave)
- E-mail address & self-chosen password
- Address of the company
- Value added tax identification number (VAT ID)
- National identification number (e.g. commercial register number)
- Listing of all brand names sold in Germany
- Planned annual quantities in the LUCID account and in the dual system must always match; the Central Agency Packaging Register will check this. In case quantities need to be adjusted – also for your quantity report-, these changes must be done with both, your dual system AND also with LUCID in your LUCID account („Data report“).
2. LUCID – Create a login
3. LUCID – You will receive an activation link from LUCID. Please do not forget to activate the link within 24 hours. After activation, you can log in to the LUCID database at https://lucid.verpackungsregister.org and continue your registration.
4. LUCID – Completion of the registration in the LUCID account (you must complete 4 different registers: „Master data“, „Packaging details“, „Brand names“ and „Summary“). Before you submit your registration, you must confirm that you are fulfilling your take-back obligation through participation with a dual system (Landbell).
5. LUCID will instantly send you a confirmation of your registration incl. your producer number (= EPR number) commencing with DE + 13 digits.
6. Landbell – Return to the License packaging at www.landbell-marketplace-seller.com and choose the button “Get your contract here”. Complete the form to create an account and buy the contract for the required period → this is the 2nd legal obligation of the VerpackG. You must join a Producer Responsibility Organisation (Landbell in this case). Please note that your EASyShop contract will only become valid after receipt of payment (electronic payment normally clears overnight).
7. LUCID – For the reporting: Please log on to your LUCID account, choose “Data report”. If you conclude the system participation contract and the registration right now for the current year, select “intra-year volume report”, then select reporting period and “Landbell” as your system operator and, finally, enter your annual planned quantities with the respective material types.
8. Landbell – After contract validation, please log in to your EASyShop account and submit your planned volumes report (Volume reporting à Planned volumes (grey box on the left of the page).
AND DON´T FORGET:
9. Please remember also provide your marketplace where you sell your goods with your producer number (EPR number). Complete your marketplace seller profile with your registration number, where the marketplace is requesting you to do so. They will define dedicated spaces.
10. Landbell AT – at our EASyShop you can also already buy the license for Austria. Shortly the marketplace is facing the same obligation as in Germany. After completion of the German registration, just switch on top of the Easy shop at the arrow to our packaging EASyShop AT.
What is the definition of ‘packaging’?
Sales packaging (product packaging) describes packaging used to protect goods and products and ensure their safe handover to the consumer. Sales packaging is considered as a sales unit, consisting of goods and packaging offered to the end user.
Shipping packaging for online sales is used to deliver goods to the end users (e.g. the shipping cartons, filling materials like bubble foil, etc.). Shipping packaging is always subject to registration and membership of a PRO. For shipping packaging, there are always direct obligations for marketplace sellers/online sellers selling to Germany.
Very rarely, sales packaging (product packaging) may already be registered and covered by membership of a scheme, if the manufacturer fulfilled the obligations in Germany. In this case, a proof of registration and scheme membership is required. If there is no proof, the obligations remain with the Marketplace seller/online seller.
PLEASE REMEMBER: In Germany, you must fulfil the obligations for all packaging put on the German market. Therefore, the obligations are valid for all sales channels and are not limited to the goods sold via your Marketplace.
What is EPR – and why does it
concern me as a Marketplace seller?
Extended Producer Responsibility (EPR) is an environmental policy that makes producers responsible for the entire life cycle of the products that they introduce on the market, from their design until end of life (including waste collection and recycling).
Under EPR regulations, liable companies must mitigate the environmental impacts of their products throughout the entire product life cycle.
Starting in 2022, if you sell in France and/or Germany, Marketplaces must confirm that you are complying with Extended Producer Responsibility (EPR) regulations in the country where you are selling. Obligations in Austria start on January 1, 2023.
If you need support with the registration in France or other countries, please indicate this in the contact form.