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 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 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).


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.

WEEE = Waste of Electrical and Electronic Equipment

Watchout: marketplace obligation starting January 1st 2023
Seller obligation is already long-term in place!

How to fulfil your obligations in Germany

To comply with your obligations, Marketplace sellers have 5 duties:

1. Registration: Your electrical devices must be registered at the public register EAR (per category and per brand.) Please be aware that foreign companies can only register via an appointed authorized representative (see point 2).

2. Appoint an Authorized Representative (AR) in Germany: for electrical and electronic equipment manufacturers/dealers without a subsidiary in Germany

3. Join a PRO (Landbell Group) to ensure collection and recycling of electrical and electronic equipment. Get your contract here!

4. Report to the Registry (you report to Landbell Group and Landbell Group will provide this to the registry)

5. Fulfilment of other obligations like take-back (1:1 and others) is provided as (paid) services by Landbell Group as well

What is the definition of ‘WEEE’?

Devices which are exposed to an alternating voltage of maximally 1,000 V or a direct current voltage of maximally 1,500 V during operations and:

  1. which are dependent on electric currents or electromagnetic fields for proper operation, or
  2. which serve for the generation, conduction and measurement of electric currents and electromagnetic fields.

If you offer an EEE product containing a battery, you must register for both EEE and Batteries.


How to fulfil your obligations in Germany

To comply with your obligations, Marketplace sellers have 4 duties:

1. Registration: Your registration of your batteries must show up in this register (stiftung elektro-altgeräte register). Your batteries must be registered with the EAR (per category and per brand). This is a service Landbell Group can do for you.

2. Join the battery takeback scheme of Landbell Group.
Get your contract here. (membership must be approved by the scheme during the registration process)

3. Report the quantities of batteries placed on the German market. In case you join the scheme of Landbell Group, please report to them and submit to authority.

What is the definition of ‘Batteries’?

The battery law differentiates between three battery types

  • “portable batteries” are batteries, which are sealed and can be hand-carried. Industrial and automotive batteries are not portable batteries
  • “industrial batteries” are all batteries for exclusively industrial, commercial or agricultural purposes. An industrial battery can also be used in electric vehicles such as e-bikes or hybrid cars.
  • “automotive battery” means any battery used for automotive starter, lighting or ignition power.

The manufacturer of all battery types has to register these batteries with the correct brand and battery type at the authority (Stiftung ear) before placing them on the market.

Manufacturers of portable batteries are obligated, to take back waste portable batteries at no charge and nationwide, which were collected at distributors or local collection points. In order to fulfil this take-back obligation, the producer has to participate in a take-back scheme approved by §7 of the battery law. The take-back scheme implements take-back and recycling of waste batteries, and reaches the legally demanded collection rate of at least 50 % from reporting year 2021 onwards.

Manufacturers of industrial batteries and automotive batteries are obligated to take back waste batteries. They have to offer a take-back solution at no cost and reasonably convenient, and recycle these according §14.