Which EPR proof do I need to sell on Amazon.de?

Amazon's information is currently inconsistent: the general Germany page still lists only packaging and electrical equipment.^[2] The specific Seller Central announcement, by contrast, lists all four categories.^[1] Before you submit, also check the current guidance for each category in your seller account.

Your own registration or proof from your upstream supplier

Before submitting anything, clarify your role for each category and each country you sell to. Producers, importers, resellers and authorised representatives carry different obligations. Being a reseller of an electrical device, for example, does not automatically mean you have no obligations of your own for its shipping packaging.

• Check whether your company is itself the producer, that is the party first placing the product on the German market, for the category in question. What counts are the legal definitions and your specific supply and contract arrangement.
• If the obligation is yours, you need the corresponding registration of your own, or the registration through an authorised representative that the law provides for. The registered legal entity, the brand and the equipment type or battery category must meet the respective requirements.^[4][5][9]
• If you only resell goods from a properly registered upstream supplier and have no producer role of your own, check and document the matching producer proof. For this case, Amazon describes flagging yourself as a non-producer and using the upstream supplier's registration number.^[1][17]

For packaging, check sales packaging and shipping packaging separately. Shipping packaging you add yourself can create registration and system participation obligations of your own. The ZSVR distinguishes, among other things, between packaging carrying your own brand and unbranded packaging, and between cases where you assemble or alter a complete package yourself and cases where you do not. Exemptions, for example for certain micro-enterprises, can also be relevant. A supplier's number therefore only covers you where the supplier is actually responsible for that specific packaging.^[8]

Producers with no establishment in Germany are subject to special representation rules, depending on the category. For electrical equipment, § 8 ElektroG requires an authorised representative, who registers in place of the producer.^[9][4] For the foreign producers covered by § 5 Abs. 2 VerpackDG, an authorised representative is also required; the LUCID registration remains with the producer.^[10] For batteries, stiftung ear explains registration through an authorised representative based in Germany.^[5]

When clarifying your role, delivery terms such as DDP or DAP, your role in import and customs declaration, and the storage and delivery route can all be relevant indicators. None of these on its own proves in general who legally counts as the producer or the party first placing the goods on the market. What decides is the specific arrangement in each category.

The obligations behind the proof

Registering and submitting to Amazon are separate steps. A number the portal accepts does not replace the system participation the law requires, nor any take-back, financing or reporting obligations.

Packaging and electrical equipment

LUCID records the obligated producer with its brand names and the required details about its packaging.^[18] Under § 7 VerpackDG, packaging subject to system participation must be enrolled in a system.^[15] For electrical equipment, registration with stiftung ear is made per legal entity, brand and equipment type. The producer must state its WEEE registration number when offering products and on invoices.^[4]

The statutory prohibitions apply to different parties: § 6 Abs. 2 ElektroG covers producers, distributors, online marketplaces and fulfilment service providers.^[4] § 13 VerpackDG sets out prohibitions for producers, distributors and fulfilment service providers. For checks by online platforms, paragraph 4 also refers to Art. 30(1)(d) of the Digital Services Act and Art. 45(4), first subparagraph, point (b) of the EU Packaging and Packaging Waste Regulation. The ZSVR provides an automated interface for matching the required register data.^[16]

Batteries

Batteries are an established proof category for Amazon.de. This also applies to devices with built-in batteries or rechargeable batteries.^[17] Registration with stiftung ear is made per brand and battery category. The batteries concerned may only be made available in Germany for the first time once the registration decision has been issued.^[5] The Batterierecht-Durchführungsgesetz (BattDG), Germany's battery law implementation act, has applied since 7 October 2025, and the Umweltbundesamt has entrusted stiftung ear with the tasks of the competent authority.^[11]

For each battery category, producers must either join an approved producer responsibility organisation (Organisation für Herstellerverantwortung, OfH) or fulfil their extended producer responsibility individually. Individual fulfilment also requires approval. This alternative follows from § 7 Abs. 1 in conjunction with § 8 BattDG, so joining an OfH is not the only permitted route.^[12][13]

Certain single-use plastic products

Registration is made through DIVID, the Single-Use Plastics Fund platform run by the Umweltbundesamt.^[14] What counts are the product groups and conditions of the Einwegkunststofffondsgesetz. Annex 1, for example, covers certain food containers, beverage cups and wet wipes. Check the specific product description and your role before you start a registration. The registration obligation falls on the producers obligated under this act.^[6][7]

Submitting proof to Amazon and resolving rejections

Gather the proof that matches the role you clarified earlier. With your own producer registration, the company details must be assigned to the responsible legal entity. With a permitted upstream supplier proof, you instead document the registered producer and its link to your goods. So the registration holder does not have to be identical to the seller account in every case.

• In the EPR compliance portal, select the relevant country and category. Enter the matching registration number.^[1]
• For WEEE and batteries, check which brands and equipment types or battery categories are covered. Match the proof to the products you actually offer.^[4][5]
• Where applicable, flag your non-producer role and submit the required proof from the producer or upstream supplier. Watch for additional documents, such as a producer consent requested in the portal.^[1][17]
• Keep the submitted proof and the portal's response with their dates. If a submission is rejected, record the reason and correct the underlying details before you resubmit.

If a submission is rejected, check above all the role you selected, the assigned legal entity, the brand and category, and the current register status. Someone else's number is not a general substitute for a registration obligation of your own. Conversely, an upstream supplier's number is not wrong merely because its holder differs from the seller account.

In its battery announcement, Amazon states that validation takes up to five business days. This figure refers to the battery process described there and is not a general processing time for all EPR proof.^[17] For your specific case, the status shown and the current guidance in your seller account remain decisive. Listings concerned can be deactivated if proof is missing or invalid.^[1]

Whether you are a producer, importer, reseller or authorised representative depends on your specific arrangement. Have your supply relationships, brand details and contracts to hand. If you want to clarify your obligations for packaging, electrical equipment or batteries, you can request a consultation with ClearoSystems.

Frequently asked questions

Which EPR number does Amazon require for Germany?

Depending on your product range, this can be LUCID for packaging, the WEEE registration for electrical equipment, the stiftung ear battery registration and DIVID for certain single-use plastic products. Whether you submit your own number or a permitted upstream supplier proof depends on your role in each category.

Why does Amazon reject my WEEE number as invalid?

Check whether the registration is active and covers the brand and equipment type you offer. Also compare the producer or reseller role you entered and the responsible legal entity. With a permitted upstream supplier proof, the number must belong to the goods you source; it then does not have to be in the name of your seller account holder.

Is the LUCID number enough if I only sell packaged goods without electronics?

The LUCID number is the registration proof for packaging. It does not replace any system participation that may be required. Other proof categories can apply even without electronics, for example certain single-use plastic products. So check your product range and role, and your sales and shipping packaging, separately.

Do I need a DIVID registration for every plastic package?

No. What matters is whether the specific product falls under the Einwegkunststofffondsgesetz and whether your company carries the producer obligations under it. Using plastic alone is not enough for that classification.