Anyone know about the changes to German packaging law and being required to register with LUCID?

Etsy had a new post on seller accounts regarding the new German packaging law which requires anyone shipping to Germany be registered with LUCID and have an ID number. I noticed on Shopify there isn’t an option to enter in additional ID numbers when shipping, so I was wondering if Shopify was already partnered and that we’re automatically covered?

I don’t have any official answers. But to this:

“I was wondering if Shopify was already partnered and that we’re automatically covered?”

I don’t think that’s even possible, based on my understanding so far. I don’t think it works like that at all.

You can read about the law in English here:

https://www.verpackungsregister.org/en

Here’s what the law is about, from that site:

“Throughout Europe, the producer of a product also takes producer responsibility for the packaging – in terms of preventing packaging waste in the first place, but also in terms of optimising reuse and recovery of what cannot be prevented.”

LUCID is how Germany is making sure producers of products are taking that responsibility:

“packaged goods may only be distributed in Germany if their producers have registered with the LUCID Packaging Register.”

So there’s no way Shopify can “partner” with anything or anybody to do with this, I don’t think. Every individual company/entity that produces a packaged product to ship to Germany has to be registered, and that registration involves providing information about the packaging they use and how that packaging will be recycled once the consumer is done with it. This last bit requires a formal agreement with an approved “system:”

“The fundamental obligation is to have packaging participate in one or more system(s), which will
then collect the packaging from private final consumers nationwide. Systems are responsible for
ensuring that the recycling quotas defined by law (and increases in these quotas) are being met.”

“System participation must be undertaken with one or more of the systems approved for operation
throughout Germany. These systems compete with each other. Prices are market prices and need
to be queried with the systems.”

In other words, it will cost you money to comply with the law by entering into an agreement with one of these systems. The amount will depend on your shipping volume, I suppose, among other things. That’s the point at which I decided to stop shipping to Germany, so my understanding of the rest of this is not rock solid :slightly_smiling_face: But you can read their info/requirements for online retailers here:

https://www.verpackungsregister.org/fileadmin/files/Themenpapiere/Subject-specific-paper_Information-for-mail-order-companies-and-online-retailers.pdf

And this is not a new law. Also from that site: “System participation is a requirement that has been around since 1993.” What’s new as far as Etsy is concerned is that as of July, Etsy will be on the hook for ensuring its sellers are registered. That’s why the July 1 date is getting emphasized on Etsy. From that same site:

“The pressure on online retailers to fulfil their packaging law obligations has increased with a new legal obligation for electronic marketplaces, which now have to check whether the retailers active on their platforms are registered in the LUCID Packaging Register and are fulfilling the system participation requirement. If online retailers cannot provide evidence of compliance, the marketplaces must no longer enable them to offer their goods. The same applies to fulfilment service providers: they may only do work for parties that are fulfilling their producer responsibility.”

Just to head it off, 'cause it was one of my first questions, there is no exemption for being a tiny business:

“The Verpackungsgesetz does not set out any exceptions from the registration requirement, e.g. due to the small size of a company, small packaging quantities subject to system participation, or not having exceeded a ‘de minimis threshold’. Only non-commercial initial distributors of packaging subject to system participation do not have to register or subject the packaging that they have placed on the German market to participation in a (dual) system.”

Anyway, Shopify is not an electronic marketplace like Etsy is, so it has no need to collect our LUCID registration numbers. So that’s why there’s nowhere to put them.

Somebody please correct me if I’ve misunderstood something somewhere.

@karmazain is spot on about the regulations—Shopify isn’t a marketplace like Etsy, so they don’t force you to register, but you are still legally required to do it if you ship to Germany (LUCID) or France (CITEO). The liability falls 100% on you as the merchant.

The biggest headache I found wasn’t just paying the fee, but figuring out the actual weight to report. Most suppliers (like AliExpress or Uline) just say “500 boxes” on the invoice but don’t list the gram weight or material codes (e.g., PAP 20) that the German register demands.

If anyone is still stuck on the math, I built a free calculator that estimates the compliance weight based on box dimensions and industry-standard material density. It gives you the exact gram weight you need to enter into the LUCID portal.

It’s open source and free (I’m a dev, not an agency): https://tare.fyi

Hope it saves you from having to stop shipping to Germany!

Karmazain is spot on.

The registration part is actually pretty straightforward once you understand it. The real headache comes after, calculating what you actually need to report.

You register with LUCID, you pick your dual system, but then you need to tell them: “I shipped X kg of cardboard, Y kg of plastic, Z kg of paper.”

The problem is Shopify doesn’t track that. It has no clue what packaging you actually used.

So you’re left manually figuring out which orders went to Germany, what packaging each used, and totaling the weights by material. If you miss something, your LUCID numbers won’t match your dual system numbers (which is a red flag if you get audited).

This is exactly where most people either bail on selling to Germany or just wing it and hope for the best.

I actually built a Shopify app (EPR One) specifically to handle that calculation piece. You set up your packaging once, and it reads your orders to do the math automatically.

But even if you do it manually, the secret is creating a “packaging recipe” for your products so you aren’t guessing every each deadline.