Packaging EPR in Germany and France: what overseas sellers need
By Drew Cooper, Founder & CEO · Last reviewed: 12 November 2026
If you sell packaged goods to consumers in Germany or France, you must register as a packaging producer, pay into a recycling scheme and report your volumes. France also requires the Triman sorting label on household packaging. From 12 August 2026, the EU's Packaging and Packaging Waste Regulation (PPWR) also requires producers without an establishment in a country to appoint an authorised representative for producer responsibility there. Marketplaces in both countries check registration and can block sellers who are not compliant.
Who this guide is for
Overseas brands shipping packaged products to consumers in Germany or France, whether from an EU warehouse, through Amazon or other marketplaces, or direct from outside the EU.
1. Germany: LUCID and the dual system
Under the Packaging Act (VerpackG), you must:
- Register in LUCID, the packaging register run by the Zentrale Stelle Verpackungsregister, before you sell
- Join a dual system (system participation) for all packaging that ends up with private consumers, including sales packaging, outer packaging and shipping boxes and fillers
- Report volumes by material to your dual system and the same figures to LUCID
- File a declaration of completeness if you exceed set thresholds by material
There is no minimum threshold for registration. Online marketplaces and fulfilment providers must check that sellers are registered and participating in a system, and fines for selling without system participation can reach €200,000.
Germany is adapting its law to the PPWR. Under the new rules, producers without a German establishment appoint an authorised representative, who takes on registration and reporting. Check the current LUCID guidance before you register.
2. France: eco-organisme, IDU and Triman
- Join an approved eco-organisme for household packaging and pay contributions based on what you place on the market
- Get your unique identification number (IDU), issued through the national register run by ADEME once you join
- Show the IDU in your terms and conditions or other customer information
- Appoint an authorised representative in France if you are based outside the country
Marketplaces must collect sellers' IDUs. If you cannot show one, the marketplace may pay contributions on your behalf and recharge you, or stop you selling.
France applies producer responsibility to many product categories beyond packaging, including electrical equipment, textiles and footwear, toys, furniture, sports and leisure goods, and DIY and garden products. Each needs its own eco-organisme membership and IDU.
3. The Triman label and sorting instructions
Household packaging sold in France must carry the Triman logo with sorting instructions (Info-tri) showing which bin each part goes in. It normally goes on the packaging itself, with digital-only display allowed only in limited cases. Italy has its own mandatory environmental labelling, so a single EU pack does not yet exist. The PPWR brings harmonised EU sorting labels, expected to apply from 2028.
4. What else the PPWR changes
The PPWR applies from 12 August 2026 and replaces the old packaging directive with a regulation that applies directly in every EU country. Alongside the authorised representative rule, it brings:
- Limits on PFAS in food contact packaging
- Recyclability requirements for packaging, phasing in from 2030
- Rules on minimising empty space and packaging weight
- Harmonised labelling and, for some formats, reuse and recycled-content targets
At a glance
| Requirement | Germany | France |
|---|---|---|
| Register | LUCID (Zentrale Stelle Verpackungsregister) | National register run by ADEME, issuing an IDU |
| Scheme | Dual system participation | Approved eco-organisme |
| Number to show or provide | LUCID registration number, checked by marketplaces | IDU in terms and conditions, collected by marketplaces |
| Sorting label | No mandatory national logo | Triman and Info-tri |
| Overseas sellers | Authorised representative under the PPWR | Authorised representative required |
| Minimum threshold | None | Registration applies; check small-volume arrangements with your eco-organisme |
Questions we get asked
Does selling through Amazon's fulfilment network cover my packaging obligations?
Generally, no. You are the producer of the packaging around your products. Ask your fulfilment provider in writing who licenses any shipping packaging they add.
I only sell small volumes. Do I still need to register?
In Germany, yes: there is no minimum. In France, registration applies, and some eco-organismes offer simplified terms for small volumes.
Is UK packaging EPR the same?
No. UK packaging EPR has turnover and tonnage thresholds and different reporting. See UK packaging EPR.
Can I use one label across the EU?
Not yet. France and Italy each require their own environmental labelling until the PPWR's harmonised labels apply.
How Lantara helps
Lantara handles packaging EPR registration and reporting in Germany, France and other EU countries, acts as your authorised representative where required, and checks your packs for the right sorting labels. Start with a free readiness check of up to 10 SKUs, or read about EU compliance.