Amazon FBA and German packaging rules: what changed on 12 August 2026

Published 7 September 2026 · by Jennifer Rogalski-Koschel, authorised representative · 8 minute read

For four years, FBA sellers had to pay for the recycling of Amazon’s own cardboard boxes. That rule was deleted in August. It is a real saving, and it is also the point at which a lot of sellers now overcorrect and stop reporting things they still owe.

The short version

  • Until 11 August 2026 the law simply attributed Amazon’s FBA shipping boxes to you. That attribution no longer exists.
  • Amazon says it now takes on the recycling compliance for the packaging it adds itself.
  • Your own product and sales packaging never moved. It is still yours, and it is what most of your bill was made of anyway.
  • You still need your own LUCID registration, and if you sell from outside Germany you still need an authorised representative.
  • Do not simply delete your old figures. Split them by origin first, and write down why.

What the old rule said

From 1 July 2022 the German Packaging Act carried a special attribution rule for fulfilment providers. If a fulfilment service packed a seller’s goods into shipping packaging, the seller counted as the producer of that packaging — regardless of who bought the cardboard, who stored it, who folded it and who taped it shut.

For Amazon FBA that meant something quite odd in practice. Amazon purchased the boxes, kept them in its own warehouse, filled them with your goods and printed its own label on them, and you paid for their recycling. Amazon published a rule of thumb for the calculation — roughly 95 g of paper and 5 g of plastic per unit dispatched — and sellers reported those quantities through their own dual system contract.

People argued about it for four years. It has now been settled by deletion.

What replaced it

Since 12 August 2026 the EU Packaging and Packaging Waste Regulation applies directly, and in Germany the VerpackDG has replaced the old Packaging Act. The fulfilment attribution rule was not carried over.

You are therefore no longer the producer of a shipping box merely because Amazon used it to send your goods. Instead, each piece of packaging has to be looked at on its own: who made or branded it, who first placed it on the German market, and at which point in the supply chain.

Two words that now mean different things. The regulation separates the manufacturer of a packaging item, who answers for whether the packaging itself is compliant, from the producer in the extended-producer-responsibility sense, who registers, pays for the recycling and files the quantity reports. In German these are Erzeuger and Hersteller. The same company is often both. It does not have to be.

Amazon-branded boxes: Amazon

The clearest case is a box carrying Amazon’s name, logo or brand. Where packaging is made or developed under a company’s brand, that company is the manufacturer of it — and for a branded Amazon shipping box the extended producer responsibility normally sits with Amazon too. The fact that your goods are inside it does not pull the box back to you.

Amazon itself has said it will take on the EPR compliance for the shipping and transport packaging it adds during FBA dispatch. That is the practical answer for most sellers, and it lines up with the legal one.

A shipping label is not branding

This is the distinction that catches people out. A label carries the sender, the recipient, a barcode and a tracking number. Under the current interpretation, sticking a label on a box for dispatch does not make that box a branded packaging of the company named on the label.

So a completely neutral standard carton does not become an Amazon packaging simply because an Amazon dispatch label ends up on it. Which brings us to the genuinely unresolved part.

Neutral boxes: still being argued about

For a plain carton with no branding, two readings currently exist side by side.

At European level, a neutral standard carton can already count as packaging in its finished form even though it arrives flat and is only folded at dispatch. On that reading the actual box producer, further up the chain, is the manufacturer, and combining a ready-made carton with ready-made tape and ready-made filler does not create a new packaging item at the point of packing.

The German register takes a partly different line. Where separate materials — carton, tape, filler — are first assembled into a complete packaging at dispatch, the dispatching company can itself be treated as manufacturer and producer of the result.

Both readings are on the table, they do not agree, and no one has resolved it yet. Which is why “with FBA, Amazon is always the producer” is too broad a statement to build your reporting on.

What is still unambiguously yours

Nothing about August 2026 removed your own packaging from your account. If a product arrives at the fulfilment centre already in your box, your pouch, your printed sleeve, that packaging is yours. Amazon putting it inside an Amazon carton creates a second, separate packaging with possibly a different owner. It does not merge the two.

The list that stays with you, in practice:

The mixed-channel case is where the mistakes happen. Most of the sellers who write to me run FBA alongside their own shop. The change applies to one of those channels and not the other. If you take the new position and apply it to everything you send, you will underreport — and the quantities you self-ship are usually the heavier ones, because you pack them properly.

What to do with your figures

The wrong move is to strike every shipping-packaging kilogram from your reports and hope. The register can ask you why a reported quantity fell, and “I read that Amazon does it now” is not a record.

  1. Separate by origin, not by channel. What arrives at Amazon already packed by you? What does Amazon add in the fulfilment centre? Those are two different lists.
  2. Look at the actual boxes. Are the cartons Amazon uses for your goods branded, or neutral? For branded ones the answer is comfortable. For neutral ones, keep reporting for now and treat it as open.
  3. Get Amazon’s own statement in writing. Which packaging does Amazon treat as its own from 12 August 2026, and which does it still hand back to you? The EPR reports in Seller Central are the starting point.
  4. Check the inbound side. Cartons you use to ship stock into the German fulfilment centre are yours. So is anything that moves under Pan-EU from another country’s warehouse into Germany.
  5. Write down what you changed and why. One page, dated. If anyone asks in two years, that page is the answer.

Does this get you out of needing a representative?

No, and this is worth saying plainly, because the two changes landed on the same day and are easy to conflate.

Since 12 August 2026, a company established outside Germany without a branch here, supplying packaged goods to end users in Germany, must appoint an authorised representative. That duty attaches to you as a producer. It does not depend on who folds your boxes.

As long as any packaging is yours — and your product packaging almost certainly is — you are a producer with German obligations, and those obligations need someone established in Germany to carry them. What FBA can do is make the quantities smaller. It does not make you disappear.

One thing FBA does not change either. Registering in LUCID is your own personal duty. Nobody can do it for you, not Amazon and not me. Amazon then checks the number against the register, which is why a mismatch between your Seller Central entry and your LUCID entry gets listings suspended. The registration itself takes about ten minutes.

Common questions

My quantities will drop a lot. Will that look suspicious?

A drop in reported shipping packaging in the second half of 2026 is expected across the whole market. What matters is that you can explain the split. Report what is genuinely yours, keep the note, and it is a normal year-on-year change rather than a gap.

What about the years before 2026?

Unchanged. Under the old rule those FBA shipping quantities were yours, and if they were never licensed they are still owed for those years. Earlier years are bought retrospectively from a system operator, year by year, each with its own minimum charge. Nothing about the new law wipes them.

I only sell through FBA and nothing else. Am I done?

Only if literally no packaging of yours reaches a German customer — which is rare, because the item itself is almost always in something. Send me a photograph of an unopened parcel and one of the product as it arrives at the fulfilment centre, and I can usually tell you in a single email.

Not sure which half is yours?

Tell me what you ship, how, and through which channels. If the answer is that you need less than you thought, I will tell you that.

Ask me directly

General information, not legal advice, and current as of September 2026. The treatment of neutral shipping packaging is genuinely unsettled at the moment: the European interpretation and the German register’s guidance do not fully agree, and I have said so above rather than picking whichever reading is cheaper. If your setup is unusual, say so and I will tell you what I think — or tell you that you need a lawyer rather than me.