You've been shipping to Germany and never registered. What now?

This is fixable, and you weren't singled out. Enormous numbers of sellers shipping to Germany still aren't properly signed up — and that is exactly why the rules keep tightening, and why the net has finally reached small shops like yours. Here is what to do, in the order that works.

Register, appoint, license — and only one of these is new

You need all three, in that order. Registering is the quick part, and many people stop there thinking they are done — it's the licence that actually pays for your packaging.

Since when have the German packaging rules applied?

The two outer boxes are old news. Germany has made companies pay for recycling their own packaging since 1993. The register arrived with the Packaging Act in January 2019, and from 1 July 2022 it covered every kind of packaging. Only the middle box — the representative — is new.

So why did almost nobody know? Two reasons, and neither is your fault.

There is no small-seller exemption. Germany sets no minimum turnover and no minimum volume — the duty starts at your first parcel. Many countries let small traders below a certain size skip these rules, so sellers fairly assume Germany does the same.

Nobody checked until 2022. The rules were there for years, but no one was looking. Then marketplaces were told to check their sellers, and a rule most people had never heard of started closing shops.

Why the German packaging rules keep getting stricter

All of this exists because so many companies don't pay. The authority behind the register was created in 2019 to stop free riders, whose unpaid share was estimated at over €200 million a year. Even after a million companies had signed up, the amount of packaging actually being paid for hardly moved — many register and then never buy a licence. The authority now emails them in batches.

None of that was aimed at you. It was aimed at the gap between who should pay and who does, and the rules apply the same way to a one-person shop and to a large importer. What changed is that marketplaces now have to check, so sellers on platforms are usually the ones who find out first.

What changed on 12 August 2026: who, not whether

The duties are the same. What changed on 12 August 2026 is that you can no longer carry them yourself from abroad. With no establishment in Germany, a named person here has to hold them in their own name: an authorised representative, in German a Bevollmächtigter.

That reversed the order of the steps. The register no longer lets you finish a registration without naming one, so the representative comes first now, not last.

Being blocked on Etsy or Amazon, and how to avoid it

If you're reading this, you probably haven't been blocked yet. That's the moment to move, not after.

Marketplaces have had to check their sellers' registration since July 2022, and the new law keeps that duty: they may not let you sell if you aren't properly registered. There is no warning first. Your listings simply stop, and you sort out the paperwork with your shop closed. On Etsy your number sits under Finances → Legal and tax information, and it has to match the register exactly: same company name, same address.

Two things worth doing this week:

• Start with the countries that actually earn you money. You don't have to solve all of Europe at once. Sort out your biggest market first, then add the next one. Most sellers begin with Germany.
• Pause shipping to the countries you haven't sorted yet. Turning a destination off for a few weeks is your decision. Having your whole shop switched off isn't.

How to register and license: five steps

1. Find a representative and agree terms You need their ID before you can finish registering, so this comes first now. Ask three things: what they charge, what the recycling costs on top, and what they do about the time before you signed up.
2. Register in LUCID Free, about ten minutes, and you have to do it yourself — the law reserves this step for the producer, your representative included. The screens, step by step, in English. Don't backdate anything; the register records the day you signed up, and that's fine.
3. Enter their ID They accept it from their side, and the authority confirms it. The appointment only counts once both have happened. When a valid ID goes in, their name appears on your entry — if it doesn't, something went wrong.
4. License this year Your representative signs the recycling contract and reports your quantities. This is the step that gets your listings back.
5. Sort out the earlier years Anything before this year is bought separately, one year at a time. Your representative can organise it — you don't have to work out how alone, and at small volumes it usually costs less than people expect.

What it costs to put right

The cost for this year

The recycling company charges by weight and material, with a minimum annual charge that starts at about €30 and rises depending on the operator. The minimum replaces the weight-based price rather than being added to it: if your packaging works out to €11 for the year, you pay the minimum, not the minimum plus €11. Your representative's own fee comes on top of that. The three costs, kept apart. If a law firm has already written to you about this, that letter needs handling separately.

Licences run by calendar year — contracts are written 1 January to 31 December — so signing up in September doesn't leave the earlier months of this year hanging. You declare the year's quantities, including the parcels already sent.

The cost for earlier years

This part is normal paperwork, not a punishment. People expect something much worse, so it's worth saying clearly.

Recycling companies sell licences for past years: you pick 2025, or 2024, and buy it much as you would this year. Each year is bought on its own, so expect the minimum charge once per year rather than once for the lot. Those years then get reported in the register too, so both sides say the same thing.

For a small shop — a few dozen parcels over two or three years — this is a normal business cost, not a shock. It is real money, and I won't pretend otherwise. It is also much less than most people fear when they first realise they've missed something.

Where it does get expensive is hundreds of parcels a year going back to 2019, or heavy packaging like ceramics and glass. If that's you, get the figures properly before assuming anything.

General information, not legal advice, current as of August 2026. How earlier periods are treated depends on the case; where the sums are large, take proper advice.