Print-on-demand and German packaging rules: who licenses the parcel?

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

You never touch the product. Someone else prints it, boxes it and posts it. So it feels obvious that the packaging is not your problem — and for a lot of sellers that is even true. The trouble is that it is true only under conditions most people never check.

The short version

  • Printify, Printful and Gelato are registered in Germany and license the packaging on the orders they fulfil.
  • They give you their LUCID number to enter on marketplaces. It covers their parcels and nothing else.
  • Two providers, or one provider plus anything you post yourself, and you are back to needing your own registration.
  • The question that decides it is not who prints. It is whose packaging reaches the customer.
  • If any of it is yours and you are outside Germany, you need an authorised representative for that part.

What the providers actually do

The large print-on-demand networks worked this out years ago, because German marketplaces started blocking listings without a valid register number. So they registered themselves, pay for the recycling of the parcels they send, and hand their customers a number to enter in the marketplace field.

That is a real service and it is worth what it saves. Printful, for instance, is explicit about the boundary: you may use their number if you sell only Printful-fulfilled products, and you may not use it for anything they do not fulfil. Printify and Gelato operate the same way. Some German providers go a step further and license the packaging while telling you plainly that your own registration duty is untouched.

The boundary is the whole story. Everything below is about where it sits.

The question that decides it

Not “who prints my products”. The one that matters is: whose packaging reaches a German customer, and who put it on the market here?

Work through your own setup with that in mind and it usually resolves in a couple of minutes.

Covered by the provider, typically: the mailer or box the provider uses, its filler, its tape, its label — for orders that provider fulfilled, sent under its own arrangement, and licensed.

Yours, typically: anything from a second provider that does not license; anything you post yourself from your own stock; branded packaging, inserts, cards, tissue or stickers you supply; and any product packaging that carries your brand rather than the provider’s.

Where it goes wrong

The second provider

This is the most common one by a distance. Shirts through one network, mugs through another, and the second one either is not registered in Germany or does not license on your behalf. The first provider’s number does not stretch over the second provider’s parcels, and putting it on the marketplace as though it did is a false statement in a register.

The samples and the small batch

You ordered thirty units to a trade fair, or you keep a few bestsellers at home for quick dispatch, and you post those yourself. Small quantities, but they are entirely yours: box, filler, tape, label. There is no minimum quantity in German packaging law. Ten parcels a year is ten parcels a year.

Your own branding inside the parcel

The thank-you card, the tissue paper, the sticker, the branded sleeve you had shipped to the provider — those are your packaging, placed on the German market by you, even when someone else puts them in the box.

The provider ships from outside the EU

Some networks route European orders through a print partner elsewhere. Then the goods are imported, and importing is its own role with its own consequences. Ask your provider which facility actually serves German orders. The answer is often a different one from what the marketing page suggests.

Print-on-demand does not remove you from the picture by itself. A provider is a fulfilment service. What it can do is take on the packaging it supplies, license it, and say so. What it cannot do is take on packaging it never touched.

What to ask your provider

Five questions, by email, and keep the reply. This is the single most useful hour you can spend on the topic.

  1. Are you registered in the German packaging register, and what is your number? You will need it for the marketplace field, and it should be verifiable in the public register.
  2. Do you license the packaging for German orders through a dual system, and may I rely on that? A number alone is not licensing. Ask for the confirmation of participation.
  3. Which facility fulfils German orders? Country and whether it is in the EU.
  4. Who appears as the sender? If your shop name and address are on the label, the honest position is usually that the packaging is yours, whoever folded it.
  5. What does a typical parcel weigh, by material? Even if the provider licenses it, you may want the number. If you ever ship anything yourself, you will need it.

Do you need an authorised representative?

Since 12 August 2026, a company established outside Germany without a branch here, supplying packaged goods to end users in Germany, has to appoint a representative established here. The duty attaches to producers.

So the answer follows the same split as everything else on this page. If a single provider fulfils every German order, appears as the sender and licenses the packaging, there may be nothing left that makes you a producer here — and then there is nothing for a representative to carry, and you should not pay anyone for one. I would rather tell you that than sign you up.

If any part is yours — the second provider, the samples you post, the branded insert — then you are a producer for that part, and the appointment duty applies to it. It applies to the whole of you, not to a fraction, even when the quantity is small.

One duty is always personal. Registering in the register is yours to do, whatever your provider handles. It is free, it takes about ten minutes, and nobody may do it in your name — not your provider, not a representative. Here is the walkthrough in English.

Common questions

Etsy is asking me for a LUCID number. Can I paste my provider’s?

If that provider fulfils every German order you have and has told you in writing that you may use it, yes — that is what the number is for. If you sell anything else through the same shop, no. The register entry has to match the company name and address on your shop, and the marketplace checks it electronically.

I use Printify but with several print partners. Does that count as several providers?

Normally no, because the contract and the packaging arrangement are with Printify. But the location the order ships from can still matter for the import question, so it is worth asking which partners serve Germany.

What about earlier years?

If parcels went out that nobody licensed, those quantities are still owed for those years and are bought retrospectively from a system operator. It is paperwork, not a criminal matter. It is also cheaper to sort out before someone asks about it.

How much does this cost if it turns out to be mine?

For a small shop it is usually the operator’s minimum annual charge plus my fee. The full price list is here, and the calculator will give you a figure from your own parcel numbers in about thirty seconds.

Tell me your setup

Which providers, which countries, whose name on the label. Three lines is usually enough for me to tell you whether any of this is yours.

Ask me directly

General information, not legal advice, and current as of September 2026. What individual providers cover changes, and it is the provider’s own written confirmation that counts, not a description on a help page — including this one. If your situation is unusual, say so and I will tell you what I think, or tell you that you need a lawyer rather than me.