German packaging law for Etsy and Shopify sellers shipping to Germany from abroad
On 12 August 2026 a new European packaging regulation starts to apply, and Germany's own implementing law comes into force the same day. For most people running a small online shop, one change matters far more than the rest: if you post to German customers and you're based somewhere else, you now need a representative inside Germany.
The short version
- The rule applies from 12 August 2026. There's no grace period written into it.
- It affects you if your business sits outside Germany, has no branch there, and you ship packaged goods directly to German consumers.
- There is no small-seller exemption and no minimum quantity. The duty starts at your first parcel, whether you send twelve a year or twelve thousand — what you pay does scale with volume.
- You may appoint only one representative.
- Registering in the German packaging register is free — and you have to do it yourself.
What actually changed
Germany has had packaging obligations for years. Anyone putting packaged goods on the German market had to register, join a recycling system and report their weights. What was missing was a reliable way to reach sellers who had no presence in Germany at all — which, in the age of Etsy and Shopify, is a great many of them.
The new rules close that gap by requiring those sellers to appoint someone locally. That person steps into your obligations and carries them in their own name. From the authority's point of view, there is now always somebody in the country who can be asked and, if necessary, held responsible.
Do you need an authorised representative in Germany?
Three conditions have to be true at the same time:
- Your business is registered outside Germany. Where you personally live doesn't matter; where the business sits does.
- You supply German consumers directly. If you sell to a German wholesaler or importer who then resells, the obligation usually moves to them.
- You have no branch or subsidiary in Germany. Renting space in a fulfilment centre isn't a branch of yours.
If even one of those isn't true, this particular duty probably doesn't land on you — though other packaging obligations still might, so it's worth checking rather than assuming.
A word about marketplaces. Etsy, eBay and Amazon are required to check whether sellers are registered, and they can and do suspend listings that aren't. That check is not the same as the platform handling the obligation for you. The duty stays with whoever puts the packaging on the market — which is you.
What counts as packaging under German law
More than people expect. Not the thing you're selling, but everything you send it in and with:
- the box or mailing bag
- tissue paper, shredded filler, bubble wrap, air pillows
- tape, including paper tape
- the label, ribbon, twine, stickers, thank-you card sleeve
- any inner packaging the product already came in
What gets reported is the weight per material over a year — cardboard separately from plastic, glass separately from metal. Not the number of parcels. This surprises people, and it's why the first honest step is weighing a typical order on a kitchen scale — what counts, and how to weigh it properly.
The four things that have to happen
| Step | Who does it |
|---|---|
| Appoint a representative in writing, in German, signed by both sides | You and them |
| Register yourself in the packaging register (LUCID) and name them there | You, personally |
| Sign a contract with a recycling system for your packaging | Your representative |
| Report your weights, to the system and to the register, and keep them matching | Your representative |
Why LUCID registration has to be done by you
This is the part people most want to delegate, and the one part that cannot be delegated. German law treats registering in the packaging register as a personal duty — closer to signing your own tax return than to a task you hand to a bookkeeper. So does any later change to your entry: a new brand name, a new address, a change of company name.
Anyone who offers to do the registration for you is either mistaken about the rules or cutting a corner that you, not they, will answer for. The registration itself takes about ten minutes, and the step-by-step guide walks you through the German screens.
Why the contract has to be in German
The appointment has to be made in writing, in the German language, and the German text is the legally binding one. A reputable representative will send you an English reading copy alongside so you know exactly what you're agreeing to — but that copy has no legal effect of its own.
Both sides also have to sign properly: by hand, or with a qualified electronic signature. A signature image pasted into a PDF, or a tick-box saying you accept, is not enough.
What German packaging compliance costs
Three separate things, and it helps to keep them apart:
- The register entry: nothing. Being listed is free. If a service charges you for the entry alone, that's the moment to close the tab.
- The representative: an annual fee. Mine starts at €55 a year for up to 100 parcels.
- The recycling fees: by weight. Paid onward to a recycling system. Cardboard is inexpensive per kilo; plastic is roughly six times more.
For a shop sending around a thousand orders a year in cardboard mailers, the whole thing usually lands somewhere around twenty to thirty cents per parcel. The full cost breakdown is here.
The cheapest lever is your packing table, not your paperwork. One thing surprises people here: switching plastic mailers for paper ones barely moves the bill. Plastic costs far more per kilo, but it weighs so much less that the two roughly cancel out. What actually lowers the figure is less packaging — a box that fits the item, and no more filler than the thing needs. Choose paper over plastic for other reasons if you like; just don't expect it to be the saving.
What happens if you ignore it
The version most sellers actually experience is not a fine — it's a marketplace quietly deactivating their listings, usually at the worst possible moment. The fines exist too, and for serious cases under German packaging law they reach six figures. The other version sellers meet is a cease-and-desist letter from a competitor’s lawyer, which German law allows. But the practical risk for a small shop is losing access to the market while you sort out paperwork you could have done in an afternoon. If you've already been shipping to Germany without any of this in place, here is how to put it right, including what happens with the years already gone.
What to do this week
- Weigh a typical outgoing order — box, filler, tape, label — and note the grams by material.
- Estimate how many parcels went to Germany over the last twelve months.
- Work out what it would cost you, so the decision is a number and not a worry.
- If it applies to you, appoint someone before your next German order goes out.
Not sure where you stand?
Put your own numbers in and get a straight answer in about fifteen seconds. No account, no email address.
See what it would cost meThis article is general information, not legal advice, and it reflects the position as of August 2026. Your own situation may differ — if it does, write to me and I'll tell you so.