Guide · Etsy

Packaging EPR for Etsy sellers

Etsy shops are usually tiny, handmade and shipped from a kitchen table. EU packaging rules don't care: if you ship to customers in Germany, the same duties apply as for a big retailer.

Facts checked: 28 October 2026

Based outside Germany? Representative first, then LUCID

Since 12 August 2026, companies without an establishment in Germany that sell directly to end users there must appoint an authorised representative in Germany before their first sale. The LUCID registration form asks you to select them: without a representative, you can't complete the registration.

Not law yet. On 20 October 2026 the European Parliament voted 616 to 9 to postpone this obligation until 2035 for small businesses established in the EU (fewer than 50 staff, under €10 million turnover). The Council also supports an exemption. Until it is adopted and published in the Official Journal, the obligation applies.

Council press release, 21 October 2026

Official ZSVR page We help you with this step: ask us

Why it applies to a small Etsy shop

You pack the parcel, so you are the producer of that packaging. In Germany there's no minimum quantity: the first box, padded envelope or tissue paper you send to a German buyer counts. Shops based abroad are producers too, if they ship directly to end users in Germany.

What Etsy asks for

Online platforms must check that sellers shipping to Germany are registered in LUCID and confirm that they meet their EPR duties. Etsy asks for your LUCID number in its settings for sellers. If it's missing, your listings can't be offered in Germany.

Typical Etsy packaging, and what to license

Cardboard boxes and paper mailers: paper/cardboard.
Bubble mailers, poly bags, bubble wrap: plastics (or a composite, if paper and plastic are glued together).
Tissue paper, paper filler and decorative wrapping: usually packaging too, if they protect or present the item.
Tape and labels: part of the shipping packaging.

Tip: weigh one typical parcel without the product, split by material, and multiply by your yearly orders to Germany. That's your starting estimate for the dual system.

Selling to other EU countries

France has no small-seller exemption either, and clothing sellers also need Refashion. Belgium says there's no minimum. The Netherlands and Ireland are less clear. Use the checker for each country you ship to.

Your to-do list

Based abroad? Find an authorised representative in Germany.
Register in LUCID, with the same data as in your Etsy account.
License your packaging with a dual system.
Report the same quantities in LUCID.
Enter your LUCID number in Etsy.

Questions

I only sell a few items a month on Etsy. Do I really need this?

For Germany, yes. There's no minimum quantity. For other countries it depends, and some are still unclear.

I use print-on-demand. Who is the producer?

It depends on who packs and ships, and whose brand is on the packaging. If the provider ships in its own unbranded packaging, it may be the producer; if the packaging carries your brand, it's usually you. We check your setup.

Does Etsy pay the packaging fees for me?

No. Etsy checks your registration; the registration, the dual-system licence and the reports are your responsibility.

Sources

Not sure where you stand?

Tell us what you sell and where you ship. We'll tell you what applies, even when the answer is "nothing".

Ask us to check