Etsy EPR Numbers for Germany, France and Spain: Which Register, and What Changed on 12 August 2026

Etsy asks sellers who ship to buyers in Germany, France or Spain for an EPR (Extended Producer Responsibility) registration number for each country. The numbers don’t come from Etsy. They come from national registers: LUCID in Germany, ADEME’s SYDEREP in France and MITECO’s producer register in Spain. Since 12 August 2026, when the EU packaging regulation started to apply, Germany has also required sellers based abroad who ship straight to German buyers to appoint an authorised representative there. Etsy’s Spain article sets the same requirement.

Everything below was read on 9 November 2026: Etsy’s three Help articles Extended Producer Responsibility (EPR) in Germany, …in Spain (both created 4 August 2026) and …in France (created January 2022), all three last edited 11 August 2026; the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40 (the PPWR), on EUR-Lex; and the English pages of Germany’s Central Agency Packaging Register (ZSVR). Etsy’s articles end by telling sellers to check their own case with “a qualified legal or compliance professional”. This post sets out what the pages say. It can’t tell you whether you are a producer.

What is an EPR number on Etsy, and where do you enter it?

An EPR number is the registration number a national register gives a “producer”: the business that first puts packaging or certain products on that country’s market, and so pays for recycling them. Etsy has one field per country, at Shop Manager → Finances → Legal and tax information → Extended Producer Responsibility (EPR) Registrations → Add info under Germany, France or Spain.

Each article says the numbers “must be provided to Etsy” (France: “you must provide it to Etsy”). None of them says what Etsy does with a shop that sells to those countries without one. The Help Center search for “EPR” returns only these three articles. The seven other pages it returns for “extended producer responsibility” (vacation mode, attributes and What Can I Sell on Etsy? among them) don’t use the phrase.

Which register issues the number in each country?

Germany and Spain each have separate registers for packaging, electrical and electronic equipment (EEE) and batteries, so a shop can need up to three numbers per country. France issues one number per product category and covers far more categories, including textiles, toys and furniture.

The table is built from Etsy’s three articles. Its last row quotes each article.

The France row is the one most likely to catch a seller out. A shop selling T-shirts to French buyers deals with two categories on Etsy’s list (textiles and packaging), and a shop selling plush toys with two others (toys and packaging). Etsy’s article links to the full product list on Légifrance.

Does EPR apply if you ship from outside the EU?

For packaging, yes, when you ship straight to the buyer. The PPWR’s definition of a producer covers a business “established in a Member State or in a third country” that ships packaged products into another member state “directly to end users”. ZSVR: “A foreign company is only considered the producer if it ships from abroad directly to a (private or commercial) end user.”

The shipping box counts. ZSVR’s page for online retailers says packaging used for distance selling is “e-commerce packaging”, classed as transport packaging, and lists “shipping boxes and bags, as well as other packaging materials used for shipping, such as labels, adhesive tape and filler material like plastic films, flakes or wrapping tissue.” In Germany, it adds, “Packaging intended for shipment is always subject to system participation, without exception.”

Article 44 of the PPWR, which sets up the registers, has no minimum quantity for registering. Its 10-tonne line (paragraph 8) changes which annual report a producer files, not whether it registers.

What changed on 12 August 2026?

On 12 August 2026 the EU Packaging and Packaging Waste Regulation started to apply, “directly applicable in all Member States”. It bars unregistered producers from selling packaged goods into a country, and requires producers that ship straight to buyers in another member state to appoint an authorised representative there, with room for national rules on sellers outside the EU. Germany replaced its packaging law the same day.

The two rules, in the regulation’s words:

• No registration, no sales. Article 44(4): producers “shall not make available packaging or packaged products on the territory of a Member State for the first time” if they, or their authorised representative, “are not registered in that Member State.”
• An authorised representative in each country. Article 45(3): a producer that ships directly to end users in another member state “shall appoint, by written mandate, an authorised representative for the extended producer responsibility in each Member State where the producer makes packaging or packaged products available for the first time, other than the Member State where the producer is established.” Its next sentence adds that member states “may provide” that producers established in third countries appoint one, so for sellers outside the EU each country’s own rules matter.

ZSVR says that on 12 August 2026 the PPWR and the new German Packaging Law Implementation Act (VerpackDG) “replaced the existing German Verpackungsgesetz (Packaging Act)”, and that companies abroad which “have, until now, been able to appoint an authorised representative on a voluntary basis” are now “obliged to do so.”

Etsy’s Germany article, last edited the day before, still names the Packaging Act (VerpackG) as Germany’s packaging law and says the PPWR “will apply in Germany alongside Germany’s national packaging framework.” The register it names (LUCID) and its representative rule match ZSVR’s pages. The law it names doesn’t, and it leaves out ZSVR’s rule that you register in LUCID yourself.

Etsy’s France article doesn’t mention an authorised representative at all, while its Germany and Spain articles do. Nothing in Article 45(3) limits it to particular member states. If you ship packaged goods to French buyers from outside France, ask your French PRO or ADEME what it means for you, rather than reading the gap in Etsy’s article as an exemption.

How does the authorised representative work in Germany?

A seller based abroad without a German branch must now have one authorised representative in Germany, who takes over the EPR obligations under a written contract in German. You still register in LUCID yourself, and the representative has to be named before that registration can be completed. The details, from ZSVR’s page on authorised representatives:

• You still register yourself. The representative takes over the EPR obligations “with one exception: registration in the LUCID Packaging Register. This is a personal duty that you have to fulfil yourself.”
• Name the representative when you register. A new registration can’t be completed without one. Sellers already registered get a pop-up after logging in asking for it.
• One representative only, based or with a branch in Germany, and not affiliated with your company.
• A written agreement in German, signed by both sides by hand or with a qualified electronic signature. If there are versions in other languages, the German one is binding.
• The representative needs its own LUCID login and ID before you can select it. Its appointment takes effect when it confirms in LUCID, and you get an email.
• It costs money: “authorised representatives charge fees for their services”, and ZSVR doesn’t publish a list of them.

Once appointed, the representative handles the rest: the system participation contract, volume reports and declarations of completeness in LUCID. ZSVR also notes that LUCID is down for maintenance on 10 November 2026, from 09:00 to about 18:00.

Why does Etsy have to collect the numbers?

Because the PPWR puts the check on the marketplace. Under Article 45(4), online platforms “shall obtain” two things from a producer offering packaged products to EU consumers, “prior to allowing those producers to use their services”: its registration number in the buyer’s member state, and a self-certification that it meets its EPR duties there.

Article 45(6) adds that the platform must make “best efforts” to check the information is complete and reliable. ZSVR states the consequence for Germany: “Without this evidence, or if there are any irregularities, the packaged products may not be offered on the online platform.” LUCID is a public register, so a platform can check a number against it.

Article 45(4) also lets a marketplace, “on the basis of written mandate”, pay a producer’s EPR contributions on its behalf. None of Etsy’s three articles mentions it. They describe the seller registering and joining a scheme. The PPWR also requires producers to give the same information to fulfilment service providers (Article 45(7)). ZSVR says a fulfilment service provider that isn’t the manufacturer of your shipping packaging must get it before serving you, and must stop serving you if missing information isn’t fixed in time.

Who is the producer when the box carries your brand?

You are, under the brand rule on ZSVR’s online-retail page: “If you have another party design or manufacture packaging under your name, logo or brand and you use that packaging to ship your products, you are considered both the manufacturer and producer under the PPWR,” wherever the supplier is based.

The same page has a narrow exception for micro-enterprises (under ten employees and no more than €2 million in turnover or balance sheet). There, a supplier of finished shipping packaging based in the same member state as the micro-enterprise counts as manufacturer and producer instead.

Plain packaging doesn’t get you out of it. If you assemble plain boxes, tape and filler yourself, ZSVR says you are the manufacturer and the producer of that packaging.

What do you have to tell buyers?

All three articles set a buyer-facing duty, and they place it differently. Germany wants return and recycling information somewhere visible, such as shop policies. Spain names no place. France wants the EPR number itself shown to buyers, plus a recycling return route for some categories. Each article’s wording:

• Germany: return and recycling information for the packaging, EEE and batteries you sell, “in a visible location, such as the seller’s shop policies, Message to Buyers, or terms and conditions.”
• Spain: information “about the return, collection, and recycling” of the packaging, EEE or batteries. The article names no place to put it.
• France: the EPR number itself “should also be displayed in a location visible to buyers, such as your shop policies or Message to Buyers.” For some categories, “such as electrical and electronic equipment (EEE) and certain chemical products”, you must also offer a way to return used products for recycling. For furniture, toys, sports and leisure goods and DIY and gardening goods, that applies only above an annual turnover threshold. Etsy’s article doesn’t give the figure.

The Germany and Spain articles also say “additional labeling, marking or take-back requirements may also apply”, without listing them.

A checklist if you ship to Germany, France or Spain

1. List what you ship to each country: packaging always, plus EEE, batteries, and in France textiles, toys, furniture, sports and DIY goods.
2. Register in each country’s register for each category. In Germany, register in LUCID yourself, even if you use a representative.
3. Shipping to Germany from abroad? Sign up an authorised representative first. LUCID won’t complete a registration without one. Etsy’s Spain article requires one too.
4. Join a Dual System or PRO to pay for the recycling.
5. Enter each number in Etsy under Finances → Legal and tax information.
6. Add the buyer information to your shop policies or Message to Buyers (and your French EPR number).

EPR is one of several EU rules that reach Etsy sellers outside the EU. Product-safety contact details have their own Etsy fields, covered in our post on Etsy’s GPSR fields. Words like “eco-friendly” in a listing fall under a separate directive, explained in our post on the green-claims rules. Customs charges on EU orders are in our post on the €3 duty and €2 handling fee. If you are revising listings for EU buyers anyway, the free generator at /generate drafts a title, 13 tags and a description from a short product description.