{"id":6423,"date":"2026-04-28T13:00:00","date_gmt":"2026-04-28T11:00:00","guid":{"rendered":"https:\/\/ekopro-grupa.pl\/?p=6423"},"modified":"2026-04-07T14:10:42","modified_gmt":"2026-04-07T12:10:42","slug":"lucid-a-dropshipping","status":"publish","type":"post","link":"https:\/\/ekopro-grupa.pl\/en\/lucid-a-dropshipping\/","title":{"rendered":"LUCID and dropshipping"},"content":{"rendered":"

LUCID versus dropshipping, fulfillment and Amazon FBA - who is responsible for packaging and registration?<\/strong><\/h1>\n\n\n\n
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When selling to Germany, the key principle is simple: LUCID's obligations are not the responsibility of the person who physically packs the parcel as a service provider, but as a matter of principle the one who places the packaging containing the goods on the German market as an obliged entity<\/strong>. The ZSVR emphasises that any company that commercially distributes packaged goods in Germany or imports packaged goods into Germany must be registered with the LUCID Packaging Register<\/strong>, irrespective of the country of establishment. If packaging is covered by the participation scheme, there are two further obligations: to conclude an agreement with the dual system and to report packaging quantities on a regular basis. In e-commerce, this very often concerns shipment packaging<\/strong>, a shipping package that, according to the ZSVR, almost always ends up as waste to a private end user.<\/p>\n\n\n\n

LUCID vs dropshipping - when a seller does not have to register<\/strong><\/h2>\n\n\n\n

In the classic dropshipping model, the situation is unique, as the ZSVR indicates explicitly that the drop shippers are not considered manufacturers within the meaning of the Verpackungsgesetz<\/strong>, as they are not the first to market a package filled with goods in Germany. For this reason, the dropshipping seller does not have to register with LUCID for the products it sells under this model<\/strong>, does not also enter into a contract with the system and does not report the volumes of these packages. This, however, does not mean a complete absence of obligations, as the ZSVR imposes a statutory due diligence obligation on such a seller: it must verify that its counterparty, i.e. the actual dropshipper, is registered with LUCID and that it finances the recycling of the shipping packages.<\/p>\n\n\n\n

LUCID and fulfilment - who is responsible when packages are packed by a logistics operator
<\/strong><\/h2>\n\n\n\n
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With fulfillment, accountability works differently than many vendors assume. The ZSVR defines fulfillment as a model in which a service provider performs two or more activities, such as warehousing, order packing, labelling and shipping, without owning the goods. At the same time, the authority explicitly points out that when the fulfilment provider packs the goods for shipment packaging<\/strong> for the principal, it is ordering dealer or distributor<\/strong> must fulfil the packaging law obligations for that package. The fulfillment provider itself therefore does not take over the registration and licensing obligation for the customer, but is obliged to verify that its customer is registered with LUCID and complies with the participation system obligation; if not, it should not provide services for it. In addition, the fulfillment provider is to provide the customer with data on the volumes of packaging used so that the customer can report the weights correctly.<\/p>\n\n\n\n

Amazon FBA vs LUCID - why the mere fact that Amazon is packing does not exempt the seller<\/strong><\/h2>\n\n\n\n

In practice Amazon FBA<\/strong> fits into the logic of fulfilment, as Amazon stores the goods, picks the orders, packs them and ships them to customers, while the seller remains the product owner and party to the sale. This follows from the official FBA description, according to which Amazon \u201estores, picks, packs, and ships orders\u201d, and the ZSVR definition of fulfilment. From this juxtaposition, it follows that in the FBA model, the seller should not assume that responsibility for LUCID automatically shifts to Amazon simply because Amazon physically prepares the shipment. From the perspective of German packaging law, the obligations for the shipping package still essentially fall on the ordering party<\/strong>, i.e. the seller using the fulfilment service. In other words: if you are selling to Germany via Amazon FBA, the safest and official ZSVR logic assumption is that you are responsible for registering with LUCID, the participation system and reporting on the shipping packages used for your orders. This is the conclusion from combining the ZSVR fulfillment definition with Amazon's official description of how FBA works.<\/p>\n\n\n\n

Frequently asked questions<\/strong><\/p>\n\n\n

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Does dropshipping exempt you from LUCID?<\/strong><\/h3>\n
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\u00a0In classic dropshipping, the seller is not recognised as a manufacturer within the meaning of VerpackG for these products, so he does not register with LUCID on this account. However, he must check that his counterparty fulfils the registration and system obligations.<\/p>\n\n<\/div>\n<\/div>\n

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Does the fulfilment operator take over LUCID's responsibilities for the online shop?<\/strong><\/h3>\n
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No. The ZSVR indicates that with fulfillment it ordering party<\/strong>, i.e. the commissioning vendor, is to fulfil the obligations for the shipping package, while the operator merely verifies compliance and transmits the data on package weights.<\/p>\n\n<\/div>\n<\/div>\n

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Does Amazon FBA exempt from registration with LUCID?<\/strong><\/h3>\n
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There is no basis for assuming this. Amazon FBA operates as a fulfilment model, and according to the ZSVR, with such a model the shipment packaging responsibilities remain with the seller ordering the service. This is the conclusion of the official definition of fulfilment and how FBA works.<\/p>\n\n<\/div>\n<\/div>\n

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Who is responsible for shipping packaging to Germany?<\/strong><\/h3>\n
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As a general rule, the obliged party that introduces such packaging into the German market. With ordinary e-commerce and fulfilment, the ZSVR indicates that the responsibility for shipment packaging most often lies with the seller or distributor and not with the logistics service provider itself.<\/p>\n\n<\/div>\n<\/div>\n

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With fulfillment, do you only have to register with LUCID or do you have to enter into a contract with the system?<\/strong><\/h3>\n
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If the packages used are included in the participation scheme, you have to do three things: register, enter into a contract with the dual system and report volumes.<\/p>\n\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n\n\n

You have doubts as to whether, in your sales model dropshipping, fulfillment or Amazon FBA<\/strong> means an obligation to register with LUCID<\/strong> and accounting for packaging in Germany? Contact us Ekopro Group<\/strong> will help you assess your packaging liability, sort out your obligations and answer your questions about BDO, LUCID and cross-border sales. Go to \u201eContact\u201d<\/a><\/strong> and make use of our support.<\/p>\n\n\n\n

<\/p>","protected":false},"excerpt":{"rendered":"

When selling into Germany, the key principle is simple: it is not the one who physically packages the package as a service provider who is responsible for LUCID obligations, but as a general rule the one who places the packaged goods on the German market as an obligated party. The ZSVR emphasises that any company that commercially distributes packaged goods in Germany or imports packaged goods into Germany must be registered in the LUCID Packaging Register, irrespective of its country of establishment<\/p>","protected":false},"author":2,"featured_media":6424,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_kad_blocks_custom_css":"","_kad_blocks_head_custom_js":"","_kad_blocks_body_custom_js":"","_kad_blocks_footer_custom_js":"","_kadence_starter_templates_imported_post":false,"_kad_post_transparent":"","_kad_post_title":"","_kad_post_layout":"","_kad_post_sidebar_id":"","_kad_post_content_style":"","_kad_post_vertical_padding":"","_kad_post_feature":"","_kad_post_feature_position":"","_kad_post_header":false,"_kad_post_footer":false,"_kad_post_classname":"","footnotes":""},"categories":[4],"tags":[107],"class_list":["post-6423","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-baza-wiedzy","tag-lucid-a-dropshipping"],"taxonomy_info":{"category":[{"value":4,"label":"Baza wiedzy"}],"post_tag":[{"value":107,"label":"LUCID a dropshipping"}]},"featured_image_src_large":["https:\/\/ekopro-grupa.pl\/wp-content\/uploads\/2026\/04\/image-50.png",1024,1024,false],"author_info":{"display_name":"Jakub Nalewa","author_link":"https:\/\/ekopro-grupa.pl\/en\/author\/jakub-nalewa\/"},"comment_info":0,"category_info":[{"term_id":4,"name":"Baza wiedzy","slug":"baza-wiedzy","term_group":0,"term_taxonomy_id":4,"taxonomy":"category","description":"","parent":0,"count":195,"filter":"raw","cat_ID":4,"category_count":195,"category_description":"","cat_name":"Baza wiedzy","category_nicename":"baza-wiedzy","category_parent":0}],"tag_info":[{"term_id":107,"name":"LUCID a dropshipping","slug":"lucid-a-dropshipping","term_group":0,"term_taxonomy_id":107,"taxonomy":"post_tag","description":"","parent":0,"count":1,"filter":"raw"}],"_links":{"self":[{"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/posts\/6423","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/comments?post=6423"}],"version-history":[{"count":1,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/posts\/6423\/revisions"}],"predecessor-version":[{"id":6426,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/posts\/6423\/revisions\/6426"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/media\/6424"}],"wp:attachment":[{"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/media?parent=6423"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/categories?post=6423"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/tags?post=6423"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}