EPR used to be a matter between brands and national environmental authorities. That changed when the EU required marketplaces to take an active role in enforcement. Now Amazon, Zalando, Otto, and other platforms are the front line of EPR compliance — and they can suspend your account faster than any regulator can issue a fine.
Here's how marketplace enforcement actually works.
The 2018 German Packaging Act (VerpackG) was the first EU legislation to make marketplace operators legally responsible for the EPR compliance of their sellers. Under §3 and §9 of the VerpackG, marketplaces that "enable third-party sellers to place packaging on the German market" must verify that those sellers are registered in LUCID.
If a marketplace knowingly allows non-compliant sellers to list, the marketplace itself can be liable. That's why Amazon, as the largest EU marketplace, built compliance verification directly into its seller onboarding and account management systems.
The PPWR (Article 47) extends this principle EU-wide from August 2026. All major EU marketplaces must now verify producer registration numbers across all EU markets, not just Germany.
Amazon requires all sellers listing on Amazon.de to provide their LUCID registration number in Seller Central. This is enforced in two ways:
At onboarding: New sellers can't complete listing setup on Amazon.de without entering a LUCID number. The system flags accounts that skip this.
Ongoing cross-checks: Amazon periodically cross-references seller-provided LUCID numbers against the public LUCID database (which the ZSVR makes available). If a LUCID number is invalid, expired, or doesn't match the seller's account name, Amazon suspends the affected listings.
What to do in Seller Central:
Go to Settings → Account Info → EPR Information, then select Germany and enter your LUCID registration number in the format DE followed by digits (e.g., DE1234567890).
Amazon France requires your Citeo contributor number for B2C packaging. Without it, Amazon.fr listings are restricted.
From January 2026, Citeo Pro numbers may also be required for B2B/FBA sellers whose inventory moves through Amazon's French fulfilment centres.
Amazon has progressively added EPR registration number requirements across its EU marketplaces:
| Marketplace | EPR System | Required Number |
|-------------|-----------|-----------------|
| Amazon.de | LUCID (Germany) | DE + digits |
| Amazon.fr | Citeo (France) | Citeo contributor number |
| Amazon.it | CONAI (Italy) | CONAI producer code |
| Amazon.es | Ecoembes (Spain) | SRAP registration number |
| Amazon.co.uk | UK EPR (not EU, different rules) | UK PRN/PERN |
Belgium, Netherlands, and Austria have not yet had dedicated Amazon enforcement fields added in Seller Central, but this is expected to change in 2026 as the PPWR mandates uniform marketplace enforcement.
Missing number: No LUCID number on file → listing restriction, usually within 30 days of the requirement being flagged on your account.
Invalid number: The LUCID database check returns "not found" or "inactive" → immediate suspension of affected ASINs.
Mismatched entity: The company name on your LUCID account doesn't match your Amazon seller entity → suspension pending verification.
Expired compliance: LUCID registration that has lapsed (not renewed) or where a PRO contract has ended → listings suspended.
What Amazon does NOT check (yet): Whether your reported packaging volumes match your actual sales volumes. Amazon verifies registration, not fee accuracy. If you under-report to your PRO, that's between you and the PRO — Amazon won't catch it via Seller Central.
Zalando introduced EPR compliance requirements for fashion and lifestyle brands selling in Germany in 2022. Zalando checks LUCID numbers for German sellers and has progressively extended requirements to French and Austrian sellers. Non-compliant brands receive automated email warnings before suspension.
Zalando also requests documentation of PPWR compliance for new product categories, particularly for brands selling accessories and apparel with significant plastic packaging.
Otto follows a similar model to Amazon for German EPR compliance. LUCID numbers are required in the Otto seller portal. Otto's enforcement is slightly less automated than Amazon's — in practice, there's usually a 30–60 day warning period before suspension.
FNAC Darty, MediaMarkt, Bol.com: Other EU marketplaces have been slower to implement systematic enforcement, but this is changing. PPWR Article 47 creates an EU-wide obligation that will force all significant marketplaces to implement compliance verification by mid-2026.
If you use Amazon's FBA service, your inventory sits in Amazon warehouses across EU countries. The EPR obligation is yours, not Amazon's — you remain the producer and are responsible for EPR compliance in each country where your inventory is stored or sold.
The practical implication: if you store FBA stock in Amazon's German, French, and Italian warehouses, you have EPR obligations in Germany, France, and Italy — regardless of which country your customers actually order from.
This surprises many FBA sellers. The act of moving inventory into an EU country triggers producer status for that country. Registration must precede the inventory movement, not just the first sale.
For brands selling on multiple EU marketplaces, the priority is:
If you're already suspended: get your LUCID number, re-enter it in Seller Central, then contact Amazon Seller Support to request reinstatement. Reinstatement usually takes 2–5 business days once a valid number is on file.
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For a full breakdown of enforcement consequences by country, read What happens if you miss an EPR deadline?