As our partner Internetrecht (=Internet law) Rostock reported, a clear regulation will be in place from 1 July 2022 for fulfilment service providers, to which Amazon in particular belongs, if in the context of FBA Amazon the merchandise is dispatched to the customer:
“If the activities of a fulfilment service provider include the packaging of goods in system-participating shipping packages, the distributor of the goods for whom the fulfilment service provider is acting will be deemed to be the manufacturer as far as the shipping packages are concerned.”
This means that in future, every Amazon seller must be registered with the Central Packaging Register in the LUCID database and must also participate in a disposal system. Exceptions, which were previously possible if the sales packaging was registered to the manufacturer, but the seller does not make shipments in any case, are then no longer possible.
Amazon will probably request registration data from the Central Packaging Register (in the LUCID database) from all Amazon sellers using FBA as part of Extended Producer Responsibility (EPR). Distribution without LUCID database registration will then no longer be possible via FBA from 1 July 2022.”
The take-e-way consultancy team will be glad to answer any questions you may have on the Packaging Act. Please call +49/40/750687-0 or send an e-mail message to firstname.lastname@example.org.