Amazon.de compliance checklist for brands outside the EU
To sell on Amazon.de from outside the EU you usually need ten things: German VAT if your stock is in Germany, customs, packaging registration and a PPWR representative, WEEE and battery registrations for electrical products, an EU responsible person, safety documentation, a German label and listing, and a plan for product liability. No single provider handles all of them.
By Konstantin Filin, Director · Last reviewed: 8 October 2026
Ten items, and who usually handles each
German law and EU law ask for different things, from different people. Marketplaces turn several of them into fields in Seller Central: without a registration number or a responsible person, a listing can be blocked.
| # | Item | Who usually handles it |
|---|---|---|
| 1 | German VAT registration | A tax adviser or VAT agent |
| 2 | Customs and import | Your freight forwarder and customs broker |
| 3 | Packaging registration (LUCID) and a packaging scheme | You, with a packaging compliance scheme |
| 4 | Authorised representative for packaging (PPWR) | A representative established in Germany |
| 5 | WEEE registration | An authorised representative established in Germany |
| 6 | Battery registration | An authorised representative or compliance provider for Germany |
| 7 | EU responsible person | An EU-established responsible person |
| 8 | Product safety documentation | You and your manufacturer; an accredited laboratory where tests are required |
| 9 | Label and listing, with warnings in German | You; your responsible person checks it |
| 10 | Product liability from 9 December 2026 | Your EU importer and your authorised representative, alongside you |
Which of them apply to you depends on your products and on where your stock is. Our two-minute check builds the list from nine answers.
What each item means in practice
German VAT registration
If your goods are stored in Germany — in Amazon fulfilment centres or another warehouse — you will usually need a German VAT number before the first sale from that stock, and the marketplace will ask for it. Stock in several EU countries usually means a VAT number in each of them. Rules for marketplaces and imports change often; this is a map, not tax advice, and a tax adviser should confirm your case.
Customs and import
Goods entering the EU are declared to customs, and someone is named on the declaration as importer. You need an EORI number to be that someone. Since 1 July 2026 the €150 customs duty exemption has ended: every consignment under €150 shipped directly to an EU consumer carries a €3 duty per tariff line. Your freight forwarder and customs broker set this up; it changes your landed cost and decides whether there is an importer in the EU.
Packaging registration (LUCID) and a packaging scheme
Anyone who first puts packaged goods into circulation for consumers in Germany registers in the German packaging register, LUCID, and joins a packaging compliance scheme that pays for collecting that packaging. This includes shipping boxes and fillers. German law requires online marketplaces to check the registration, so a listing without it can be blocked.
Authorised representative for packaging (PPWR)
Since 12 August 2026 the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, Article 45(3)) requires a producer that is not established in a member state to appoint, by written mandate, an authorised representative for packaging in each member state where it makes packaging available for the first time. For Germany, that is a company established in Germany. If your goods reach consumers from other EU countries, each of them needs its own.
WEEE registration
Electrical and electronic products — including anything with a battery or a plug — must be registered in Germany with Stiftung EAR before they are sold. A producer without a company in Germany registers through an authorised representative established in Germany. Marketplaces must check the registration number.
Battery registration
Batteries, including batteries built into a product, must be registered in Germany with Stiftung EAR before sale, under German battery law and the EU Batteries Regulation (Regulation (EU) 2023/1542). A producer outside Germany usually acts through an authorised representative or compliance provider there. Products that plug into the mains but contain no battery may not need this; check each product.
EU responsible person
Under Article 16 of the General Product Safety Regulation (Regulation (EU) 2023/988), a product can be placed on the EU market only if an economic operator established in the EU is responsible for it. If an EU company imports your goods, it can take that role. If you sell directly from outside the EU, there is usually no importer, and you appoint an authorised representative by written mandate. Its name and contact details, including a postal and an electronic address, go on the product, its packaging, the parcel or an accompanying document, and on the listing. One responsible person covers the whole EU. See what an EU responsible person does and what it costs.
Product safety documentation
As manufacturer, you carry out an internal risk analysis and keep technical documentation for each product (Article 9 GPSR), for ten years. Products under specific EU rules — electrical products, for example — also need a declaration of conformity and test reports, where those rules require them. The documents are yours and your manufacturer's; an accredited laboratory runs tests where they are required. Your responsible person keeps them available and hands them to the authorities on request.
Label and listing, with warnings in German
The product, or where that is not possible its packaging, must show a type, batch or serial number; the manufacturer's name, trade name or trademark, postal and electronic address; and the EU responsible person's name and contact details (Articles 9 and 16 GPSR). Instructions and safety information must be in a language consumers in the country easily understand — for Amazon.de, German. The online listing must show the same identification and safety information (Article 19 GPSR). You prepare the label and the listing; your responsible person checks them against the regulation.
Product liability from 9 December 2026
The new Product Liability Directive (Directive (EU) 2024/2853) applies to products placed on the market from 9 December 2026. For a manufacturer outside the EU, Article 8(1)(c) makes both the importer and the manufacturer's authorised representative liable for damage caused by a defective product, without prejudice to the manufacturer's own liability; a fulfilment service provider is liable only where there is neither. Liability towards an injured person cannot be excluded by contract. It is worth knowing who your importer and your representative are, and what your mandate says.
What Altex does, and what it does not
- We do: act as the EU responsible person and authorised representative for brands outside the EU (item 7), and check your documentation, labels and listings against GPSR (items 8 and 9).
- We do not: register you for VAT, packaging, WEEE or batteries; act as packaging, WEEE or battery representative; handle customs; test or certify products; or give tax advice.
If you want this list for your own catalogue, product family by product family, see the Compliance Map.
FAQ
Is there one provider that does all ten?
Not usually. VAT is tax work; packaging, WEEE and battery representatives must be established in Germany; testing is done by laboratories. The EU responsible person can be anywhere in the EU.
Does the EU responsible person have to be in Germany?
No. One economic operator established in any EU member state covers all 27. The German representatives for packaging, WEEE and batteries are separate roles.
Is Amazon my responsible person?
No. Online marketplaces have their own obligations under Article 22 GPSR. They ask you to name your responsible person; they do not take that role.
I sell only on Amazon.de. Do the other EU countries matter?
For the EU responsible person, no — one covers the whole EU. For VAT and packaging, they can: if your stock or your shipments reach consumers from other EU countries, registrations there may apply as well.