Print-on-Demand Sellers: Your Own LUCID and Citeo Packaging Duties

If you sell print-on-demand products through Printify or Printful on Shopify, you probably never thought about packaging law. The provider printed the shirt, put it in a mailer and shipped it, and packaging compliance in Germany looked like something that came with the service.

Sellers are reporting that this is changing, for example in this r/Printify thread on EU requirements. At the same time the rules themselves changed: the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, known as PPWR) has applied since 12 August 2026, and Germany replaced its Packaging Act with a new implementing law on the same day.

This guide explains where the duty sits for a print-on-demand shop, what Germany and France ask for now, and how to get the one number every scheme needs: how many kilograms of each packaging material you ship to each country.

This article is general information, not legal advice. Read your provider’s own notice for exactly what it covers and from when, and check your obligations with the register, your scheme or a compliance adviser.

What changed on 12 August 2026

PPWR is a regulation, so it applies directly in every EU country. It repealed the old Packaging Directive from that date. For a small online seller, these parts matter most:

PPWR rule	What it means for you
Producer definition (Article 3)	A seller in another EU country or outside the EU who ships packaged products directly to end users in a country is a producer there.
Registration (Article 44)	You register in the producer register of each EU country where you make packaging available, and may not sell there without it.
Authorised representative (Article 45)	If you are established in another EU country, you appoint an authorised representative for EPR in each country you ship to, by written mandate. Countries may require the same of sellers outside the EU.
Reporting (Article 44)	Data on the previous calendar year is reported by 1 June. Below 10 tonnes a year in a country, a shorter set of data applies. Countries may ask for quarterly reports.
Online platforms (Article 45)	Marketplaces must collect your registration information before they let you sell.

Some PPWR rules come later and depend on implementing acts that are not all adopted yet. The harmonised sorting label applies from 12 August 2028 at the earliest, and the 50% maximum empty space in e-commerce packaging from 1 January 2030 at the earliest (Articles 12 and 24). The empty-space rule falls on whoever fills the parcel, which in print-on-demand is usually your provider.

For a broader look at the regulation, see our guide to PPWR for Shopify sellers.

Why the duty lands on the seller

Packaging EPR (extended producer responsibility) makes the business that puts packaged goods on a market pay for collecting and recycling that packaging. In a print-on-demand setup, the customer buys from your store, under your brand. Even though you never touch the parcel, you are usually treated as the business placing that packaging on the market.

Germany’s register operator says this plainly for mail order: a foreign seller shipping directly to German end users is at minimum the manufacturer and producer of the shipment packaging it uses, whether it sits in another EU country or outside the EU.

Where a provider had arranged packaging cover for its sellers, that question stayed hidden. Once the cover ends, every seller shipping into these countries has to answer it alone.

Germany: LUCID, a dual system and a representative

On 12 August 2026 the PPWR and Germany’s new Packaging Law Implementation Act (VerpackDG) replaced the old Packaging Act. The register is still LUCID, run by the Zentrale Stelle Verpackungsregister (ZSVR). For an online seller the steps are:

1. Register in LUCID, with all your brand names. You get a registration number.
2. Sign a contract with a dual system (system participation) before your first sale. Shipment packaging, including boxes, bags, labels, tape and filler, always needs system participation.
3. Report your data in LUCID: material type and weight, the same figures you give your dual system.
4. Appoint an authorised representative if you are not established in Germany. The representative takes over your packaging duties except the LUCID registration, which stays with you.

The transition dates are set in § 68 VerpackDG:

• Registrations made under the old law stay valid, but changes the new law requires must be made by 12 November 2026. Check brand names, packaging types and representative details now.
• Sellers newly required to register under the new law had to do so by 12 September 2026.
• Dual system contracts signed before 12 August 2026 end on 31 December 2026 at the latest. Plan a new contract for 2027.

Marketplaces and fulfilment providers must check your LUCID registration before they work with you. If a platform turns your number down, our guide on a rejected LUCID registration number lists the usual causes.

France: an eco-organisation, an IDU and a mandataire

France runs packaging EPR under its Environmental Code. If you sell packaged goods to consumers in France, you join an approved eco-organisation for household packaging, most commonly Citeo, declare your packaging and pay a contribution.

• Unique identifier (IDU). Once you join, ADEME issues a 15-character unique identifier per EPR scheme. You show it in your terms of sale and on your website, and give it to the marketplaces you sell through.
• Declaration. Citeo’s 2026 tariff guide sets the declaration window from January to the end of February for the previous year, so packaging placed on the market in 2026 is declared in early 2027. Below 10,000 consumer sales units (UVC) a year you pay a flat €110 excl. VAT; between 10,000 and 500,000 a simplified declaration applies; above that you declare per unit.
• Shipping boxes count. In Citeo’s guide, the product’s packaging is one UVC and the shipping carton is another.
• Mandataire. Since 10 July 2026, a producer not established in France must appoint, by written mandate, a person established in France who takes over its EPR obligations. The article sets out when a marketplace that already covers your products meets this for you.

The number every scheme asks for: kg per material, per country

Whatever the scheme, the core question is the same: how much paper and cardboard, how much plastic and how much of any other material did you ship to this country?

For a print-on-demand shop, that is harder than it sounds:

• You don’t pack the parcels. The mailer, box or poly bag is chosen by the provider, sometimes differently per product or print facility.
• Products differ. A mug in a box with filler is a very different packaging weight from a T-shirt in a poly mailer.
• Destinations are mixed. Only orders shipped to Germany count for LUCID, and only those shipped to France count for Citeo.
• Seasons distort short samples. A busy November does not look like a quiet March. A few weeks of orders can give a figure far off the real year.

A practical way to estimate

1. List your packaging types. Ask your provider, or check a sample parcel, which packaging each product type ships in. Weigh each component and split it by material: cardboard box, paper filler, plastic mailer, label.
2. Map products to packaging. Note which packaging each product or product type ships in, and what changes when an order has several items in one parcel.
3. Count shipped units by country. From your shipped orders, count how many units of each product went to Germany and to France. Use a full calendar year where you can.
4. Multiply and add up. Units times packaging weight, summed per material and per country, gives you the kilograms to declare. The free packaging weight EPR calculator does this sum for one country at a time and exports it as CSV.
5. Keep the working. Save the packaging weights and order counts behind your figures, so you can show how you got them.

You can do this in a spreadsheet from an order export with one row per line item. Our step-by-step guide to packaging weight per material from Shopify orders shows the full calculation. The hard part is keeping it correct as products, packaging and volume change.

Checklist for the rest of 2026

• Read your provider’s notice and note exactly what it stops covering, and when.
• Check your LUCID entry: brand names, packaging types and, if you are abroad, your authorised representative.
• Sign a dual system contract for 2027 before the current one ends.
• If you sell to France, join Citeo or another approved eco-organisation, get your IDU and appoint a mandataire if you are established abroad.
• For other EU countries you ship to, check each national register and whether you need a representative there.
• Work out kilograms per material for each country from your shipped orders.
• Show your registration numbers on your store and give them to your marketplaces.

FAQ

Does Printify or Printful cover my packaging EPR?

Only your provider can answer that for your account, and sellers report that cover is changing. Read the provider’s current notice. If it does not name your country, your registration and your packaging, plan to cover them yourself.

I’m based outside the EU. Does PPWR apply to me?

If you ship packaged products directly to consumers in an EU country, PPWR treats you as a producer there, whether you are established in the EU or not. Germany and France both require sellers established abroad to appoint a representative.

Is my old LUCID registration still valid?

Yes. Registrations made under the old Packaging Act carry over, but changes required by the new VerpackDG must be made by 12 November 2026. Log in and check your entry.

Do shipping boxes and mailers count?

Yes. In Germany shipment packaging always needs system participation. In France Citeo counts the shipping carton as its own unit.

Where do I show my registration numbers?

Your French IDU goes in your terms of sale and on your website. You can show your LUCID number the same way, for example in the footer or legal pages, and marketplaces ask for both.

How Grammo: Packaging EPR Report helps

Grammo: Packaging EPR Report is a Shopify app on the Shopify App Store that turns your shipped orders into kilograms per destination country and material, counted per shipment. You record each packaging component’s material, set shipping rules for multi-item orders and export tables, LUCID XML and Citeo-ready sheets, plus a per-country view in PPWR material categories. It also shows your registration numbers on your store. You stay the declarant: registering, signing contracts and declaring are steps you take with those organisations. Install it from the Shopify App Store.