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 now reporting that this is changing, for example in this r/Printify thread on EU requirements. If your provider no longer covers the packaging that goes to your German or French customers, the duty to register and report it sits with you as the seller.

This guide explains what that means in practice and how to get the one number every scheme asks for: how many kilograms of each packaging material you actually 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 which date, and check your obligations with the register or a compliance adviser.

Why the duty lands on the seller

Packaging EPR (extended producer responsibility) rules make 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.

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 registration and a dual system

Germany’s Packaging Act (VerpackG) has two separate steps, and you need both:

1. Register in LUCID, the public packaging register run by the Zentrale Stelle Verpackungsregister. Registration is free and gives you a registration number. It applies to sellers abroad too, if they ship packaged goods straight to consumers in Germany.
2. Sign a contract with a dual system (a licensed take-back scheme). You estimate the packaging you will put on the German market, by material, and pay the system to collect and recycle it.

The quantities you report to LUCID must match what you report to your dual system. Marketplaces and many partners ask for your LUCID number, and selling without registration is not allowed.

Dual system contracts usually run per calendar year. If your provider’s cover stops at the end of the year, plan to have your own registration and contract in place before you ship to Germany in the new year.

France: Citeo and a unique identifier

France works in a similar way under its own EPR rules. Businesses that put household packaging on the French market join an approved producer responsibility organisation, most commonly Citeo, declare their packaging by material and pay a contribution.

Membership comes with a unique identification number (UIN). Sellers are expected to show that number to customers, for example in their terms of sale or on their website. Sellers based outside France may also need an authorised representative there, so check this point early.

The number both schemes ask 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 question 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 the 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 you a figure that is far too high or too low for the 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 one 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.
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 year of orders where you can, so seasonal peaks even out.
4. Multiply and add up. Units times packaging weight, summed per material and per country, gives you the kilograms to declare.
5. Keep the working. Save the packaging weights and order counts behind your figures. If your numbers are questioned, you can show how you got them.

You can do this in a spreadsheet from an order export. The hard part is keeping it correct as products, packaging and order volume change, and repeating it each time you report.

Showing your registration numbers

Once you are registered, customers and partners may want to see your numbers. Germany’s LUCID number and France’s UIN are both identifiers you can display openly, typically in your store’s legal pages or footer, so that anyone checking your shop can find them.

A checklist before you ship into the new year

• Read your print-on-demand provider’s notice and note exactly what it stops covering, and when.
• Register in LUCID and get your registration number.
• Choose a dual system for Germany and sign a contract for the coming year.
• Join Citeo, or another approved organisation, for France if you ship there, and get your UIN.
• Work out kilograms per material for Germany and for France from your shipped orders.
• Report the same figures to LUCID that you give your dual system.
• Show your registration numbers on your store.

How StoreFleet: Packaging EPR helps

We built StoreFleet: Packaging EPR for shops selling into the EU that need these figures without rebuilding a spreadsheet each time. It is a free Shopify app that turns your shipped Shopify orders into packaging EPR figures: kilograms per material and per destination country, for Germany (LUCID and dual systems) and France (Citeo). It also shows your EPR registration numbers on your storefront.

Registering in LUCID, signing with a dual system and joining Citeo are still steps you take with those organisations. The app gives you the numbers to bring to them.

Try StoreFleet: Packaging EPR