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Drop shipping in online retail: who needs to do what?

Are you a drop shipper? Selling third-party products to customers for your own account, but not shipping these products yourself? If you are, then you have obligations under German packaging law to comply with. On this page, we will explain what you need to do.

Drop shippers sell products without keeping them in stock ('drop shipping seller'). Instead, they forward orders to a third-party supplier, who then ships the products directly to the customer ('drop shipping sender'). While drop shippers sell the goods for their own account, they never physically touch them.

Packaging law obligations in drop shipping

  • Drop shippers are not considered producers under the Verpackungsgesetz (Packaging Act) because they are not the first to place packaging filled with goods on the German market.

  • Drop shippers do not have to register with the LUCID Packaging Register for the products they are selling. They also do not have to conclude a system participation agreement or report their packaging volumes (data reporting).

  • Drop shippers selling packaged goods via a marketplace have to provide evidence of the drop shipping sender fulfilling their packaging law obligations.

  • Drop shippers are required by law to verify that their contractual counterparty, i.e. the drop shipping sender,

    • is registered with the LUCID Packaging Register,

    • meets the system participation requirement for the shipment packaging by paying for that packaging’s recycling.

Heads-up: The drop shipping sender may also have obligations related to retail or grouped packaging. This applies if the drop shipping sender is the manufacturer of the goods and is the first to commercially place the packaged goods on the German market or if the drop shipping sender is the importer of the packaged goods.

If a drop shipper sells an international company's goods to customers in Germany, the sender of the goods is always responsible.

Mail order companies and online retailers

Mail order companies and online retailers use shipment packaging to send their goods. They are required to pay for the recycling of this packaging and to check whether they bear responsibility for other packaging as well.

Fulfilment service providers

Fulfillers handle tasks for other companies, including managing warehouses, packaging orders, labelling shipments and shipping the goods.

Registration

Every company that distributes packaged good commercially on the German market or imports packaged goods into Germany has to register with the LUCID Packaging Register, regardless of where in the world that company is based.

System participation & data reporting

The following obligations apply to packaging subject to system participation: you will need to register with the LUCID Packaging Register, conclude a system participation agreement and regularly report packaging volumes (data reporting).

Please refer to the support contact page for more information.

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