What EPR numbers does Otto ask for before you can sell in 2026?

This guide sets out which EPR numbers Otto ask for before they will let you sell, which registrations German law requires even though Otto never mention them, and how long each one takes to obtain. It also settles why the answer is always German paperwork, wherever your company is registered.

EPR is short for extended producer responsibility, the German rules that make you pay for recycling the packaging and electrical goods you sell. Otto collect your answers at step seven of the application to join otto.de, before your first product goes live. It covers every seller Otto accept, in all six of their permitted countries.

The company test you clear before EPR comes up

Otto decide who may apply before they ask anything about waste. Their published requirements set five conditions, and a company that fails any of them never reaches the EPR questions at all.

1. Your registered office is in Germany, the Netherlands, Poland, Austria, France or Spain. No other country of establishment is accepted.
2. Your legal form is on their list, which runs from GmbH and UG through B.V., Sp. z o.o., SAS and S.L.
3. You hold your own VAT ID from that same country. A group VAT ID does not work, and Otto say plainly that the VAT ID of a parent entity cannot be used.
4. You are in the OSS scheme if you are established anywhere other than Germany, using your home country's VAT ID for it.
5. You are not a small business under § 19 UStG. Otto exclude them from the marketplace outright.

That last one matters more than it looks. On most marketplaces the smallest sellers are the ones who assume producer responsibility is for bigger companies. At Otto that group is not on the platform in the first place, so nobody reaching the EPR questions has a size argument to fall back on.

Before you start on the registrations themselves, have four things in front of you.

• The packaging you ship, broken down by material and weight per unit.
• Your product list, with anything that plugs in, charges or contains a battery flagged separately.
• Every brand name you sell under, because two of the German registers are keyed to brands rather than to companies.
• Your company registration details and the name of whoever is legally authorised to represent you.

Why every Otto seller registers in Germany

Otto's marketplace is otto.de, and their own terms of sale settle where it reaches. Deliveries are in principle only possible within Germany, with two postcodes excluded. They also require you to offer German-speaking customer service. There is one destination, and it surprises people who have sold on other marketplaces.

Compare that with the rest of the marketplace world. On Amazon, eBay or Kaufland the seller is usually in one country and the customers are spread across several, so the registrations multiply by destination.

Otto turn that around. There is a single destination and six permitted seller countries, so the thing that varies is where you sit, not where your buyers are.

Producer responsibility follows the buyer rather than the seller. Under the EU packaging regulation you register in each member state where you first make packaging available, and you may not make it available there at all unless you are registered. Your Dutch, Polish, Austrian, French or Spanish registration is not the one Otto need. It covers a market Otto do not sell into.

Read that the right way round, because the wrong way round is expensive. The six countries are where your company may be based. They are not markets you can cover with one German registration.

If you also sell into other countries through your own shop or another marketplace, each of those countries has its own register, its own number and its own deadlines, and nothing you do for Otto touches them. And if your company is based outside the six, the question never arises, because Otto will not take your application in the first place.

The same regulation is why the question comes up during onboarding rather than after your first sale. Platforms that let consumers buy from third-party sellers have to obtain the seller's registration in the member state where the consumer is located, plus the registration number in that register, before allowing the seller to use the service.

They also have to make a genuine effort to check that what they were given is complete and reliable. That is what Otto's individual application review is doing.

Step 1. Work out which of Otto's three declarations apply to you

Otto's mandatory information list carries three items that touch producer responsibility, plus one that only looks like it does. Read them apart from each other, because they ask for three different things.

The fourth item on Otto's list asks whether you hold an FSC certification number. FSC is a forest-certification scheme. It is not a producer register, no German waste law requires it, and answering no to it has nothing to do with your EPR position.

The take-back question is the one that gets answered wrongly most often, and the reason is a measurement. The duty falls on distributors whose sales area for electrical goods reaches 400 square metres, or food retailers whose total sales area reaches 800 square metres, where they offer electrical goods more than once a year or permanently.

An online seller has no shop floor, so it reads like an automatic no.

It is not. The law applies the same test to distance selling, and for a distance seller it counts all your storage and dispatch areas for electrical goods in place of a sales floor. One reasonably large warehouse puts you over the line without a single square metre of retail space.

If you are over it, two duties follow.

1. Like for like on delivery. You take back one old device of the same kind, free of charge, when you deliver a new one.
2. Small devices on request. You take back old devices under 25 centimetres in every external dimension, free, with no purchase required and a limit of three per device type.

For a distance seller the free collection covers equipment categories 1, 2 and 4. The rest is handled through return points within reasonable reach of the customer.

Step 2. Register with the ZSVR and check the paragraph numbers

Your packaging registration goes to the Zentrale Stelle Verpackungsregister, which runs the LUCID register. It is free, it has to be done before you first make packaging available in Germany, and it cannot be handed to anyone else. Even a foreign producer who is now required to appoint an authorised representative has to keep this one registration in their own hands.

Our walk-through of the LUCID registration covers the form itself.

Then there is a wrinkle in Otto's own paperwork that is worth knowing about before you go looking things up.

Otto's form asks about system participation "according to §7 VerpackG" and registration with the ZSVR "according to §9 VerpackG". The Verpackungsgesetz stopped applying on 12 August 2026. It was replaced by the EU packaging regulation together with a German implementing act, the VerpackDG, and the paragraph numbers did not all survive the move.

System participation is still § 7, so that half of Otto's citation still lands where they meant it to. Registration moved to § 6. And § 9 now exists again as something else entirely, the data reports you file after you have joined a system.

So a seller who reads Otto's form and looks up § 9 today finds a reporting duty, and concludes reasonably enough that Otto are asking about something they have not done yet.

None of this changes what you owe. The registration, the system participation and the reporting all survived the change intact, and an existing LUCID registration carried over automatically. Changes to an existing registration are due by 12 November 2026.

There is one group with a date already behind them. If you were newly caught by the rules and had never been required to register before, the deadline was 12 September 2026, so the registration is overdue and the fix is to file it now rather than to wait for a new window.

Step 3. Join a dual system and keep both halves live

Registering with the ZSVR does not license your packaging. It records who you are.

The second half of the duty is joining a dual system, which is the scheme that actually collects and recycles what you ship and charges you for it. Otto's question bundles the two together, so you need both before you can answer it honestly.

The order matters. You register first, because the system needs your registration number to sign you up. You then tell the system the material types and masses you expect to place on the market, and they confirm the participation back to you.

After that the reporting runs on its own rhythm. The same figures you give the system go to the register, and small producers get a lighter version of it. If you place under 10 tonnes a year you report once, by 1 June of the following year, instead of reporting every time you send figures to your system.

One trap on the packaging side is worth naming now rather than later. Registration and system participation have to stay matched. If you add a brand, change materials or move a large volume between systems and only update one of the two records, the register and the system stop agreeing with each other, and it is the register that Otto and everyone else can see.

Step 4. Start the electronics registrations first

If anything you sell plugs in, charges or runs on a battery, this is the step to begin on the day you apply, because it is the only one with other work stacked in front of it.

Electrical equipment is registered with stiftung ear, and their own guidance sets out three things that make it slower than the packaging side.

1. It is per brand and per device type. stiftung ear require a separate application for each brand and each type of equipment you place on the market, so a catalogue that looks like one product line can be five registrations.
2. Household equipment needs an insolvency-proof guarantee attached to the application. You arrange that with a bank, a credit insurer or an approved guarantee system before you can apply, and arranging it is not instant.
3. A producer with no German establishment cannot register itself. You appoint an authorised representative, in writing and in German, and the representative carries the registration. Finding and appointing one is another lead time in front of the first one.

Once the registration is approved you get a WEEE-Reg.-Nr. DE, and German law requires you to state it when you offer equipment and on your invoices. That is also the number Otto's third question is asking for.

There is a hard consequence behind the question, which is why Otto ask it. Where a producer is not properly registered, the law forbids marketplace operators from letting that producer's electrical equipment be offered at all. Otto are not applying their own policy there. They are avoiding a statutory prohibition on themselves.

Step 5. Fill in Otto's declarations and keep them true

Otto collect all of this at step seven of a ten-step onboarding, under company information, alongside your tax details and the seller name that will appear on the site. Steps one to six are the application, the portal invitation, two-factor setup, the contracts and the legitimation check, and the legitimation check alone can take up to fifteen business days.

That gives you a usable planning window. The packaging registration is free and can be done immediately. The electronics side cannot, so the sequence that works is to start the WEEE and battery registrations on the day you apply and let them run while Otto are checking your company.

The declarations are also not a one-off. They describe your position at the moment you answer them, and that position moves whenever your range does.

Three ordinary changes are enough to make an answer out of date.

1. Adding your first kettle to a clothing catalogue. That creates a WEEE registration you did not have, and pushes you toward the take-back threshold.
2. Selling a cordless version of the same kettle. That adds a battery registration on top.
3. Growing past 10 tonnes of packaging. That changes when you report.

Otto's form will not ask you again, so a short annual re-read of your own answers is the cheapest control you can put on this.

Where Repax fits when the register is in another country

Getting registered is paperwork you do once per stream. What repeats afterwards is the reporting, and for a seller established outside Germany that repeat has an awkward shape. Your product data is organised the way your home market wants it, and the German registers want German cuts of the same products, in German categories, on German dates.

Repax Core is built for exactly that gap. You describe each product once, broken down to its materials and components, and pull your sales data in through your existing systems. The report then comes out in the shape the filing wants, so one product record can serve a Dutch filing and a German one without being rebuilt twice.

The limits are worth stating plainly. Core prepares the data behind a filing. It does not submit to a register and it does not obtain your number, and on the German packaging side it could not, because the law reserves that registration to you personally. Comply is the Repax product that files, under a power of attorney, across EU markets.

What Otto's form does not ask about

Otto's three questions are not a checklist of German producer responsibility. They are a checklist of the things German and EU law require a platform to check, which is a narrower list. The difference is visible in the statutes.

Otto have never published why their form stops where it does, but the pattern fits the law precisely. Where a statute puts the checking duty on a marketplace, Otto ask. Where it does not, they are silent, and their silence is not permission. Four gaps follow from that.

1. Batteries need their own registration and nothing on Otto's form will remind you. If batteries are among the things you make available in Germany, you register with stiftung ear per brand and per battery category, and you may not make them available until you are. Budget for it early, because the registration counts as granted twelve weeks after you have supplied everything asked for.
2. Single-use plastics have a separate register and a separate agency. Food containers, beverage containers and cups, lightweight carrier bags and wet wipes fall under the single-use plastics fund, which is run by the Umweltbundesamt through its own DIVID platform rather than by the ZSVR. You register before you start trading and report by 15 May each year.
3. The take-back question is not the WEEE question. They are two separate items on Otto's list for a reason. You can owe take-back with no WEEE registration, if you distribute other people's registered equipment at scale, and you can hold a WEEE number and still be under the take-back threshold. Answering one as if it covered the other leaves a false declaration on your file.
4. Textiles have no German scheme to join yet. If you sell clothing, there is currently nothing to register for, and the German act that would change that is still being drafted. This is the one gap where the honest answer today is that the duty does not exist rather than that it is hiding.

Frequently asked questions about EPR numbers for Otto

Below are the five questions sellers ask most often about EPR numbers on Otto.

How long does this take?

The packaging registration is same-day and free. The electronics side is the constraint, and a battery registration counts as granted twelve weeks after complete information, so start those the day you apply to Otto.

Can Otto register on your behalf?

No. Otto collect your declarations, they do not obtain numbers for you. German packaging registration in particular is reserved to the producer personally, and no service provider or fulfilment partner is permitted to do it.

Do you need German numbers if your company is Dutch or Polish?

Yes. Otto's customers are in Germany, and producer responsibility follows the buyer. Your home registration covers a market Otto do not sell into, so it does nothing for your application.

What happens if a declaration turns out to be wrong?

Otto's checks are one layer, and the statutory bans sit underneath them. A marketplace may not let listings run for unregistered electrical equipment, so an incorrect answer can cost you the listings whether or not Otto spot it first.

Can Repax do this for you?

Repax Core prepares the product and packaging data every German filing asks for and keeps it reproducible. It does not register you and it does not file, so the registrations in this guide stay yours.