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Do I need a German EPR representative?
Germany does not ask where you are established and stop there. It asks who initiates the German supply chain. Four questions, based on the regulator's own test.
This follows the two-step method ZSVR publishes for distinguishing a manufacturer from a producer, and the domestic-precedence rule that decides who is the producer in Germany. Sources (3)
ZSVRZSVR — manufacturer vs producer
VerpackDG § 5VerpackDG § 5
Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)
Frequently asked questions
What makes a company 'established' in Germany?
A registered branch or a German company. A warehouse, a fulfilment centre or a logistics provider is not an establishment, which is why Amazon FBA sellers storing stock in Germany are still caught by the duty.
I sell only to German businesses. Do I still need a representative?
If those businesses resell your goods, they become the producer and you generally do not. If they use the goods themselves they are end users, and you do. The packaging type then changes what you pay, not whether you need the mandate.
I already have a LUCID number. Am I finished?
No. Holding a registration does not satisfy VerpackDG § 5(2). Existing registrants must file the change naming a representative by 12 November 2026 under § 68(2).
Can I appoint more than one representative?
No. VerpackDG § 5(4) allows exactly one representative per producer, and the appointment must be made by written power of attorney in German. Changing representative means ending the existing mandate first.
Selling into Germany from abroad?
The new EU packaging law (PPWR) has applied since 12 August 2026. Four questions tell you whether it makes you appoint a representative in Germany — including when it does not.