Selling into Germany from abroad? A new German law applies.
Since 12 August 2026, the EU Packaging Regulation (PPWR, Article 45(3)) and § 5 VerpackDG require a company with no German establishment that supplies packaged goods directly to end users in Germany to appoint an authorised representative. EPRGermanyRep is that representative (AR).
Since 12 August 2026, the EU Packaging Regulation (PPWR, Regulation (EU) 2025/40, Article 45(3)), applied in Germany through § 5 VerpackDG, requires a company with no establishment in Germany that supplies packaged goods directly to end users in Germany — consumers or businesses that use the goods — to appoint an authorised representative by written mandate in German. ZSVR states that no exemption from this duty is possible. Your LUCID registration stays with you: German law makes it a strictly personal duty that cannot be delegated. Sources (3)
ZSVRZSVR — Bevollmächtigung
VerpackDG § 5VerpackDG § 5
Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)
Three rules now apply to every seller from abroad
German packaging law, the EU Packaging Regulation and marketplace checks all reach companies that ship to German customers from abroad.
German law, since 12 August 2026
§ 5 VerpackDG requires a company with no German establishment that supplies German end users directly to appoint an authorised representative by written mandate. ZSVR: no exemption is possible.
→EU packaging regulation, since 12 August 2026
PPWR Article 45(3) requires producer registration in each member state you sell into and an authorised representative for cross-border sales to end users.
→Marketplace checks
Amazon, Etsy, eBay, Kaufland and OTTO ask for your LUCID registration number before you sell to German buyers.
→Built for companies selling into Germany from abroad
Amazon, Etsy and eBay sellers
Marketplaces check your LUCID number before you can sell to German customers. We are the representative behind it.
Learn more →Sellers outside the EU
UK, Swiss, Chinese and US companies shipping to German customers. The duty applies to you in every version of the rules.
Learn more →Sellers from other EU countries
Your registration at home does not cover Germany. Selling directly to German end users makes you a producer there.
Learn more →Your own online shop
Shopify, WooCommerce or any shop that ships to Germany: no platform checks you, but the law is the same.
Learn more →Compliant in three steps, LUCID and dual system included
Sign the mandate, send your packaging estimate
Sign the written mandate (§ 5(4) VerpackDG) by hand, upload it in your client portal and enter your estimated packaging per material: paper, plastics, glass.
Register in LUCID and appoint us
Register your company in LUCID, the German packaging register (free, about ten minutes), and name EPRGermanyRep as your authorised representative. We confirm the appointment.
You are compliant
We license your packaging with a dual system in our name, at cost, and file your volume reports to the system and to LUCID. LUCID and the dual system are included.
A German company, at a German address
| Legal name | EPRGermanyRep GbR |
| Legal form | Gesellschaft bürgerlichen Rechts (GbR) |
| Registered address | Im Mediapark 5, 50670 Köln, Germany |
| Trade registered | Gewerbemeldestelle Köln, 1 October 2026 |
| LUCID authorised-representative ID | DE8516653799349 |
Your German EPR compliance, all in one place
Every client gets a personal dashboard: your LUCID status, the mandate, your packaging volumes, the reports we file and every document.
Registered, representative named, confirmed by the ZSVR.
Upload the signed § 5(4) mandate; we countersign it.
Enter your estimate per material; we license it with a dual system at cost.
We file your volume reports and tell you what we need, and when.
Answer your German EPR questions in minutes
Do I need a German EPR representative?
2-minute interactive check
→German EPR deadlines
Every statutory date, with its source
→Provider price verification
Every source, with the date it was read
→Provider prices
What every representative charges
→Dual-system licence rates
Verification status and the operators’ own tools
→LUCID market size
How many producers are registered, counted
→Simple, transparent pricing
One flat fee a year, whatever your volume: the same €149 at 50 parcels or 50,000, so growing never moves you to a higher tier. No setup charge. Dual-system licence fees are passed through at cost, with no markup.
| Pricing | |||
|---|---|---|---|
| Named as your representative in LUCID | |||
| Dual-system participation, contracted in our name | |||
| Written German mandate (VerpackDG § 5(4)) | |||
| EPR regimes covered | Packaging | Packaging | Packaging, batteries, electricals |
| Licence fees (dual system) | At cost, 0% markup | At cost, 0% markup | At cost, 0% markup |
| Annual volume reporting | |||
| Declaration of completeness when required | |||
| B2B transport packaging: we tell you what falls under § 39 | |||
| ZSVR correspondence | |||
| Client dashboard | |||
| Compliance monitoring — we tell you when the rules change | |||
| Priority support | — | ||
| Marketplace support (Amazon, eBay, Kaufland) | |||
| Step-by-step guides: LUCID registration, packaging weights, lower licence fees | |||
| Batteries (BattG) representation | +€500 a year | +€500 a year | +€500 a year |
| Electricals (ElektroG) representation | +€500 a year | +€500 a year | +€500 a year |
Straight answers to what foreign sellers ask
I sell on Amazon. Do I need EPR in Germany?
Yes. Submit your 13-digit LUCID number in Amazon's “Compliance Information for Extended Producer Responsibility” portal and license your packaging with a dual system. If your company has no establishment in Germany, you also need a German authorised representative since 12 August 2026. FBA does not change that.
Read the answer →I sell on Etsy. Do I need EPR in Germany?
Yes, from the first parcel to a buyer in Germany. Register yourself in LUCID, license your packaging with a dual system and add your LUCID number in Etsy under Shop Manager › Finances › Legal and tax information. If your shop is not based in Germany, you also need a German authorised representative since 12 August 2026.
Read the answer →I am a seller from outside the EU (UK, US, Switzerland, China…). Do I need a German EPR representative?
Yes, if you sell packaged goods directly to end users in Germany and have no establishment there, whether you are in the UK, the US, Switzerland, China or anywhere else outside the EU. You still register in LUCID yourself. If you only sell to a German importer or retailer that resells, that company is the producer instead.
Read the answer →Is registering in LUCID the same as appointing a representative?
No. Registration in LUCID is your own, strictly personal duty and stays with you even when you have a representative (§ 5(2) VerpackDG). Appointing a representative is a separate step: a written mandate in German, the representative named in your LUCID entry and confirmed. The representative then handles licensing, reports and correspondence.
Read the answer →I have already licensed my packaging with a dual system. Do I still need a representative?
Yes, if your company has no establishment in Germany and sells directly to end users there. The licence covers system participation (§ 7 VerpackDG); the representative duty is separate (§ 5(2)). With a representative, the licence moves into its name: it concludes system participation in its own name for your packaging.
Read the answer →What happens if I sell into Germany without an authorised representative?
If you are required to have one, your LUCID registration cannot be completed without naming it, so marketplaces cannot verify you and may block your listings. A producer that is not properly registered may not make packaging available in Germany at all (§ 13(1) VerpackDG), and failing to register correctly is an administrative offence under § 66.
Read the answer →Frequently asked questions
Who needs a German EPR representative?
When did the duty start?
Does my German customer's status change the answer?
Is a representative the same as registering in LUCID?
What does it cost?
Selling into Germany from abroad?
Your German authorised representative from €149 a year: help with your LUCID registration, dual-system contract and annual report included. No setup fee.