Razvan Toma is the founder of EPR Germany Rep and of EPR France Rep, the French sister service. He reads the statutes and the regulator's own guidance directly, and publishes what they say — including when it means telling a visitor they do not need to buy anything.
Razvan on LinkedIn ↗What we do
We act as Bevollmächtigter für die erweiterte Herstellerverantwortung under VerpackDG § 5(2) for companies that sell packaged goods into Germany and have no German establishment. €149 a year for packaging, no setup fee, dual-system participation passed through at the scheme’s own rate. We also run open datasets on what this market charges, when the statutory dates fall, and which bodies are approved to recover packaging.
Our commercial interest, stated
We are one of the providers in our own price table. A comparison written by a competitor is worth nothing unless you can check it, so every competing row links to that provider’s own published page and our price sits in the same table under the same headings. We publish no ranking and we do not claim to be „best“. The one claim we do make is checkable: ours is the lowest published annual price in a dataset we date and source.
How we source
- Primary law first. VerpackDG and the Kreislaufwirtschaftsgesetz from gesetze-im-internet.de; Regulation (EU) 2025/40 and Commission proposals from EUR-Lex. Quoted in German, with a translation, never paraphrased into a claim.
- The competent authority second. The Zentrale Stelle Verpackungsregister for anything about LUCID, registration, roles and fulfilment.
- Providers only for their own prices, read from their own pages on a stated date.
- No provider marketing as a source for law. Not ours either.
- Where something is unsettled we say so rather than picking the convenient reading. Two examples live on the site: whether a shipping label makes a seller the Erzeuger, where ZSVR and the Commission FAQ differ, and whether § 9 reporting moves with the mandate, which is our reading of § 5(1)–(3) and is labelled as one.
Corrections
Every dataset carries a changelog and a last-checked date; every guide carries a Rechtsstand line. If a figure here is wrong, tell us and we will change it and log the change: hello@eprgermanyrep.com. Text and data on this site are reusable under CC BY 4.0 with attribution to eprgermanyrep.com.
Legal entity
Stated plainly because we ask you to check it of every provider, including us: our German business address is Rudolfplatz 3, 50674 Köln, and the company registration is still in progress. VerpackDG § 5(2) requires a Bevollmächtigter to have a Sitz or Niederlassung in Germany, so until the registration is entered and appears in our Impressum with its Handelsregister number, ask us where it stands before you commit. We would rather you hear that from us than find it out later — we answer it in writing.