By Razvan Toma · Founder · Last checked 3 October 2026 · Sources linked below
Usually you, not the Alibaba supplier. Alibaba is a business-to-business marketplace: the supplier sells to you. Under German packaging law the producer is whoever first makes the packaged goods available to end users in Germany. If your company sells them on to German buyers, the LUCID registration, the dual-system licence and, if you have no establishment in Germany, the German authorised representative are yours. Sources (3)ZSVRZSVR — manufacturer vs producer
VerpackDG § 5VerpackDG § 5
VerpackDG § 7VerpackDG § 7