EU packaging rules (PPWR) apply since 12 August 2026 · day 53Check if it applies to you →
PPWR · since 12 Aug 2026 · Check if it applies to you →
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I buy on Alibaba and sell in Germany. Who is the producer?

Usually you. Whoever first makes the packaged goods available to German end users is the producer, not the Alibaba supplier.

By Razvan Toma · Founder · Last checked 3 October 2026 · Sources linked below

Quick answer

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.

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