By Razvan Toma · Founder · Last checked 4 October 2026 · Sources linked below
Quick answer
Yes, if your company has no establishment in Germany. A dual-system licence covers system participation (§ 7 VerpackDG); the duty to appoint a representative is separate (§ 5(2)), and LUCID asks for both. Once a representative is appointed, it takes over system participation in its own name for your packaging (§ 5(3)), so agree with your representative how your existing contract is handled for the rest of its term. Sources (3)
VerpackDG § 5VerpackDG § 5VerpackDG § 7VerpackDG § 7
ZSVR helpZSVR help — Authorising a representative
More on who needs a representative
- I only send a few items a year to Germany. Does German packaging law still apply?
- I also sell electronics in Germany. Is that the same registration as packaging?
- Does a German representative also cover my sales to other EU countries?
- Can I avoid German packaging law by not selling to Germany?
- Can the ZSVR act as my German authorised representative?
- Is there an official list of German authorised representatives?