Amazon says it may comply on my behalf. Is Amazon then my German representative?

No. A representative needs a written mandate in German and must be named in your LUCID entry and confirmed by ZSVR.

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

Quick answer

No. Amazon's help page says that if you are found to be non-compliant, it may need to deactivate your listings or comply with the regulations on your behalf. That describes what Amazon may do as a platform. A German authorised representative is something else: appointed by a written mandate in German (§ 5(4) VerpackDG), named in your LUCID entry and confirmed by ZSVR (§ 5(5)). Amazon signs no such mandate with its sellers.

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