Is my German representative legally treated as the producer?

Q: Is my German representative legally treated as the producer?

Yes, for the duties it takes over. § 5(3) VerpackDG says the authorised representative counts as the producer for the obligations it performs, and it performs them in its own name. That is why it concludes the dual-system licence and files the reports itself. Registration in LUCID stays with you: § 5(2) excludes it from what the representative takes over.

Yes, for the duties it takes over. § 5(3) VerpackDG: the representative counts as producer for those duties and acts in its own name.

Since 12 August 2026, § 5 VerpackDG, implementing Article 45(3) of Regulation (EU) 2025/40, requires a producer with no establishment in Germany to appoint an authorised representative before it first makes packaging available in Germany. Read § 5

By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below

Quick answer

Yes, for the duties it takes over. § 5(3) VerpackDG: the authorised representative counts as the producer for the obligations it performs, and it performs them in its own name. So it concludes the dual-system licence and files the reports itself. One duty stays with you: registration in LUCID, which § 5(2) excludes from the mandate. VerpackDG § 5

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