Does a German representative also cover my sales to other EU countries?

No. The representative duty runs per member state: a German representative covers Germany only.

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

Quick answer

No. The duty runs per country. Article 45(3) PPWR requires an authorised representative in each member state where you make packaging available for the first time and are not established. A German representative covers your obligations under German law, the LUCID register and the German dual systems. Other countries you sell to have their own registers and their own rules.

More on who needs a representative

All answers →

Selling into Germany from abroad?

The new EU packaging law (PPWR) has applied since 12 August 2026. Four questions tell you whether it makes you appoint a representative in Germany — including when it does not.

Free 2-minute check →Get started