By Razvan Toma · Founder · Last checked 4 October 2026 · Sources linked below
Quick answer
No, if your company is required to have one. ZSVR states it plainly: if you must appoint an authorised representative under the new rules, “you must name this authorised representative when you first register”, and “if you do not provide this information, you will not be able to complete your registration”. The practical order is: choose a representative and sign the written mandate, then register in LUCID and select them. The same applies if an existing German company moves its registered office abroad. Sources (2)
ZSVR helpZSVR help — Authorising a representative
VerpackDG § 5VerpackDG § 5
More on lucid and licensing
- Can a marketplace or a service provider register me in LUCID?
- Do I have to license the shipping box, filling and tape too?
- When do I have to report my packaging volumes in Germany?
- Why is LUCID asking me to appoint an authorised representative?
- Do I need to re-register in LUCID because of the PPWR or the VerpackDG?
- Which dual system do I have to use in Germany?