Does a German VAT number make my company established in Germany?

Q: Does a German VAT number make my company established in Germany?

No. A German VAT registration is a tax status, not an establishment. § 5(2) VerpackDG asks whether your company has an establishment (Niederlassung) in Germany. A company with a German VAT number but no seat or branch in Germany still has to appoint a German authorised representative before it first makes packaging available there.

No. A VAT registration is a tax status. § 5(2) VerpackDG asks whether your company has an establishment (Niederlassung) in Germany.

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

No. A German VAT registration is a tax status, not an establishment. § 5(2) VerpackDG applies to producers that have no establishment (Niederlassung) in Germany, and a VAT number does not create one. A company with a German VAT number but no seat or branch in Germany still appoints a German authorised representative before it first makes packaging available there. The same goes for stock in a warehouse run by someone else. VerpackDG § 5

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