By Razvan Toma · Founder · Last checked 3 October 2026 · Sources linked below
Quick answer
Not if someone else runs it. § 5(2) VerpackDG asks whether your company has an establishment (Niederlassung) in Germany. Stock held in Amazon's warehouse or a logistics provider's is not your establishment. A company based abroad that sells through FBA or a German 3PL still needs a German authorised representative. Sources (2)VerpackDG § 5VerpackDG § 5
ZSVRZSVR — Bevollmächtigung