By Razvan Toma · Founder · Last checked 4 October 2026 · Sources linked below
Quick answer
No, they are two separate steps. Registration is your own duty: § 5(2) VerpackDG excludes it from what a representative takes over, and ZSVR calls it strictly personal. Appointing a representative is separate: a written mandate in German (§ 5(4)), then the representative named in your LUCID entry and confirmed there. For a company based abroad both are needed, and LUCID will not complete the registration without the representative. Sources (3)
VerpackDG § 5VerpackDG § 5
ZSVR helpZSVR help — Authorising a representativeZSVRZSVR — Bevollmächtigung
More on who needs a representative
- I only send a few items a year to Germany. Does German packaging law still apply?
- I also sell electronics in Germany. Is that the same registration as packaging?
- Does a German representative also cover my sales to other EU countries?
- Can I avoid German packaging law by not selling to Germany?
- Can the ZSVR act as my German authorised representative?
- Is there an official list of German authorised representatives?