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Answer · Who needs a representative
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Who is responsible for packaging EPR in Germany for print-on-demand?

Usually the shop owner, as the seller the customer buys from, not the print provider. Register in LUCID, license the packaging, and appoint a German representative if you have no establishment there.

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 9 November 2026 · Sources linked below

Quick answer

Usually the shop owner. The print provider makes and ships the item, but the customer buys from you, so you make the packaged goods available in Germany.

  1. Ask the provider for the packaging it uses per item: material and weight.
  2. Register in LUCID under your company name and brands.
  3. License those weights with a dual system.
  4. No German establishment: appoint an authorised representative.
If the provider offers to license packaging for you, check in writing whose name the licence is in.

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Selling in Germany?

Your German authorised representative from €149 a year: help with your LUCID registration, dual-system contract and annual report included. No setup fee.

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