By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below
Yes. § 5(4) VerpackDG requires a schriftliche Vollmacht in deutscher Sprache: a written mandate in German, given when you first make packaging or packaged products available in Germany. A translation next to the German text helps you read it, but the German version is the one that counts. § 6(2) VerpackDG then asks for the written mandate as part of your LUCID registration. Sources (2)
VerpackDG § 5VerpackDG § 5VerpackDG § 6VerpackDG § 6
German EPR authorised representative mandate in German: what must it contain?
§ 5(4) VerpackDG fixes the form: a written mandate in German. § 5(2) and (3) and § 6(2) fix what it has to cover. A mandate that ZSVR and your representative can work with contains:
| Clause | Why |
|---|---|
| Your company name, address, tax number and a person who can represent it | The same details go into your LUCID registration (§ 6(2) nos. 1 and 3) |
| The representative's name, address, contact details and register number | Entered in your registration (§ 6(2) nos. 2 and 4) |
| The duties handed over: all your obligations under the VerpackDG and Chapter VIII PPWR, except registration | § 5(2) requires this scope; registration stays with you |
| That the representative acts in its own name | § 5(3): it counts as the producer for those duties |
| Exclusivity: no other representative | § 5(4): one representative per producer |
| Your duty to supply figures: brands, packaging types, quantities by material | Needed for registration (§ 6(2) nos. 5 and 6), the licence (§ 7) and data reports (§ 9) |
| Costs: dual-system fees and how they are passed on | The representative licenses in its own name |
| Start, term, notice and reporting the end to ZSVR | § 5(6) and § 6(1): an end is reported without delay |
| A language clause: the German text governs | § 5(4): the mandate is in German |
Can I sign a German EPR mandate with a qualified electronic signature?
Yes. A qualified electronic signature (QES) is the only electronic way that counts as written. The steps in German law:
- Written form means a handwritten signature. § 126(1) BGB: where the law requires written form, the document must be signed by hand.
- Electronic form can replace it. § 126(3) BGB: written form can be replaced by electronic form unless a law says otherwise. The VerpackDG does not exclude it.
- Electronic form means a QES. § 126a(1) BGB: the signer adds their name and signs the electronic document with a qualified electronic signature.
- EU-wide. Article 25(2) eIDAS: a QES has the same legal effect as a handwritten signature, and a QES from one member state is recognised in all others (Article 25(3)).
| Signature | Accepted for the mandate? |
|---|---|
| Handwritten, on paper or a printed copy, then scanned | Yes |
| Qualified electronic signature (QES) | Yes |
| Advanced electronic signature (AES) | No |
| Simple e-signature: typed name, drawn signature, tick box, most standard e-signing envelopes | No |
BGB § 126 BGB § 126a 
Regulation (EU) No 910/2014 VerpackDG § 5
Getting a QES
A QES needs a qualified certificate from a qualified trust service provider, usually after an identity check by video or in person. Many e-signing platforms offer it as a separate, higher signature level; the standard level on those platforms is a simple signature and does not count. If the signer has no QES yet, signing by hand is faster: print the signature page, sign it, scan it and send it.
Language, signer and upload
- Language. A bilingual mandate is fine, with the German text governing. A mandate only in English does not meet § 5(4).
- Signer. Someone who can bind your company, such as a managing director listed in your company register entry, or a person holding a power of attorney from them.
- Upload. The written mandate is part of your LUCID registration (§ 6(2) no. 2(b)). You upload it when you name the representative; the representative then confirms.
Our mandate is bilingual, German and English, and covers every clause above: authorised representative in Germany.
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