By Razvan Toma · Founder · Last checked 3 October 2026 · Sources linked below
Yes. Being in the EU does not exempt you. Since 12 August 2026, Article 45(3), first sentence, PPWR requires a producer established in one member state to appoint an authorised representative in each other member state where it sells directly to end users, and § 5(2), sentence 1, VerpackDG applies that in Germany. This covers sellers in France, Austria, Poland, the Netherlands, Italy, Spain and every other EU country with no establishment in Germany. Sources (3)
VerpackDG § 5VerpackDG § 5
Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)
ZSVRZSVR — Bevollmächtigung
What changed for EU sellers
Before 12 August 2026, appointing a German representative was optional for a company in another EU country; it could register and license in Germany itself. Since the PPWR applies, it is a duty for anyone selling directly to German end users without an establishment there. You still register in LUCID yourself.
When you do not need one
If your company has a Niederlassung in Germany, or you sell only to a German importer or retailer that resells the goods, you do not. A warehouse in Germany run by someone else, such as Amazon's, is not an establishment.
The mandate
The appointment is a written mandate in German (§ 5(4) VerpackDG), and ZSVR confirms it in LUCID. For Austrian companies German is the working language anyway; for everyone else ours comes with an English translation alongside the binding German text.