By Razvan Toma · Founder · Last checked 3 October 2026 · Sources linked below
Yes, if you sell packaged goods directly to end users in Germany and your company has no establishment there. This covers sellers in the United Kingdom, the United States, Switzerland, China and every other country outside the EU. Since 12 August 2026 you must appoint a German authorised representative (Bevollmächtigter) before selling. You still register in LUCID yourself; the representative takes over everything after that. Sources (3)
VerpackDG § 5VerpackDG § 5
Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)
ZSVRZSVR — Bevollmächtigung
Why non-EU sellers are covered twice over
§ 5(2) VerpackDG has two sentences. Sentence 1 applies to producers under Article 45(3), first sentence, PPWR: those selling directly to end users in a member state where they are not established, wherever they are based. Sentence 2 is the option Article 45(3), second sentence, gives member states for producers established in third countries, and Germany took it up. For a seller in the UK, the US, Switzerland or China, both point the same way.
The UK is a third country for EU law since Brexit; Switzerland is in neither the EU nor the EEA.
When you do not need one
If you sell only to a German importer, distributor or retailer that resells the goods, that company makes them available to end users and is the producer. ZSVR applies the representative duty to companies abroad that sell directly to end users in Germany. Selling on Amazon.de, Etsy, eBay or your own shop to German buyers is selling directly.
The mandate
The appointment is a written mandate in German (§ 5(4) VerpackDG), and ZSVR confirms it in LUCID. Ours comes with an English translation alongside the binding German text.