By Razvan Toma · Founder · Last checked 4 October 2026 · Sources linked below
Quick answer
In practice you cannot sell lawfully, and marketplaces notice first. ZSVR says a company that must appoint a representative cannot complete its LUCID registration without naming one. Without a completed registration, marketplaces cannot verify you and may block your listings. A producer that is not properly registered may not make packaging available in Germany (§ 13(1) VerpackDG), and not registering, or not correctly, is an administrative offence (§ 66(1) no. 1). Sources (4)
ZSVR helpZSVR help — Authorising a representative
VerpackDG § 13VerpackDG § 13VerpackDG § 66VerpackDG § 66VerpackDG § 5VerpackDG § 5
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?