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Answer · Who is the producer
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I sell to a German retailer that resells my goods. Am I the producer?

Usually the German retailer, because it initiates the supply chain to end users in Germany. ZSVR's supply-chain test.

By Razvan Toma · Founder · Last checked 4 October 2026 · Sources linked below

Quick answer

Usually not you. ZSVR's test: the producer is the economic operator that initiates the supply chain in the member state where the packaging becomes waste. If a German retailer or distributor buys your goods and resells them to end users in Germany, it is normally the producer, and you need no German registration or representative for those sales. If you also sell directly to German end users, those sales make you the producer.

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Selling into Germany from abroad?

The new EU packaging law (PPWR) has applied since 12 August 2026. Four questions tell you whether it makes you appoint a representative in Germany — including when it does not.

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