By Razvan Toma · Founder · Last checked 7 October 2026 · Sources linked below
A representative in each country: in Germany for your packaging, in France for your packaging and your clothing. Since 12 August 2026 a Spanish company selling directly to consumers in Germany, with no German establishment, must appoint a German authorised representative; France has required a representative from companies established elsewhere since 10 July 2026. Being in the EU does not exempt you in either country. Sources (3)
VerpackDG § 5VerpackDG § 5
Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)Code de l'environnement, artCode de l'environnement, art. L. 541-10-9-1
Germany: packaging only
For a clothing shop the German duty is about packaging: the box or mailer, tape, labels and filling. You register in LUCID yourself, which is free, and name your representative there; the representative licenses your packaging with a dual system and files the reports. Clothes themselves have no separate German register. See LUCID registration, step by step.
France: packaging and clothing
France regulates clothing as its own category, with its own collection scheme, Refashion, alongside household packaging. Each category needs its own identifier (IDU), and both are held through a French representative under one written mandate.
What a small shop pays
| Germany | France | |
|---|---|---|
| Representative | EPR Germany Rep Essential, €149 a year, no setup fee | EPR France Rep Standard, €990 a year for up to three categories, no setup fee |
| What you pay the scheme | A licence fee per kilogram of packaging, usually the operator's minimum at small volumes | A contribution per item sold, for packaging and for clothing |
EPR France Rep's Standard plan includes German packaging representation, so a shop selling to both countries can cover both with that one plan. Licence fees and contributions are passed through at cost in both countries.
What you do once
Weigh one empty parcel and split it by material, then export your orders by delivery country. Those two numbers feed both declarations. See how to work out your packaging weights and selling to both Germany and France.