Do Temu sellers need packaging EPR in Germany?

Q: Do Temu sellers need packaging EPR in Germany?

Yes, if you sell to consumers in Germany under your own name as a third-party seller: you are the producer of that packaging. Register in LUCID yourself, license it with a dual system, and appoint a German authorised representative if your company has no establishment in Germany. If the platform buys your goods and sells them to the consumer itself, the producer is whoever first makes the packaged goods available in Germany: check your contract.

If you sell to consumers in Germany under your own name on Temu, you are the producer: LUCID registration, a dual-system licence and, with no German establishment, an authorised representative.

Since 12 August 2026, § 5 VerpackDG, implementing Article 45(3) of Regulation (EU) 2025/40, requires a producer with no establishment in Germany to appoint an authorised representative before it first makes packaging available in Germany. Read § 5

By Razvan Toma · Founder · Last checked 9 November 2026 · Sources linked below

Quick answer

It depends on who sells to the consumer.

You sell under your own name (third-party seller): you are the producer. LUCID registration, dual-system licence, and an authorised representative if you have no German establishment.
The platform buys and resells: the producer is whoever first makes the packaged goods available to end users in Germany. Your contract says which model you are on.

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