EU packaging rules (PPWR) apply since 12 August 2026 · day 91Check if it applies to you →
PPWR · since 12 Aug 2026 · Check if it applies to you →
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Can I appoint two authorised representatives in Germany, for example one per marketplace?

No. § 5(4) VerpackDG: each producer may appoint only one 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 7 November 2026 · Sources linked below

Quick answer

No. § 5(4) VerpackDG: each producer may appoint only one authorised representative for extended producer responsibility. That one representative covers all your packaging and every channel in Germany, from Amazon to your own shop. To switch, you end the old mandate, tell ZSVR without delay, and name the new one in LUCID (§ 5(6), § 6(1)).

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