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Answer · Who needs a representative
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What counts as packaging under German EPR?

Everything that contains, protects, handles, delivers or presents goods and reaches the consumer with them: product packaging, shipping boxes, filling, tape and labels. The definition is in the PPWR.

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

More than most sellers think.

  • Product packaging: boxes, bottles, jars, blister packs, bags.
  • Shipping packaging: the outer carton or mailer, filling, tape, labels.
  • Service packaging filled at the point of sale.
Not packaging: parts that are an integral part of the product and stay with it for its whole life. For borderline items, ZSVR publishes a catalogue of packaging subject to system participation. Everything that reaches German consumers is licensed with a dual system.

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Selling in Germany?

Your German authorised representative from €149 a year: help with your LUCID registration, dual-system contract and annual report included. No setup fee.

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