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What should an EPR mandate in Germany include?

Written and in German (§ 5(4) VerpackDG), signed by hand or with a QES: the parties, the duties the representative takes over, the licence in its name, your data duties, fees, and how it ends.

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 8 November 2026 · Sources linked below

Quick answer

At least these points.

  • Form: written, in German, signed by hand or with a qualified electronic signature; a translation alongside is fine.
  • The parties, exactly as registered.
  • The duties it takes over: system participation in its own name (§ 5(3)), data reports, the declaration of completeness where due.
  • That LUCID registration stays your own duty (§ 5(2)).
  • What packaging data you supply, and when.
  • Its fee, separate from the dual system's fees.
  • How it ends: you must tell ZSVR without delay (§ 5(6)).
See why it must be in German and changing representative.

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