By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below
Before your first sale in Germany. § 5(2) VerpackDG: a producer without a German establishment appoints its representative before it first makes packaging or a packaged product available there. § 5(5): you then name the representative to ZSVR without delay, as part of your LUCID registration, and the naming needs ZSVR's confirmation. With us, the appointment is confirmed the same day once you have named us and signed the mandate. 
VerpackDG § 5
Is a German authorised representative mandatory since 12 August 2026?
Yes, for every producer that sells packaged goods directly to end users in Germany without an establishment there. Two rules started on the same day:
- Article 45(3) PPWR. The EU Packaging Regulation (EU) 2025/40 applies from 12 August 2026 (Article 71). Its Article 45(3) requires a producer to appoint, by written mandate, an authorised representative for extended producer responsibility in each member state where it makes packaging available directly to end users and is not established.
- § 5(2) VerpackDG. Germany's Packaging Law Implementation Act replaced the Packaging Act on 12 August 2026 and turns this into a duty to appoint the representative before first making packaging available.
It does not matter where you are based. A company in France or Poland is treated like one in China or the United States; the only question is whether it has its own establishment in Germany. A German VAT number is not one: see why.
Regulation (EU) 2025/40 (PPW VerpackDG § 5
Who it applies to, case by case
Article 3(1), point 15(c) and (d), PPWR defines the producers concerned: those that make packaging or packaged products available for the first time in another member state directly to end users. An end user is anyone in the EU, consumer or business, who uses the product and does not sell it on in the form received (Article 3(1), point 23).
| Your situation | Representative in Germany? |
|---|---|
| Company outside Germany, shipping to German consumers from its own shop | Yes |
| Company outside Germany, selling on Amazon.de, eBay, OTTO or Kaufland, including Fulfilment by Amazon | Yes |
| Company outside Germany, selling to German businesses that use the goods themselves | Yes: they are professional end users |
| Company outside Germany, selling only to a German importer or wholesaler that resells | No: the German buyer is the producer |
| Company with a German VAT number but no seat or branch in Germany | Yes |
| Company with a branch or subsidiary in Germany that makes the sales | No: it is established |
Regulation (EU) 2025/40 (PPW VerpackDG § 5
The transition dates
| Date | What applies | Rule |
|---|---|---|
| 12 August 2026 | PPWR and VerpackDG apply; representative required before the first sale | Art. 71 PPWR, § 5(2) |
| 12 September 2026 | Producers newly required to register had to be registered | § 68(2) sentence 3 |
| 12 November 2026 | Producers registered under the old Packaging Act had to make their changes, including naming a representative | § 68(2) sentence 2 |
| 31 December 2026 | Dual-system participations from before 12 August 2026 end at the latest | § 68(1) |
A producer registered under the old law keeps its registration (§ 68(2) sentence 1). It does not register again; it updates the registration and names its representative there.
VerpackDG § 68 Regulation (EU) 2025/40 (PPW
The order of the steps
- Sign a written mandate in German with your representative (§ 5(4)). One representative only, for all channels.
- Name the representative in LUCID without delay, as part of your registration (§ 5(5), § 6(2)). Registration itself stays your own act; § 5(2) excludes it from the mandate.
- The representative confirms and ZSVR confirms the naming (§ 5(5)). With us that happens the same day once you have named us and signed.
- The representative licenses your packaging with a dual system in its own name, before the goods are sold (§ 5(3), § 7(1)).
- The representative files the data report with ZSVR (§ 9).
Screen by screen: LUCID registration, step by step.
VerpackDG § 5 VerpackDG § 6 VerpackDG § 7 VerpackDG § 9
What if you are already selling without one?
Then you are making packaging available without a complete registration, which § 13(1) forbids and § 66 fines: the fines, offence by offence. Marketplaces and fulfilment providers must also check your registration (Article 45(4) to (8) PPWR). Appoint the representative and complete the registration before the next sale.
VerpackDG § 13 VerpackDG § 66 Regulation (EU) 2025/40 (PPW
More on Who needs a representative
- I only send a few items a year to Germany. Does German packaging law still apply?
- I also sell electronics in Germany. Is that the same registration as packaging?
- Does a German representative also cover my sales to other EU countries?
- Can I avoid German packaging law by not selling to Germany?
- I am a sole trader, not a company. Can you represent me?
- Can the ZSVR act as my German authorised representative?