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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Who pays eco-contributions in Germany?

The producer: the company that first makes the packaged goods available in Germany. It pays the dual system's licence fee by material and weight; a representative passes it on.

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

The producer. For goods sold from abroad straight to consumers in Germany, the foreign seller is the producer of that packaging. Germany has no eco-contribution under that name: the producer pays a dual system for system participation, priced by material and weight (§ 7 VerpackDG). With an authorised representative, the representative concludes that licence in its own name for your packaging (§ 5(3)) and the fee is passed on to you. If you sell to a German retailer that resells, that retailer is the producer for that flow. See dual-system rates and selling to a German retailer.

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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.