Checked: 6 November 2026 — the date every statement on this page was checked against the sources below.
A producer with no establishment in Germany must appoint an authorised representative before it first makes packaging or packaged products available in Germany. The rule is § 5(2) VerpackDG, which implements Article 45(3) of Regulation (EU) 2025/40 and has applied since 12 August 2026. There is no tonnage, turnover or size threshold. With us it costs €149 a year, with no setup fee. Sources (2)
VerpackDG § 5VerpackDG § 5VerpackDG § 6VerpackDG § 6
Who must appoint one
The test is establishment, not nationality. A company established in another EU member state and a company established outside the EU are caught alike, as soon as they sell packaged goods to end users in Germany without a German establishment.
| Your company | Representative needed? |
|---|---|
| Established outside the EU, selling to German consumers | Yes |
| Established in another EU country, selling to German consumers | Yes |
| Established in Germany | No: you register and license yourself, or hand the work over under a mandate |
| Selling only to a German importer who resells under its own name | Usually no: the importer is the producer for those goods |
Not sure which row is yours? The producer scenarios go through the common set-ups.
VerpackDG § 5 
Regulation (EU) 2025/40 (PPW
How the appointment works
- You sign a written power of attorney in German. You can appoint only one representative.
- You register in LUCID yourself. This step cannot be delegated, but it is free and online.
- In your LUCID entry you name the representative by its LUCID ID.
- The naming takes effect when ZSVR confirms it. We accept the appointment the same day once you have named us and signed the mandate.
VerpackDG § 5 VerpackDG § 6 
ZSVR help
What the representative takes on, and what stays with you
| Duty | Who |
|---|---|
| LUCID registration | You |
| Dual-system licence for your household packaging | The representative, in its own name |
| Data reports in LUCID | The representative |
| Keeping the licence in step with your volumes | The representative |
| Accurate quantities | You supply them |
For the obligations it takes on, the representative counts as the producer and performs them in its own name.
What it costs
Our fee is a flat €149 a year for packaging, whatever your volumes, with no setup fee. The dual-system licence follows your kilograms by material and is passed on at the system's own rate. Electricals and batteries are separate regimes at €500 a year each. See pricing and the full cost guide.
What happens without one
A producer that is not properly registered may not make packaging available in Germany, and fulfilment service providers may not act for it; ZSVR checks this against the register automatically. Administrative fines go up to €200,000 depending on the breach.
Establishment, not a VAT number, decides it
§ 5(2) VerpackDG asks one question: does your company have an establishment (Niederlassung) in Germany? A German VAT registration does not count. It is a tax status, not a seat or a branch, so a company that files German VAT returns from abroad still needs a representative.
Nationality does not matter either. A company registered in France, Poland or Italy is treated exactly like one registered in China, the United Kingdom or the United States. The test is only whether you have your own establishment in Germany.
What the mandate must say
§ 5(4) VerpackDG sets the form: a written mandate in German (schriftliche Vollmacht in deutscher Sprache). A translation next to the German text is fine, but the German version is the one that counts. Each producer may appoint only one representative for extended producer responsibility, so one mandate covers all your packaging and every sales channel in Germany.
| Element | Why it matters |
|---|---|
| Your company name, address and register number | It must match your LUCID registration, or ZSVR cannot link the two |
| The representative's name, address and LUCID ID | You enter that ID when you name the representative in LUCID |
| The duties handed over: system participation, data reports, the declaration of completeness where it applies | The representative performs them in its own name (§ 5(3)) |
| What stays with you: LUCID registration and your own data | § 5(2) excludes registration from what can be handed over |
| Start date, notice period and how it ends | An ended mandate must be reported to ZSVR without delay (§ 6(1)) |
What the representative files in its own name
Under § 5(3) VerpackDG the representative counts as the producer for the duties it takes over and acts in its own name. In practice that means three filings.
- The dual-system licence. § 7(1): before the packaging is made available, the participation states the material types, their weight and your LUCID registration number. The system confirms it in writing or electronically.
- The data reports to ZSVR. § 9(1): the same four items given to the system: LUCID number, material types and masses, the system's name and the period licensed. ZSVR compares both sides.
- The declaration of completeness, where your volumes require one. § 10: checked by a registered expert or auditor and filed electronically with ZSVR with a qualified electronic signature.
Your part is the figures: what you sold into Germany, by material and weight. If they are wrong, the filings built on them are wrong, which is why we ask for them per material type and keep your confirmations in your dashboard.
VerpackDG § 5 VerpackDG § 7 VerpackDG § 9 VerpackDG § 10
Naming the representative in LUCID and keeping it current
§ 5(5) VerpackDG requires you to name the representative to ZSVR without delay, inside your LUCID registration, and the naming takes effect when ZSVR confirms it. From then on, § 6(1) makes you report every change to your registration data at once, including changes to, or the end of, the representative's mandate.
The register is public. § 6(4) requires ZSVR to publish each registered producer with its name and address, its authorised representative, its brand names, its packaging types, the registration number and the date. Marketplaces and fulfilment providers check listings against that register (§ 13(4)), so a brand missing from your entry can be blocked even when your licence is in order. Add every brand you sell under in Germany, and add new ones before the first sale.
VerpackDG § 5 VerpackDG § 6 VerpackDG § 13
What happens without a representative
| Consequence | Rule |
|---|---|
| You may not make packaging available in Germany without a valid registration | § 13(1) VerpackDG |
| Distributors may not sell packaging of unregistered or unlicensed producers | § 13(3) VerpackDG |
| Marketplaces and fulfilment providers may not handle it: listings are removed and stock held | § 13(4) VerpackDG |
| ZSVR may revoke a registration whose conditions no longer exist | § 6(5) VerpackDG |
| Fines of up to €200,000 for no system participation, €100,000 for registration failures, €10,000 for most other offences | § 66(3) VerpackDG |
The practical risk comes first: a marketplace block stops sales the same day, long before any fine. A representative named in LUCID and confirmed by ZSVR is what keeps listings live.
VerpackDG § 6 VerpackDG § 13 VerpackDG § 66
Changing or ending your representative
Because § 5(4) allows only one representative at a time, a switch is a sequence, not an overlap.
- Sign the new mandate with the new representative.
- End the old mandate on the date the new one starts, under its notice terms.
- Report the end of the old mandate and name the new representative in LUCID without delay (§ 6(1) and § 5(5)).
- Make sure the new representative's system participation covers the packaging from the switch date, so no month is left unlicensed.
If you stop selling into Germany altogether, § 6(1) requires you to report that you have permanently ceased to act as a producer. Your published entry then shows the exit date, and ZSVR deletes it three years after the end of that year (§ 6(4)).
If you were registered under the old VerpackG
The VerpackDG replaced the VerpackG on 12 August 2026. § 68 VerpackDG carries over what was done before: existing registrations count as VerpackDG registrations. System participations entered into before 12 August 2026 continue, unless the contract says otherwise, until 31 December 2026 at the latest (§ 68(1)). Packaging you make available from 1 January 2027 needs a participation under the VerpackDG, with your LUCID number. The duty to appoint a representative is not part of that transition: it has applied since 12 August 2026 (§ 5(2)).
Worked example
Illustrative example: the business is invented. A kitchenware brand registered in Poland sells on Amazon.de and through its own shop, ships from a warehouse in Poznań, and has a German VAT number for its FBA stock.
- Is a representative needed? Yes. The German VAT number is not an establishment (§ 5(2)).
- Who registers in LUCID? The Polish company itself, with every brand it sells under (§ 6(2)).
- What does the representative do? Licenses the household packaging with a dual system in its own name, files the data reports and, if the volumes require it, the declaration of completeness (§ 5(3)).
- What does the brand send? Its yearly figures per material: for example cardboard, plastic film and paper fill, in kilograms.
- What does Amazon see? The LUCID number and, in the public register, the named representative (§ 6(4)).
Representatives under the other German laws
Packaging is not the only German EPR law that requires a representative. Each has its own appointment, and one does not cover another.
| Law | Who needs a representative | Form | Do we act? |
|---|---|---|---|
| VerpackDG § 5 (packaging) | Producers with no establishment in Germany | Written, in German, one representative | Yes, €149 a year |
| ElektroG § 8 (electrical equipment) | Distance sellers and producers established abroad | Written, in German, at least three months, one representative | Yes, €500 a year |
| BattDG § 40(2) (batteries) | Producers with no establishment in Germany | Written, in German, one representative | Yes, €500 a year |
| EWKFondsG § 10 (single-use plastics fund) | Producers established abroad selling covered products | Written, in German, one representative | No |
| GPSR Article 4 (product safety) | Non-EU manufacturers selling into the EU | A responsible person in the EU, not an EPR role | No |
See electrical equipment, batteries and EPR representative vs GPSR responsible person.
VerpackDG § 5 ElektroG § 8 BattDG § 40 EWKFondsG § 10 Regulation (EU) 2023/988 (GP
What it costs in total
Three costs make up German packaging compliance for a seller without an establishment, and only one of them is the representative's fee.
| Cost | Who sets it | With us |
|---|---|---|
| LUCID registration | ZSVR | Free: ZSVR charges nothing to register |
| Representative fee | The representative | €149 a year, no setup fee, no deposit |
| Dual-system participation fee | The dual system, by material and weight | Passed on at cost, paid by bank transfer, no markup |
The system fee depends on your materials and kilograms, so a seller shipping a few hundred kilograms of cardboard pays far less than one shipping tonnes of plastic. Compare providers on all three lines, not on the representative fee alone: see published provider prices and dual-system rates.
Checklist before your first sale in Germany
- Your company is registered in LUCID, with every brand you sell under in Germany.
- The German-language mandate with your representative is signed.
- The representative is named in your LUCID entry and ZSVR has confirmed it.
- Your household packaging is licensed with a dual system for the period you sell, with your LUCID number on the participation.
- Your LUCID number is entered in each marketplace account (Amazon, eBay, OTTO, Kaufland) and shown where the marketplace asks for it.
- You have your yearly figures by material type and weight, or a plan to collect them.
- If you also sell electrical equipment or batteries: the separate stiftung ear registrations and representatives are in place.
English-speaking EPR representative in Germany
The website, the mandate translation and our written support are in English. The German text of the mandate is the binding one, as § 5(4) VerpackDG requires. We are EPRGermanyRep GbR, Im Mediapark 5, 50670 Köln, trade registered on 1 October 2026; our LUCID ID is DE8516653799349.
Germany EPR representative set-up time
Once you have signed the mandate and named us in LUCID, we confirm the appointment the same day. ZSVR's confirmation in LUCID is what makes the naming effective (§ 5(5) VerpackDG); we tell you as soon as it shows. Sell only once your registration, the naming and the dual-system licence are all in place.
Razvan Toma is the founder of EPR Germany Rep and of EPR France Rep, the French sister service. He has worked in waste management and recycling since 2009, running waste-separation programmes inside large B2B organisations in France for clients including Chanel, Microsoft, Decathlon, Pirelli, IKEA, Vinci, Capgemini and E.Leclerc. He reads the statutes and the regulator's own guidance directly, and publishes what they say — including when it means telling a visitor they do not need to buy anything.
Razvan on LinkedIn ↗