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Do I need a German EPR representative?

Germany does not ask where you are established and stop there. It asks who initiates the German supply chain. Four questions, based on the regulator's own test.

Four questions. It will also tell you when you do not need a representative.

This follows the two-step method ZSVR publishes for distinguishing a manufacturer from a producer, and the domestic-precedence rule that decides who is the producer in Germany.