Checked: 6 November 2026 — the date every statement on this page was checked against the sources below.
They are two separate roles, and a seller outside the EU often needs both. The authorised representative for packaging (§ 5 VerpackDG) takes on your German packaging duties: licence and data reports. The GPSR responsible person (Article 4 of Regulation (EU) 2023/988) is an economic operator established in the EU who answers for the safety of your consumer products. Appointing one does not cover the other. Sources (2)
VerpackDG § 5VerpackDG § 5
Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)
Side by side
| Packaging representative (Germany) | GPSR responsible person (EU) | |
|---|---|---|
| Law | VerpackDG § 5, PPWR Article 45(3) | Regulation (EU) 2023/988, Article 4 |
| Covers | Packaging EPR in Germany | Safety of consumer products in the EU |
| Where established | Germany | Anywhere in the EU |
| Who needs it | Producers with no German establishment, including EU companies | Products placed on the EU market, when no manufacturer, importer or other operator in the EU takes the role |
| Main tasks | Dual-system licence, data reports in LUCID | Product documentation, cooperation with authorities, recalls |
VerpackDG § 5 Regulation (EU) 2025/40 (PPW Regulation (EU) 2023/988 (GP
Who needs which
| Seller | Packaging representative | GPSR responsible person |
|---|---|---|
| Brand outside the EU selling to German consumers | Yes | Yes, unless an EU importer takes the role |
| EU brand with no German establishment | Yes | No: it is itself established in the EU |
| German company | No | No |
VerpackDG § 5 Regulation (EU) 2023/988 (GP
Electricals and batteries are a third and fourth role
Electrical equipment and batteries have their own authorised representative at stiftung ear. It is again a separate appointment.
What we do and do not do
We act as your authorised representative for packaging in Germany, and for electricals and batteries on request. We do not act as GPSR responsible person; keep that with your importer or a product-safety provider.
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 ↗