Checked: 6 November 2026 — the date every statement on this page was checked against the sources below.
Being in the EU does not exempt you. Since 12 August 2026 a company with no establishment in Germany must appoint a German authorised representative before it sells packaged goods to German end users. The rule is Article 45(3) PPWR, applied in Germany by § 5(2) VerpackDG. Your home country's registration does not cover Germany. Sources (2)
Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)
VerpackDG § 5VerpackDG § 5
Start here
- Seller from another EU country: do I need a representative?
- Does a German representative cover other EU countries?
- Keeping your dual-system contract
- Selling to Germany and France
Regulation (EU) 2025/40 (PPW VerpackDG § 5
By country
France, Spain, Italy, the Netherlands, Belgium, Poland, Austria and more: see selling to Germany from abroad.
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 ↗