Checked: 6 November 2026 — the date every statement on this page was checked against the sources below.
Yes. A company based in Hong Kong that sells packaged goods to end users in Germany, with no establishment there, must appoint a German authorised representative before it sells. The rule is § 5(2) VerpackDG, which has applied since 12 August 2026. There is no size threshold. With us it costs €149 a year, with no setup fee. Sources (2)
VerpackDG § 5VerpackDG § 5
Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)
Quick facts
| Based in | Hong Kong |
|---|---|
| Your home registration | Hong Kong's producer responsibility schemes cover Hong Kong only. |
| Typical sales channels | Amazon.de and FBA, Temu, AliExpress, TikTok Shop, own store, German importers |
| German register | LUCID: you register yourself, online and free, and name us |
| Our fee | €149 a year for packaging, €0 setup, no deposit; electricals and batteries €500 a year each |
| Confirmation | The same day, once you have named us in LUCID and signed the mandate |
Who is the producer in your setup?
| Setup | Producer in Germany |
|---|---|
| Your own webshop shipping to German customers | You, from the first parcel |
| Amazon.de, eBay.de, OTTO, Kaufland and other marketplaces | You, for every unit sold to a German end user. One LUCID number covers every platform |
| Stock at Amazon FBA or a German 3PL | You. The warehouse does not make you established in Germany: see warehouses and establishment |
| A German retailer or distributor buys and resells | Normally the retailer, for those goods: see selling to a German retailer |
| Dropshipping | See who is the producer in dropshipping |
What sellers in Hong Kong ask
Does our registration in Hong Kong cover Germany?
No. Hong Kong's producer responsibility schemes cover Hong Kong only. Germany keeps its own register, LUCID, where every producer registers itself, and its own dual systems.
Our Hong Kong company sells, our mainland factory makes. Which one registers?
The Hong Kong company, if it holds the seller account and invoices German customers. The factory's registration does not cover the Hong Kong company's sales.
We already have an EU responsible person for product safety. Is that enough?
No. The GPSR responsible person and the German packaging representative are two different roles under two different laws. See EPR representative vs GPSR responsible person.
Do we also need something for electricals or batteries?
Yes, if you sell them: those are separate registrations at stiftung ear, made by your representative. See electricals and batteries.
How to start
- Order online and sign the mandate. See pricing.
- Register in LUCID and name us. See LUCID registration.
- Send us your packaging by material: an estimate is enough to start. See the documents you need.
- Enter your LUCID number in every marketplace account. See marketplaces.
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 ↗