Checked: 6 November 2026 — the date every statement on this page was checked against the sources below.
Yes. Being in the EU does not exempt a company based in the Netherlands: with no establishment in Germany, it must appoint a German authorised representative before it sells packaged goods to end users in Germany. The rule is § 5(2) VerpackDG, which applies Article 45(3) PPWR and 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 | Netherlands |
|---|---|
| Your home registration | Your registration with Afvalfonds Verpakkingen covers the Netherlands only. |
| Typical sales channels | Own webshop shipping to Germany, Amazon.de and bol, German distributors, Dutch BV structures of non-EU brands |
| 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 |
VerpackDG § 5 Regulation (EU) 2025/40 (PPW
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 the Netherlands ask
Does our registration in the Netherlands cover Germany?
No. Your registration with Afvalfonds Verpakkingen covers the Netherlands only. Germany keeps its own register, LUCID, where every producer registers itself, and its own dual systems.
Our non-EU group sells to Germany through a Dutch BV. Which company registers?
The Dutch BV, if it sells to German end users: it is the producer and, without a German establishment, needs a German authorised representative.
Does a German representative also cover other EU countries?
No. The duty runs per country: each member state where you sell directly to end users has its own register and its own representative. See other EU countries.
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 ↗