EU packaging rules (PPWR) apply since 12 August 2026 · day 86Check if it applies to you →
PPWR · since 12 Aug 2026 · Check if it applies to you →
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Guides

German EPR guides for foreign sellers

Sourced, dated answers to the questions companies ask when selling into Germany.

Scope

Do you need a German EPR representative?

Who counts as a producer (Hersteller) in Germany, when a company with no German establishment must appoint an authorised representative (Bevollmächtigter), and worked examples.

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6 October 2026

Do EU micro and small companies still need a German EPR authorised representative after the 5 October 2026 PPWR vote?

Yes, today. On 5 October 2026 the European Parliament's environment committee backed a proposed suspension of the PPWR authorised-representative duty for EU micro and small companies. It is not law. What was voted, what still has to happen, and what to do now.

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Roles

Erzeuger or Hersteller: who owns the shipping box?

The PPWR splits packaging responsibility into two roles. What each one means, how ZSVR's two-step test works, and where marketplaces and fulfilment providers sit.

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Choosing

Can an EPR software platform be your German representative?

EU-wide EPR software can do most of the work, but the Bevollmächtigter itself must be established in Germany. What VerpackDG § 5 and ZSVR require, and the five questions to ask before you buy.

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Choosing a provider

How to choose a German EPR representative

No authority ranks Bevollmächtigte. What exists is a statutory test that disqualifies offers, five checks that actually separate providers, and published prices.

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Costs

How much German EPR compliance costs

German packaging EPR has three separate cost layers. What sits in each, which one is unavoidable, and where published numbers exist — and where they do not.

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The law

VerpackDG § 5: Germany’s authorised representative rule

The German rule requiring foreign producers to appoint a Bevollmächtigter, quoted in full with an English translation, paragraph by paragraph.

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Scope

Who is the producer in Germany? 18 sales scenarios

A decision table: for each way goods reach Germany, who counts as the Hersteller, whether a Bevollmächtigter is needed, and the reason.

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How to

LUCID registration, step by step

How a company outside Germany registers in the German packaging register LUCID and names its authorised representative: each screen, the two time limits, and what to enter when you have no tax number yet.

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How to

How to work out your packaging weights for Germany

How a small online shop works out its packaging weights for Germany: which parts of a parcel count, the eight material groups the register uses, and a ten-minute method with kitchen scales.

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Costs

How to lower your German packaging licence fees

German dual-system licence fees are charged per kilogram by material, and plastic costs roughly four to five times as much as paper. What that means for tape, filling and mailers, and when it makes no difference at all.

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Scope

Selling to both Germany and France

Germany and France each require their own authorised representative, register and fees. What a seller shipping to both countries has to do twice, what can be done once, and how to cover both with one provider.

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UK sellers

Selling from the UK to Germany: your authorised representative

A UK company shipping packaged goods to German consumers needs an authorised representative established in Germany. The steps, what you sign, what happens to an existing licence, and what it costs.

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Each guide is written from the statute (VerpackDG, Regulation (EU) 2025/40) or from the Zentrale Stelle Verpackungsregister, the competent authority for the German packaging register — never from another provider’s marketing page. Every page carries the date it was checked. The sourced numbers live in the open datasets.

Selling into Germany from abroad?

Your German authorised representative from €149 a year: help with your LUCID registration, dual-system contract and annual report included. No setup fee.