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Guide · UK sellers
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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.

Checked: 14 October 2026 — the date every statement on this page was checked against the sources below.

Quick answer

Yes, a UK seller needs one, today. Since 12 August 2026, § 5(2) VerpackDG requires every producer without an establishment in Germany to appoint an authorised representative established there. The EU's proposed suspension does not change this for the UK: the requirement stays for producers outside the EU. You register in LUCID yourself, sign a written mandate in German, and name the representative in LUCID. With us that costs €149 a year, plus the dual-system licence fee for your packaging.

Does it apply to you?

It applies if your company is established in the UK and packaged goods you sell reach consumers in Germany, whether from your own shop, Amazon.de, eBay or another marketplace. There is no minimum volume: one parcel is enough. Stock in an Amazon or other German warehouse, or a German VAT number, does not make you established in Germany.

The steps

  1. Register in LUCID. Free, online, and the one step you must do yourself. See LUCID registration step by step. If you registered before 12 August 2026, you must name a representative by 12 November 2026.
  2. Order and fill in your details. Your client portal opens straight after payment. Your company details fill in the mandate.
  3. Sign the mandate. German law requires a written mandate in German. Ours is German with an English translation alongside. Print it, sign it by hand and upload a scan or photo. You do not need a notary or an apostille.
  4. Name us in LUCID. Our LUCID ID is in your portal. We accept the appointment and the register confirms it.
  5. Give us your packaging weights. Cardboard, plastic and other materials per year; an estimate is fine to start. See how to work out your packaging weights. We conclude the dual-system contract in our name and file the reports.

Already licensed with a dual system?

A contract concluded before 12 August 2026 continues until 31 December 2026 at the latest (§ 68(1) VerpackDG). Packaging you have already licensed for 2026 is not licensed again, so this year you pay only our fee. From 2027 the system participation runs in our name, as your representative.

What it costs

  • Our fee: €149 a year (Essential) or €199 (Standard), for the calendar year, renewing on 1 January. No setup fee. We charge no VAT.
  • Dual-system licence fee: per kilogram, by material, passed through at the system's own rate with no markup. At small volumes you usually pay the system's minimum.
  • LUCID registration: free.

UK packaging EPR is separate and does not cover what you ship to Germany.

Sources

Every claim above comes from one of these. Primary law and the competent authority first; no provider marketing pages.

Razvan Toma
About the authorRazvan Toma

Razvan Toma is the founder of EPR Germany Rep and of EPR France Rep, the French sister service. 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 ↗

Selling into Germany from abroad?

The new EU packaging law (PPWR) has applied since 12 August 2026. Four questions tell you whether it makes you appoint a representative in Germany — including when it does not.

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