Checked: 7 October 2026 — the date every statement on this page was checked against the sources below.
They are two separate obligations: a representative in Germany does not cover France, and a French one does not cover Germany. Germany requires a representative for packaging since 12 August 2026; France requires one for every product and packaging category it regulates since 10 July 2026. What you can do once is the preparation: one set of packaging weights and sales counts serves both. Sources (3)
VerpackDG § 5VerpackDG § 5
Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)Code de l'environnement, artCode de l'environnement, art. L. 541-10-9-1
Side by side
| Germany | France | |
|---|---|---|
| Representative required since | 12 August 2026 | 10 July 2026 |
| What it covers | Packaging | Packaging, and separately each regulated product category you sell, such as clothing, toys, furniture or electricals |
| Register | LUCID, one registration | One identifier (IDU) per category, issued through the collection scheme you join |
| Who registers | You, personally; then you name the representative | The representative joins the schemes under its mandate |
| What you pay the scheme | A licence fee per kilogram of packaging, by material | A contribution per unit sold or per kilogram, set by each scheme |
| Minimum volume | None | None |
What you do twice
- Two mandates. Each country needs its own written mandate with a company established in that country. The German one must be in German.
- Two sets of numbers. A German LUCID number and, for France, an IDU for each category. Marketplaces ask for each country's numbers separately.
- Two declarations and two sets of fees. Each country's scheme charges on what you sold into that country only.
What you do once
- Your packaging data. The grams of cardboard and plastic per parcel are the same wherever the parcel goes. Weigh once, then multiply by each country's parcel count. See how to work out your packaging weights.
- Your sales split by country. One export from your shop or marketplace, filtered by delivery country, gives both figures.
- Your company documents. The same register extract and VAT number are used for both.
One provider for both
EPR Germany Rep acts in Germany and our sister service EPR France Rep acts in France. On EPR France Rep's Standard plan, German packaging representation is included, so a seller shipping to both countries deals with one team. See the French plans and our German plans.
Selling to more countries than these two? Each EU country where you sell directly to consumers and have no establishment is assessed separately: see does a German representative cover other EU countries?
Sources
Every claim above comes from one of these. Primary law and the competent authority first; no provider marketing pages.
- VerpackDG § 5 — read 2026-10-07
- Regulation (EU) 2025/40 (PPWR) — read 2026-10-07
- Code de l'environnement, art. L. 541-10-9-1 — read 2026-10-07
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 ↗