Checked: 7 November 2026 — the date every statement on this page was checked against the sources below.
VAT and EPR are separate registers with separate deadlines: a seller can hold a German VAT number and still have no LUCID registration. A VAT registration is also not an establishment, so it does not remove the duty to appoint a German representative. Your clients need both, and you can refer the EPR leg to us. Sources (2)
Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)
VerpackDG § 5VerpackDG § 5
Why it fits a VAT practice
When you register a client for German VAT, you already know it sells packaged goods to German end users. That is the trigger for LUCID registration, a dual-system licence and, without a German establishment, an authorised representative. A VAT registration is a tax status, not an establishment. See does a German VAT number make you established.
Why a firm outside Germany cannot hold the role itself: since 12 August 2026 a producer with no establishment in Germany must appoint an authorised representative established in Germany, by written mandate (Article 45(3) PPWR, § 5(2) VerpackDG). Distributors, fulfilment service providers and online platforms may not handle packaging from producers that are not properly registered in LUCID (§ 13 VerpackDG).
Regulation (EU) 2025/40 (PPW VerpackDG § 5 VerpackDG § 13
What you can offer
Copy these into your service list or proposals. We deliver them.
- Packaging EPR in Germany, France and Spain alongside your VAT services
- An authorised representative in each of the three countries
- Annual reports filed for the client
Published prices, no setup fee: Germany €149 a year for packaging, €500 a year each for electricals and batteries; France from €190 a year per stream; Spain €199 a year. Licence and scheme fees are passed on at cost. See pricing.
How to add it
When you register a client for VAT in a new country, add one onboarding question: “Do you need EPR there?” If yes, send your link.
Partner terms
| Term | What it means |
|---|---|
| Your fee | 20% of what your client contracts with us, and 20% again of every yearly renewal, for as long as the client stays. No cap. |
| Data service | 20% of every month a client stays on EPR EU Connect, our €89-a-month packaging data service. |
| Excluded | Dual-system licence fees and scheme fees: we pass them on at cost, so there is nothing to share. |
| When paid | Once your client has paid us. |
| Client price | The same published price as anyone else. Your fee comes out of ours. |
| Who keeps the client | You. Each client signs its own mandate with our representative, because the law requires a named representative; everything outside EPR stays with you. |
| Your tools | A page at epreurep.com/yourfirm with your name and logo, a partner code, and a dashboard with leads, paid clients, their yearly fees and your fee. |
| Client data | You see a client's own account only after the client approves your access, and it can withdraw it at any time. |
How to start
- Apply. Tell us about your firm and your clients; we reply in writing with the partner terms.
- Get your page. epreurep.com/yourfirm, with your name and logo. Clients buy from it directly and every order is tracked to you.
- Introduce clients. Send the link or give your partner code. No integration.
- Follow it. Leads, paid clients and your fee in your dashboard. We do the registrations and the filing.
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 ↗