Do I need exact packaging weights to start?

No. An estimate is enough to start; the licence is adjusted to your real volumes.

Can I sign the mandate electronically?

Yes, with a qualified electronic signature. Otherwise sign it by hand.

Documents you need for German packaging EPR: checklist

The documents you need for German packaging EPR

The checklist for a company outside Germany: what the written mandate needs, what LUCID asks for, the packaging data for the dual-system licence, and what the marketplaces ask afterwards.

Since 12 August 2026, § 5 VerpackDG, implementing Article 45(3) of Regulation (EU) 2025/40, requires a producer with no establishment in Germany to appoint an authorised representative before it first makes packaging available in Germany. Read § 5

Checked: 6 November 2026 — the date every statement on this page was checked against the sources below.

Quick answer

Three documents carry the whole file: a written power of attorney in German, your LUCID entry, and the dual-system licence. For them you need your company details exactly as registered, a signatory, your VAT number, your packaging by material and weight, and the date you started shipping to Germany. An estimate of your packaging is enough to start.

For the written mandate

Legal name and legal form, exactly as registered
Commercial register number and the register court or authority
Registered address
Name and position of the person who signs

The power of attorney must be written and in German. It is signed by hand, or with a qualified electronic signature.

VerpackDG § 5

For LUCID

Company name as in your national company register
The person in charge, for example the managing director
A contact person with an email address
Your VAT number
Your representative's LUCID ID

ZSVR help

For the dual-system licence

Data	Example
Packaging by material, per year	Cardboard 1.8 t, plastic film 240 kg, paper 30 kg
Brands sold in Germany	Every brand name on the packaging
Sales channels	Own shop, Amazon, eBay, Kaufland, resellers
When you started shipping to Germany	Decides whether earlier years are owed

How to get the kilograms right: weighing your packaging.

VerpackDG § 7

What marketplaces ask afterwards

Your LUCID registration number. Some also check that your packaging is licensed. See the marketplace rules.

Amazon

If you also sell electricals or batteries

Those are separate registrations at stiftung ear, where the representative registers for you. Tell us at onboarding and we add them, €500 a year each.

ElektroG § 8 stiftung ear

About the authorRazvan Toma

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 ↗