EU packaging rules (PPWR) apply since 12 August 2026 · day 91Check if it applies to you →
PPWR · since 12 Aug 2026 · Check if it applies to you →
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Selling to Germany from abroad

German packaging EPR for companies based outside Germany, country by country: who needs an authorised representative, what the home registration does not cover, and how to start.

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

Every company with no establishment in Germany that sells packaged goods to end users there needs a German authorised representative, whether it is based in the EU or outside it. Your home country's registrations do not cover Germany. Pick your country for what applies to you.

Outside the EU

VerpackDG § 5

Inside the EU

VerpackDG § 5 Regulation (EU) 2025/40 (PPW

German companies

Established in Germany? You need no representative, but you can hand the work over under a mandate. See packaging EPR for German companies.

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 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 ↗

Selling in Germany?

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