PPWR · Germany · Authorised representative

Authorised representative for packaging in Germany (PPWR)

Since 12 August 2026, companies without a branch in Germany that supply empty packaging or packaged goods directly to end users in Germany must appoint an authorised representative for extended producer responsibility based in Germany. Without one, a new registration in the LUCID Packaging Register cannot be completed.

Last reviewed: 23 September 2026 · Independent guide, not legal advice · Sources at the end of the page

Who needs an authorised representative?

The duty applies to companies based in another EU country or outside the EU (for example in China, the United States or the United Kingdom) that have no branch in Germany and supply empty packaging or packaged goods directly – without an intermediary retailer – to end users in Germany. End users are consumers and also businesses that use the goods themselves rather than resell them. A typical case is a seller based abroad who sells through an online marketplace directly to customers in Germany. According to the ZSVR, there is no exemption.

You do not need your own representative if you have a branch in Germany. If you sell to a retailer or importer in Germany who resells the goods, the ZSVR's description of the duty does not cover you: it concerns direct sales to end users without an intermediary.

Sellers based in the EU: the European Commission has proposed suspending the mandatory authorised representative for producers established in the EU until 1 January 2035 (procedure 2025/0395(COD), “Omnibus VIII”). It has not been adopted: the European Parliament's first-reading plenary vote is scheduled for 19 October 2026. The proposal does not cover producers based outside the EU. Until the law changes, the duty applies.

What the representative does – and what it does not

The representative takes over all obligations under the PPWR and Germany's Packaging Law Implementation Act (VerpackDG) and fulfils them in its own name – for example system participation (the licence with a dual system), data reports and the declaration of completeness. For those obligations it counts as the producer (§ 5 VerpackDG). The exception is registration in the LUCID Packaging Register: it is a strictly personal duty of the producer, and you also make changes to your registration details yourself.

Who can be your representative?

• A natural or legal person with its registered office or a branch in Germany that offers this service – not someone from your own company. Staff who maintain your registration are entered in LUCID as editors, not as representatives.
• You sign a written contract in German with it; if other language versions exist, the German one is legally binding. Both parties sign by hand or with a qualified electronic signature.
• It has its own login as an authorised representative in the LUCID Packaging Register.
• You may appoint only one authorised representative.

How to name your representative in LUCID

1. Sign the contract before you first supply packaging or packaged goods in Germany.
2. New registration: in the master data step (“Stammdaten”), enter your representative's company name or ID in the authorised representative section (“Bevollmächtigter”). Without it, the registration cannot be completed.
3. Already registered: after you log in to LUCID, a pop-up points out the obligation. Update your registration entries and name your representative.
4. Confirmation: the appointment only takes effect once it is confirmed in the register. If the mandate ends, notify the ZSVR without delay.

Deadlines

• Since 12 August 2026: the representative is mandatory; appoint it and name it in LUCID before you first supply goods.
• 12 November 2026: producers who were already registered must make the necessary changes to their registration by this date (§ 68(2) VerpackDG). For sellers without a branch in Germany, the ZSVR says this includes naming the representative.
• 31 December 2026: dual-system participations concluded under the old Packaging Act (VerpackG) remain valid until this date at the latest (§ 68(1) VerpackDG).

What happens without a representative?

Without a representative, a new LUCID registration cannot be completed. Producers may not supply packaging or packaged goods in Germany for the first time as long as they – or, where required, their representative – are not registered (Art. 44(4) PPWR). Amazon and eBay also ask for the LUCID number before you sell packaged goods to customers in Germany. Under § 66 VerpackDG, not taking part in a dual system can be fined up to €200,000; most other duties, including registration, up to €100,000; minor formal breaches up to €10,000. Fines are imposed by the competent authority of the German state (Land), not by the ZSVR.

Who offers the service?

The ZSVR does not publish a list of registered authorised representatives; you have to check yourself who offers the service. Before you sign, check four points: registered office or branch in Germany, a contract in German signed by both sides, its own LUCID login as authorised representative – and which obligations (system participation, data reports, declaration of completeness) the mandate covers.

Since 12 August 2026, German packaging law is the EU Packaging and Packaging Waste Regulation (PPWR) together with the Packaging Law Implementation Act (VerpackDG), which replaced the Verpackungsgesetz (VerpackG). Registration in LUCID, system participation and data reporting remain mandatory.

German version: PPWR-Bevollmächtigter · Free 3-question check and LUCID number format check: eprcheck.com.

Frequently asked questions