From 12 August 2026, you must appoint a Germany-based packaging EPR Authorised Representative if your business is established outside Germany, has no German branch, and supplies empty packaging or packaged products directly from abroad to private or commercial end users in Germany. The rule covers qualifying businesses established both inside and outside the EU.

Your existing LUCID registration remains valid. However, registration and changes to your producer registration data remain your personal responsibility; the representative takes over most other packaging EPR duties only after the appointment is confirmed by the ZSVR.

What Changed on 12 August 2026

The Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, or PPWR) entered into force on 11 February 2025 and became generally applicable on 12 August 2026. Germany's Verpackungsrecht-Durchführungsgesetz (VerpackDG) replaced the previous VerpackG on the same date. The Bundestag adopted the new German packaging-law framework on 11 June 2026.

Under the previous VerpackG, a foreign producer could choose to appoint a German representative. The ZSVR now confirms that qualifying foreign producers without a German branch must appoint one from 12 August 2026, with no general exemption.

Who Actually Needs One

This is not a blanket rule for every business selling into Germany. You generally need a German packaging EPR Authorised Representative when all three conditions below apply:

• Your business is established outside Germany and has no branch in Germany
• You qualify as the producer under the PPWR rules because you supply empty packaging or packaged products directly from abroad to end users in Germany
• The German recipient is the end user, which may be a private consumer or a commercial end user

What the Representative Does — and the One Thing They Can't

Once appointed, your representative takes over nearly all of your ongoing packaging-law duties in Germany, acting in their own name on your behalf. Per the ZSVR, this specifically includes:

Initial LUCID registration and later changes to your producer registration data remain duties you must perform personally. Existing registrations continue to be valid; the VerpackDG transition rules allow changes required by the new law to be filed by 12 November 2026. The representative's appointment must be recorded in LUCID and confirmed by the ZSVR before it takes legal effect.

How the Appointment Actually Works

1. Choose an eligible representative. They must be a natural or legal person with a registered office or branch in Germany, be independent of your business, and use a separate authorised-representative login in LUCID.
2. Sign a written agreement in German. Both parties must sign by hand or with a qualified electronic signature.
3. Appoint only one representative. German law explicitly limits producers to a single active mandate at a time.
4. Enter the details in LUCID and wait for ZSVR confirmation. The authorisation only takes legal effect once the ZSVR has confirmed it — only then does the representative appear alongside your producer data in the public register.

What Happens If You Don't Comply

Online marketplaces must collect evidence of EPR registration or the required self-certification before allowing a producer to offer packaged products. Amazon has already stated that relevant Germany listings can be deactivated when a seller does not provide a valid LUCID registration number. Under the VerpackDG, a registration breach can carry an administrative fine of up to €100,000, while a failure to participate in a required packaging system can carry a fine of up to €200,000. These amounts relate to those specific offences; they are not an automatic fine simply for a missing representative. The PPWR also allows automated reconciliation of platform information with the national producer register.

Don't Confuse This With Other EU Representative Duties

Frequently Asked Questions

Need Help with EPR Compliance?

VATAi can help you assess whether the German packaging representative rule applies to your sales model and coordinate the relevant EPR registration, reporting, and authorised-representation steps.