PPWR authorized representative in Germany under VerpackDG

What a PPWR authorized representative does in Germany

Under extended producer responsibility (EPR), whoever first makes packaging available in a country registers there, reports quantities and pays for its collection and recycling. The PPWR, Regulation (EU) 2025/40 (opens in a new tab), has applied since 12 August 2026 (Article 71); on the same day, the VerpackDG (opens in a new tab) replaced Germany's Packaging Act (VerpackG).

The PPWR calls the role the "authorised representative for the extended producer responsibility": a person established in the member state concerned who fulfills the producer's EPR obligations under Chapter VIII (Article 3(1), point (20)). In Germany, the representative also takes on the VerpackDG obligations, is deemed the producer for them and acts in its own name (§ 5(2), (3) VerpackDG (opens in a new tab)).

Who needs a PPWR representative in Germany, and who does not

A company outside the EU is the producer under the PPWR only where it makes packaged goods available directly to end users in a member state, consumers or businesses that use the goods themselves (Article 3(1), points (15)(c), (d) and (23)). It must then appoint a representative by written mandate in that member state (Article 45(3), first sentence), and member states may require one from producers in third countries (second sentence). Germany has written both into § 5(2) VerpackDG.

ZSVR applies the duty to companies abroad without a branch in Germany that sell directly to end users there (ZSVR (opens in a new tab)).

What the representative takes over, and what stays with you

You entrust the representative with your EPR obligations under the PPWR and the VerpackDG, except registration (§ 5(2) VerpackDG). ZSVR calls registration a personal duty: you register in LUCID and make later changes yourself (ZSVR (opens in a new tab)).

The mandate: one representative, in German, confirmed in LUCID

You may appoint only one representative, by written power of attorney in German (§ 5(4) VerpackDG). According to ZSVR, the representative has a registered office or branch in Germany, is not affiliated with your company and has its own representative login in LUCID; both sides sign by hand or with a qualified electronic signature (ZSVR (opens in a new tab)).

You name the representative in your registration without delay, and ZSVR must confirm the appointment (§ 5(5)). In LUCID, it takes effect once the representative confirms it and appears in the public register the next day (ZSVR help (opens in a new tab)).

When the mandate ends, you notify ZSVR; the representative stays responsible for obligations from its time (§ 5(6)). Representatives can also end the appointment in LUCID themselves, so agree notice periods and a handover.

Already registered under the old Packaging Act?

Before 12 August 2026, a representative was voluntary; since then it has been mandatory, and LUCID prompts registered companies abroad to name one (ZSVR (opens in a new tab)). Your old registration continues to count, and changes to registration data are due by 12 November 2026 (§ 68(2) VerpackDG).

System participations under the old Act end on 31 December 2026 at the latest (§ 68(1)); from 2027 at the latest, your representative concludes them. New sellers get no transition: LUCID does not let a company abroad complete its registration without a representative (ZSVR).

Five steps before your next shipment to Germany

1. 1.Map your channels: wherever you sell directly to end users in Germany, you are the producer (table above).
2. 2.List your packaging: retail packaging, shipping boxes, filling material and tape, by material and weight (§ 7(1) VerpackDG).
3. 3.Sign one mandate: written, in German, with a representative in Germany that has a LUCID representative login (§ 5(4) VerpackDG; ZSVR).
4. 4.Register yourself: naming the representative, before the first sale or by updating your entry (§ 5(5), § 6(1), § 68(2)).
5. 5.Set up the data flow: agree which quantities you send and when; give platforms and fulfillment partners your registration number (Article 45(4), (7) PPWR).

Example: a Canadian cookware brand

A Canadian company sells pans to consumers in Germany through its web shop, shipped from Canada in printed retail boxes inside plain cartons with paper filling. It also supplies a German department store chain by the pallet.

For web shop orders, the brand is the producer of retail boxes and shipping cartons (Article 3(1), point (15)(c), (d)). It registers in LUCID; its representative joins a take-back system and reports. With about 6 tonnes of packaging a year, reports are due once a year by 1 June, and a declaration of completeness only on request (§ 9(2), § 10(4) VerpackDG).

For the pallets, the chain is the producer: it first makes the pans available in Germany (point (15)(b)). As manufacturer, the brand still answers for the conformity of its branded retail box (Article 3(1), point (13)(a), and Article 15).

Will the EU drop the representative requirement?

In December 2025, the Commission proposed suspending Article 45(3) PPWR until 1 January 2035 (COM(2025) 982 (opens in a new tab), Article 2). For producers outside the EU, the duty would not simply disappear: each member state could still require a representative or ensure enforcement by other means, because enforcement against producers in third countries is harder (Article 2, Recital 6).

On 20 October 2026, Parliament adopted amendments to the proposal and referred it back to its environment committee for negotiations with the Council (text adopted by Parliament (opens in a new tab); procedure file 2025/0395(COD) (opens in a new tab)). In Parliament's version, the suspension would cover only micro and small enterprises established in the EU; for producers in third countries, the current rules should be maintained, and the option to replace their representative by other means is deleted (amendments to Article 2 and Recital 6). In the Council, negotiations had been discontinued (Legislative Train (opens in a new tab)).

A plenary vote alone changes nothing: until an amendment is adopted and in force, Article 45(3) PPWR and § 5(2) VerpackDG apply as written.

Common mistakes with packaging representation in Germany

• Counting only the retail box. Shipping cartons, filling material and tape are e-commerce packaging (Article 3(1), point (8), PPWR) and, according to ZSVR, always need system participation (ZSVR, online retailers (opens in a new tab)).
• Treating a German VAT number as an establishment. According to the Commission's guidance, VAT registration alone does not make a company established for EPR purposes (C/2026/3084 (opens in a new tab), section 4).
• Relying on your product law mandate. An EU Authorized Representative or GPSR Responsible Person does not cover packaging EPR (roles compared).
• Forgetting other EPR roles. Electrical equipment and batteries need their own registrations and representatives in Germany; see WEEE representative in Germany and § 40(2) BattDG (opens in a new tab).

Conclusion: register yourself, mandate one representative

If you ship from abroad to end users in Germany, you need two things before the first sale: your own registration in LUCID and one written mandate in German for everything else. Already registered? Appoint your representative now; changes to existing registrations are due by 12 November 2026.

We support packaging representation as part of our Representation pillar and packaging compliance under the PPWR through Packaging, EPR & Sustainability. For product safety, see GPSR Responsible Person.

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