Authorised Representative for Packaging in Germany (Bevollmächtigter)
Since 12 August 2026, companies without an establishment in Germany that sell packaged goods directly to German end consumers must appoint an authorised representative (Bevollmächtigter) based in Germany (VerpackDG, implementing Art. 45 PPWR). Without one, a valid LUCID registration is no longer possible – and marketplaces such as Amazon are legally required to block unregistered listings.
We are not an authorised representative ourselves. Two clear routes: if you need an authorised representative, we put you directly in touch with our partner in 23 countries. If you do not need one because you have a German establishment, we guide you through the LUCID registration with guidance ourselves.
Am I affected? The 3-question check
1. Do you have an establishment in Germany?
Yes → usually no representative needed; you count as a domestic producer.
No → question 2.
2. Do you sell directly to end consumers in Germany?
Yes (Amazon.de, eBay, Etsy, own shop, dropshipping) → you count as the producer under packaging law.
No, only B2B to a German importer → the importer is usually responsible.
3. Are the goods packaged when they arrive at the customer?
Yes → the authorised-representative obligation applies.
What the representative does – and what he does not
Does:
– takes over all obligations after your LUCID registration (you register in the LUCID packaging register yourself as the producer and name the representative there)
– signs you up with a dual system (system participation)
– files volume reports and acts as contact for the ZSVR and authorities
– bears liability for proper fulfilment of the EPR obligations
Important – how the appointment becomes effective: a signed contract alone is not enough. You name the representative with his ID in your LUCID account, the representative confirms the appointment in his account, and only after verification by the ZSVR is the appointment valid. Your authorised representative guides you through both steps.
Does not:
– cover the cost of the packaging licence (stays with you)
– prepare the PPWR declaration of conformity (create it with our generator)
– handle packaging labelling under Art. 15 PPWR (label generator)
How we help: an authorised representative in 23 countries
Need an authorised representative? We put you in touch with an experienced partner offering authorised-representative and EPR registration services in 23 countries – Austria, Belgium, Bulgaria, Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Netherlands, Norway, Poland, Portugal, Romania, Slovenia, Spain and Sweden. Prices differ by country (examples in the FAQ below). You receive a concrete quote from the partner for exactly the countries you sell in; contract and handling run directly between you and the partner.
Not sure whether you are affected? The 3-question check above is sufficient in most cases. For special situations – dropshipping, Amazon FBA warehouses in several EU countries, mixed B2B/B2C business – we clarify it in a short initial consultation (€99 one-off). Consultation happens in writing by email — 100% online. Request initial consultation.
Our partners by country
For each country we name a trusted local partner. The contract and all further steps are handled directly between you and the partner.
We may receive a commission for referrals to our partners. This does not cost you anything extra.
Authorised representatives in other EU countries
The principle applies reciprocally in all 27 member states: anyone selling directly to end customers in France, Italy, Spain or the Netherlands becomes a producer there and needs a local authorised representative as well. More in our article EPR numbers in EU countries.
Further reading
– German packaging law from 12 Aug 2026: authorised representative and labelling in detail
– FAQ: Foreign sellers and registration in Germany
– LUCID registration service
Frequently asked questions
Who needs an authorised representative for packaging since 12 August 2026?
Companies without an establishment in Germany that sell packaged goods directly to German end consumers (e.g. via Amazon, eBay, Etsy or their own shop). Under German packaging law they count as the producer and must appoint an authorised representative based in Germany. Companies with a German establishment generally do not need one.
What does the authorised representative actually do?
The company registers in the LUCID packaging register itself – this is a personal obligation of the producer – and names the representative there. The representative then takes over all other packaging obligations towards the Central Agency Packaging Register (ZSVR) and the authorities: participation in a dual system, volume reports, the declaration of completeness where required, and acting as the official contact. The cost of the packaging licence itself remains with the company.
Does this also apply to companies from other EU countries?
Yes. What matters is not the country of origin but whether there is an establishment in Germany. A seller from Austria, Poland or the Netherlands without a German establishment is affected just like a seller from China or the USA. The principle applies reciprocally in all EU member states.
How much does an authorised representative cost?
Typical all-inclusive packages on the market – authorised representative, EPR registration and dual-system participation in one – cost around €100 per year for Germany. Other EU countries are usually more expensive, e.g. Netherlands approx. €160, France approx. €250, Spain approx. €320, Austria approx. €480, Italy and Poland approx. €500 per year. Important: registration is per calendar year – if you start in autumn you usually pay for the current and the following year. All figures are approximate typical market prices (as of October 2026), not the prices of any particular partner – the binding price is quoted by the respective provider.
Is Packaging Compliance itself an authorised representative?
No. We are not an authorised representative and do not assume liability as one. If you need one, we put you directly in touch with our partner, who offers authorised-representative and EPR registration services in 23 countries – everything further then runs between you and the partner. If you do not need an authorised representative because you have a German establishment, we guide you through the LUCID registration ourselves.
Is a contract with the representative enough?
No. The appointment only becomes effective once you name the representative with his ID in your LUCID account, he confirms the appointment in his own account, and the ZSVR has verified the link. Without this two-sided confirmation in the register the obligation is not fulfilled.
Will the obligation be suspended again?
In December 2025 the EU Commission proposed suspending the authorised-representative obligation until 1 January 2035 – mainly for producers established in another EU member state; for producers from third countries (e.g. China, USA, UK), member states are to remain free to require an authorised representative. On 5 October 2026 the European Parliament's environment committee voted to limit the relief to micro and small enterprises established in the EU; the plenary vote is scheduled for 19 October 2026, followed by negotiations with the Council. Until an amendment is actually adopted, the obligation applies unchanged since 12 August 2026 (VerpackDG). As of 14 October 2026.
Note: This page does not replace legal advice. Status: 14 October 2026.