Authorised representative for packaging in Germany – VerpackDG, PPWR and LUCID
Which packaging obligations apply in Germany
Anyone placing packaged goods on the German market for the first time must comply with the Packaging Law Implementation Act (VerpackDG), which replaced the Packaging Act on 12 August 2026. This includes registration in the LUCID packaging register, participation in a dual system, reporting packaging volume data and, where statutory volume thresholds are exceeded, a declaration of completeness. This also applies to online retailers based abroad whose parcels reach customers in Germany.
When an authorised representative is mandatory
Since 12 August 2026, businesses without an establishment in Germany have been required to appoint an authorised representative if they supply packaged goods directly to final recipients in Germany, for example through their own shop or marketplaces such as Amazon, eBay or Kaufland. Registration in LUCID remains your strictly personal obligation. You name your authorised representative during this process.
PPWR: authorised representative for extended producer responsibility
From 12 August 2026, Article 45(3) of the PPWR requires producers and distance sellers supplying end users in a Member State where they are not established to appoint an authorised representative for extended producer responsibility (EPR) there. This is done under a written power of attorney. The producer remains responsible, while the authorised representative takes on the operational work.
What you receive from PPWR Partner
- An authorised representative for packaging in Germany,
- Support with EPR obligations,
- Preparation of the contract,
- Instructions for LUCID registration,
- Deadline reminders,
- Correspondence in German.
Price
Representation costs €99 for 12 months and renews automatically for successive 12-month periods (cancellation requires one month’s notice). You order participation in a dual system separately from our partner, starting at €35 per year plus per-kilogram fees depending on the material. PPWR Partner is not a dual system operator.
FAQ
Does packaging law also apply to retailers based in other EU countries?
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Yes. If you place packaged goods on the German market for the first time, the obligations apply regardless of where your business is based.
Can I order only the authorised representative service without a dual system?
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Yes. You can order representation, system participation or both together.
Do I remain responsible?
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Yes. The authorised representative handles the operational work, while the producer retains legal responsibility.
This page is for information only and does not constitute legal advice.