Authorised Representative for Extended Producer Responsibility – who needs one in Germany?

19 October 2026 · Legal status: 19 October 2026

The Authorised Representative for Extended Producer Responsibility is the official term used in the EU Packaging Regulation PPWR (EU 2025/40) and the German VerpackDG. In practice, people also speak of a "PPWR representative", "EPR representative" or "LUCID representative". In German the role is called Bevollmächtigter für die erweiterte Herstellerverantwortung, in Polish upoważniony przedstawiciel ds. rozszerzonej odpowiedzialności producenta.

We explain what the authorised representative does, which companies from other EU countries must appoint one in Germany and how this works in practice.

The term in different languages

Extended producer responsibility (EPR) means: whoever places packaging on the market finances its collection and recovery.

Legal basis

• Art. 3(1)(20) PPWR – definition. Simplified: a person established in the EU Member State in which a foreign producer makes packaging available for the first time, who is mandated to fulfil the producer's obligations under Chapter VIII PPWR.
• Art. 45(3) PPWR – obligation to appoint by written mandate in every Member State in which the producer makes packaging available for the first time, other than its own Member State of establishment.
• § 5 VerpackDG – German rules: written power of attorney in German, only one authorised representative per producer, appointment in the LUCID packaging register.

Full text of PPWR: Regulation (EU) 2025/40 on EUR-Lex.

Who must appoint an authorised representative in Germany?

The obligation under Art. 45(3) PPWR applies to producers under Art. 3(1)(15)(c) and (d) PPWR. These are companies that:

• have no establishment in Germany (e.g. based in Poland, the Czech Republic, Austria or the Netherlands),
• and deliver packaging or packaged goods directly to end users in Germany.

The end user can also be a company, not only a consumer (Art. 3(1)(23) PPWR). The obligation can therefore also cover B2B deliveries – for example to a business that uses up or unpacks the goods.

If you only sell to a German company that places the goods on the market itself (e.g. a wholesaler), that company is usually the producer in Germany – and the obligation to appoint an authorised representative may not apply to you. Check this separately for each sales channel.

LUCID registration alone is not enough

A common mistake: the company registers in the LUCID packaging register and considers the matter closed.

What does the authorised representative do?

The authorised representative takes over all obligations of extended producer responsibility in Germany – except LUCID registration. Towards the authorities it is treated as the producer and acts in its own name. This includes, among others:

• system participation with a dual system for packaging that ends up with private final consumers,
• data reports to LUCID and the dual system,
• the Declaration of Completeness if the thresholds are reached,
• obligations for packaging not subject to system participation, e.g. transport and B2B packaging (take-back, recovery, documentation),
• communication with ZSVR, the dual systems and authorities.

Important: According to ZSVR, the current authorised representative may be obliged to make up for obligations the producer missed in the past (e.g. retroactive participation in the dual system). It is therefore worth clarifying the past before starting cooperation.

What the authorised representative for EPR is not

PPWR also knows the authorised representative of the manufacturer (Art. 17 PPWR). This is a different role: it concerns the technical conformity of the packaging, e.g. keeping the technical documentation. The Authorised Representative for Extended Producer Responsibility deals exclusively with EPR obligations – registration, systems, reports. The two roles are easily confused.

How the appointment works in Germany

1. The producer registers in LUCID (if not already done).
2. The producer and the authorised representative sign a written power of attorney in German.
3. The producer appoints the authorised representative in LUCID.
4. The authorised representative accepts the appointment in LUCID – from then on it is listed in the public register and takes over the obligations.

Each producer may appoint only one authorised representative in Germany (§ 5 VerpackDG). Both the producer and the authorised representative can end the appointment in LUCID. However, the authorised representative remains responsible for the obligations from the period of its registration.

Can the obligation still change?

The obligation to appoint under Art. 45(3) PPWR has applied since 12 August 2026. However, relief is being discussed at EU level and in Germany: in December 2025 the European Commission proposed suspending the obligation, and in September 2026 the German Federal Government spoke out in favour of relief for small companies. As of 19 October 2026, none of these proposals is applicable law. We will update this article as soon as anything changes.

Frequently asked questions

This article is for general information only and reflects the legal status as of 19 October 2026. It does not constitute legal advice. In individual cases, PPWR, VerpackDG and the position of ZSVR are decisive.

Sources: Regulation (EU) 2025/40 (PPWR), Art. 3 and 45; Packaging Law Implementation Act (BGBl. 2026 I No. 207), §§ 5 and 6; ZSVR – "Information for authorised representatives on their obligations" (08/2026); Commission proposal COM(2025) 982.

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