PPWR: authorised representative for packaging in Germany

What the PPWR changes from 12 August 2026

Regulation (EU) 2025/40 on packaging and packaging waste, known as the PPWR, entered into force on 11 February 2025. Most provisions apply from 12 August 2026. Article 45(3) is particularly important. Anyone supplying packaging or packaged goods directly to end users in a Member State where they are not established must appoint an authorised representative for extended producer responsibility (EPR) there under a written power of attorney.

Who is affected

The PPWR definition of a producer is broad. It covers manufacturers, importers and distributors, as well as distance sellers and online retailers. If you ship goods from another EU country directly to customers in Germany and are not established there, the rule generally applies to you even as an EU business. One authorised representative is required per Member State. For Germany, this means an authorised representative in Germany; for other EU countries, a separate representative in each country.

What the authorised representative does

The authorised representative handles EPR tasks on your behalf in the relevant country: contact with the register and system, reporting, packaging data and deadlines. The scope is determined by the power of attorney and German regulations. In Germany, the appointment is recorded in the LUCID packaging register, which is why our service combines PPWR and LUCID. Since 12 August 2026, the VerpackDG has applied in Germany, replacing the Packaging Act and supplementing the PPWR. Deadline reminders are an integral part of the service.

You remain responsible

The authorised representative takes on the operational work, but not the producer’s legal responsibility. Please also note that the EPR authorised representative under Article 45 has a different role from the authorised representative under Article 17 PPWR, which concerns conformity documentation for manufacturers from third countries. Our service relates to EPR.

Price and ordering

Representation as an authorised representative in Germany costs €99 for 12 months. The contract renews automatically for successive 12-month periods unless cancelled with one month’s notice. Participation in a dual system is a separate service provided by our partner; PPWR Partner is not a dual system operator. If you are unsure whether you are affected, take the short check.

FAQ