Do I need an authorised representative in Germany?

At most 4 questions to your result.

Question 1: does your company have an establishment in Germany?

Yes No

Question 2: do you deliver goods to customers in Germany?

It makes no difference whether through your own online shop or through marketplaces such as Amazon, eBay or Etsy.

Yes No

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Question 3: do those deliveries go to private end customers?

Yes No, only to businesses

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Question 4: are the goods packaged (box, mailing bag, filling material)?

Yes No

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Result: yes, from 12.08.2026 you need an authorised representative in Germany.

Without an appointed representative you may no longer deliver to Germany from that day. There is no minimum quantity, the obligation starts with the 1st parcel. On top of that, the registration and reporting duties of German packaging law already apply to you today.

We take on this role for 170 € per year.

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Result: with an establishment in Germany you need no authorised representative.

The obligation only applies to companies without a German establishment. Your remaining duties (registration, system participation, volume reporting) you fulfil yourself as a domestic company. What LUCID and the dual system are is explained in our questions and answers.

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Result: pure B2B selling carries obligations too.

Anyone delivering exclusively to business customers needs no dual system for those deliveries, because only sales packaging that ends up with private end consumers is subject to system participation. Instead, take-back and documentation duties apply to your transport packaging and your commercial sales and grouped packaging (section 39 VerpackDG).

Important: registration in the LUCID packaging register has applied to every type of packaging since 01.07.2022 and therefore to pure B2B packaging as well. And since 12.08.2026, as a company without a German establishment you need an authorised representative in Germany for pure B2B deliveries too.

You can book the representation directly in the order form with the option “We deliver exclusively to business customers”: the licence fee is then dropped and you pay only the 170 € per year. If that does not settle your case, describe it to us briefly.

Appoint your representative Send a short enquiry

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Result: according to your answers this does not apply to you.

Without deliveries to Germany, or without packaging, you need no authorised representative. If your business changes, repeat the test.

Borderline cases such as fulfilment, dropshipping or deliveries to business customers are explained in our questions and answers.

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