Do I need an authorised representative in Germany?
At most 4 questions to your result.
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.
Question 3: do the deliveries go to end users, meaning private customers or businesses that use the goods themselves?
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.
Appoint your representativeResult: 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.
Result: if you only deliver to retailers in Germany, you usually do not need an authorised representative.
If you deliver exclusively to retailers in Germany who resell your goods unchanged, the German retailer, as the first company in the domestic supply chain, is usually the producer. It then bears the obligations under packaging law, and for these deliveries you need neither an authorised representative nor a LUCID registration.
Important: businesses that use your goods themselves are end users. If you also deliver to such businesses, you need an authorised representative, and the shipping boxes of your parcels always have to be licensed, even if the parcel goes to a business. In individual cases the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister) decides with binding effect.
If you deliver to businesses that use the goods themselves exclusively as freight on pallets, without shipping individual parcels, choose the option “We deliver exclusively as freight on pallets to business customers” in the order form. The licence fee then does not apply and you only pay the 170 € per year. If this does not settle your case, describe it to us briefly.
Appoint your representative Send a short enquiryResult: 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.