Questions and answers
The obligation from 12.08.2026
Why do I need an authorised representative from 12.08.2026?
That is the day the EU Packaging Regulation (PPWR) starts to apply. It requires sellers without an establishment in Germany to appoint an authorised representative based there who takes on their packaging obligations. Without one, shipping to German end customers is no longer permitted from that day.
What is the PPWR?
The PPWR is the new EU Packaging Regulation (Regulation (EU) 2025/40, „Packaging and Packaging Waste Regulation“). It applies directly in all EU member states from 12.08.2026. For sellers shipping across borders its most important change is the duty to appoint an authorised representative in every target country where they have no establishment.
What happened to the German Packaging Act (VerpackG)?
The Packaging Act was repealed on 12.08.2026. It was replaced by the Packaging Law Implementation Act (VerpackDG), which implements the European packaging regulation PPWR in Germany. Little changes for you in substance: the Central Agency Packaging Register remains in charge, the LUCID register continues to exist, and the duty to register still applies. What is new is the duty for traders without a place of business in Germany to appoint an authorised representative. If you still have documents referring to VerpackG: the sections are numbered differently today, the obligation behind them has stayed the same.
Does this also apply to small shops with only a few parcels?
Yes. There is no minimum quantity, no minimum turnover and no exemption for small businesses. The obligation starts with the 1st packaged parcel to an end customer in Germany.
Which packaging counts?
Everything that wraps, protects or transports your goods: the shipping box, the mailing bag, filling material, adhesive tape and the product packaging itself. It is counted in kilograms per material type (for example paper/cardboard, plastic, glass, aluminium). For small senders an estimate and weighing a few typical parcels is enough. Transport packaging does not count: pallets, stretch film and strapping used to deliver goods to warehouses or business customers are registered in LUCID but need no licence.
What is LUCID?
LUCID is the public packaging register of the German register agency. Every seller has to be registered there, registration is free of charge and German law requires the seller to do it in person. With our guide it takes about 15 minutes.
What is a dual system?
Dual systems organise the collection and recycling of sales packaging in Germany. Every seller has to license their packaging volumes with a dual system and pay a fee based on weight and material. As your authorised representative we handle that for you.
I already have a LUCID number. Can I still order?
Yes, for you it is even easier. Enter your LUCID number directly in the order form, then the registration step disappears completely. After the order confirmation you only enter us as your authorised representative in your existing LUCID account, which takes about 5 minutes.
My packaging is already licensed with a dual system. What do I book then?
Only the representation for 170 € per year. Simply tick the "already licensed" option in the order form, then the licence fee is dropped and your existing licensing continues unchanged for the current licence year. From the following licence year we take over the licensing. The year-end report with the actual quantities for this year you still submit to your previous system; we enter the identical quantities for you in LUCID.
I already have a licence contract with another provider. Can I cancel it?
For the current licence year your existing licence simply continues, in that case you book only the representation with the "already licensed" option. From the following licence year we take over the licensing of your volumes. You cancel with your previous provider yourself; its own notice periods apply, usually at the end of the calendar year.
What is the difference between an authorised representative and a dual system?
The authorised representative is your legally required representative in Germany, who fulfils your reporting and register obligations. The dual system is the waste management organisation that collects and recycles your packaging in Germany, and that is what the licence fee pays for. You need both, and as your authorised representative we coordinate both for you.
Who it applies to
I only deliver to businesses, not to private customers. Does this still apply to me?
As a rule yes, but differently. Anyone delivering exclusively to business customers does not place sales packaging subject to system participation on the market and therefore needs no dual system for those deliveries. Instead, take-back and documentation obligations apply to transport packaging and commercial sales and grouped packaging (section 39 VerpackDG). Since 01.07.2022 the duty to register in the LUCID packaging register also covers every type of packaging and therefore pure B2B packaging as well. 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.
Who counts as the producer if I sell through fulfilment or dropshipping?
Under packaging law the producer is whoever first places packaged goods on the German market on a commercial basis. With dropshipping and fulfilment this depends on who sells the goods to the customer in Germany in their own name and who fills the packaging. As a rule it is not the warehouse service provider. Describe your setup to us if you are unsure.
My customer in Germany imports the goods himself. What applies then?
Then it is not the foreign seller but the German importer who first places the goods on the German market. In that case the packaging obligations fall on the importer. What matters is who actually imports the goods under the delivery terms, not where the contract was concluded.
Costs, contract and us
What does it cost me in total?
Our fee is 170 € for 12 months from conclusion of the contract, not per calendar year: if you order in September, you are covered until September of the following year. On top comes the licence fee of the dual system, and that runs per calendar year: 35 € base amount plus a price per kilogram and material type, for the whole current year including the parcels already shipped. After the end of the year we settle with the actual quantities. All prices plus VAT; with a valid EU VAT number the reverse charge procedure applies.
Do you add a margin to the dual system licence fee?
No. We calculate the licence fee exactly according to the price list of the dual system and pass it on to you without any surcharge. Our entire remuneration is the 170 € per year.
How can I pay?
After submitting the order you choose your payment method with our payment provider Mollie. Available are credit and debit card, PayPal and bank transfer, plus country-specific methods such as iDEAL, Bancontact, eps, Przelewy24, Bancomat Pay, MB Way and Multibanco. Payment is made in advance for the contract year, the invoice reaches you by email.
What happens if I do nothing?
Breaches of German packaging law can be fined with up to 200,000 € per case, and a ban on selling into the German market can be imposed on top. Marketplaces such as Amazon check the registration and block listings without a valid LUCID number.
I received a German warning letter (Abmahnung) over a missing LUCID registration. What now?
Respond within the deadline and do not sign the pre-drafted cease-and-desist declaration unchecked; the legal reply is a matter for a lawyer specialised in German competition law. In parallel, the cause has to go: LUCID registration and system participation, and as a seller without a German establishment also the authorised representative. The individual steps are covered in our guide LUCID Abmahnung.
I only sell through Amazon, eBay or Etsy. Does this still apply to me?
Yes. What matters is that your goods arrive packaged at German end customers. The sales channel makes no difference, and the marketplaces additionally demand the records themselves.
Which number do I enter at Amazon, eBay, Etsy or TikTok?
Your own LUCID registration number (DE plus 13 digits), which you receive from the packaging register. It is your EPR number for packaging in Germany, and the marketplaces check it in the public register. Our authorised representative ID belongs only in your LUCID account, not in the marketplace. In TikTok Shop choose the category for Germany (packaging) and leave the switch “not a producer” off, because the number is your own.
Process and deadlines
How does the process work, and from when may I ship?
5 steps: 1. You order and pay online, which takes about 5 minutes. 2. You sign the power of attorney, by post or electronically. 3. With the order confirmation you receive our authorised representative ID and your personal LUCID guide. 4. You register in LUCID or enter us as authorised representative in your existing account. 5. We confirm the authorisation in LUCID. The requirements are then fulfilled and you can ship to Germany.
Under which name do I find you in the LUCID form?
In LUCID you enter the authorised representative via its registration number. You receive our ID with the order confirmation together with your personal guide, as soon as payment and the signed power of attorney are in place; to protect it from misuse we do not publish it in advance.
How does the power of attorney work?
German law requires the power of attorney to be granted in writing and in German. You have the choice how to sign it. Standard: you print the power of attorney, sign it and send us the original by post, the only cost is your postage. Without postal mail: you sign in your browser with a qualified electronic signature through the signature service Skribble, with a one-time identity check, see the next question. Both ways are legally equivalent. Important on the postal way: only the original with your handwritten signature counts, a scan or fax is not sufficient. The signature must come from a person authorised to represent the company, for example the managing director; the contact person in the order form can be someone else, then simply tell us the name of the signatory. For the electronic signature you need a valid passport (EU citizens also an ID card) and a smartphone; if the check fails, for example because of your mobile number, we switch your order to the postal route free of charge.
Why do I have to identify myself?
The identity check only concerns the electronic signature, on the postal way there is none. The power of attorney needs the written form of section 126 of the German Civil Code. Electronically only a qualified electronic signature meets that, and under Article 24 of EU Regulation 910/2014 (eIDAS) it requires a check of your identity. This applies with every provider. In practice the check takes about 10 minutes and runs on your smartphone: scan your ID document, record a short video of yourself. A passport is accepted from every country. The external verification service charges a one-time fee of 24.50 € for it, the fee goes entirely to them. After that you sign with a single click. We never see your ID data, we only learn that the check was successful.
I sell drinks in single-use bottles or cans. Does something different apply to me?
Yes, in addition. Single-use beverage packaging subject to deposit has to take part in a nationwide deposit system (section 46 VerpackDG) and follow its own labelling rules. These obligations come on top of registration and system participation. Talk to us before you appoint us so that we can clarify the scope.
Which deadlines do I need to know?
2 dates: the authorised representative must be appointed from 12.08.2026, before your next delivery. After that there is 1 recurring date per year on which you report your packaging volumes to us; we remind you in good time and file everything on time (the statutory deadline for the annual report is 15 May of the following year).
I have never reported anything. Will I have problems for the past?
The register and reporting obligations have applied to foreign senders since 2019. Omissions in the past remain your responsibility; we put you on a correct footing from the start of the contract and report on time from then on.
How quickly am I up and running?
Booking takes about 5 minutes, your LUCID registration with our guide about 15 minutes. For signing the power of attorney, allow the postal transit time to us on the postal way, or once about 10 minutes for the identity check and the signature on the electronic way. Once payment has arrived and the power of attorney is signed, we normally complete the confirmation and the reports within a few working days, at the latest within 10 working days.
Do I need authorised representatives in other EU countries as well?
Yes. The PPWR duty applies per target country: anyone also selling to France or Austria needs an authorised representative there as well. rep-germany.de covers Germany, the largest e-commerce market in the EU.
Do you also offer WEEE, batteries, GPSR or other countries?
No. rep-germany.de covers packaging obligations in Germany only: authorised representative, packaging licence and data reports in LUCID. For electrical equipment (WEEE), batteries, the General Product Safety Regulation (GPSR) and for other EU countries we do not name any providers.
Who is behind rep-germany.de?
R&R Vivendi GbR from Bad Bentheim in Germany, registered as an authorised representative in the LUCID packaging register. Roman Rötting has been running trading companies with cross-border shipping for more than 20 years, through his own online shops, Amazon and eBay, is registered as a producer in LUCID himself and appoints authorised representatives in other countries. Roman Breitenbach, web developer and entrepreneur, is responsible for the technical side. We know the system from both sides.
How long does the contract run, and how do I cancel?
The contract runs for 12 months and renews for another 12 months unless it is cancelled by the end of the term. When the contract ends we terminate the appointment in LUCID; from then on you need another authorised representative for further deliveries to Germany.