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 who deliver packaged goods directly to end users in Germany to appoint an authorised representative based there who takes on their packaging obligations. End users are private customers and businesses that use the goods themselves. Without a representative, shipping to end users in Germany 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 new rule is the obligation to appoint an authorised representative in every destination country without an own establishment to which they deliver directly to end users.
What happened to the German Packaging Act (VerpackG)?
The Packaging Act has been repealed since 12.08.2026. It has been replaced by the Packaging Law Implementation Act (VerpackDG), which implements the European packaging regulation PPWR in Germany. Little changes for you in the basics: the Central Agency Packaging Register remains responsible, the LUCID register remains in place, and the registration obligation continues to apply. What is new is the obligation for sellers without a seat in Germany who deliver directly to end users in Germany to appoint an authorised representative. If you still have documents that refer to the VerpackG: the sections have different numbers today, but the obligation behind them is 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 authority. Every producer must be registered there, including every foreign seller who delivers packaged goods directly to end users in Germany. Registration is free of charge and, under German law, must be done by the producer itself. 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 producer, including every foreign seller shipping to end users in Germany, must license its packaging volumes with a dual system and pay a fee based on weight and material. As your authorised representative, we handle this for you.
I already have a LUCID number. Can I still order?
Yes, it is even simpler for you. Enter your LUCID number directly in the order form, and the registration step disappears completely. After the order confirmation you appoint us as your authorised representative in your existing LUCID registration, 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?
Yes. For 2026 your existing licensing continues unchanged; with us you only book the representation with the tick “already licensed”. From 2027 the authorised representative licenses your packaging in its own name (section 5 (2) and (3) VerpackDG). System participations concluded before 12.08.2026 remain valid under section 68 (1) VerpackDG, subject to deviating private-law agreements, until 31.12.2026 at the latest. Please check the terms of your previous provider, cancel your contract as of 31.12.2026 with reference to this provision and have the cancellation confirmed in writing.
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?
It depends on what your business customers do with the goods. If they use the goods themselves, they are end users: you then need an authorised representative, and the shipping boxes of your parcels always have to be licensed, even if the parcel goes to a business. If, on the other hand, you deliver exclusively to retailers in Germany who resell the goods unchanged, the German retailer is usually the producer, and you need neither an authorised representative nor a LUCID registration. 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. For pallets and other transport packaging, take-back and documentation obligations under section 39 VerpackDG apply, which you fulfil yourself. In individual cases the Central Agency Packaging Register decides with binding effect.
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 the 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, which applies per calendar year: a basic amount (2026: 35 €, 2027: 36 €) plus a price per kilogram and material according to the public price list of our system partner, for the whole calendar year including parcels already shipped. If your quantities turn out higher than estimated during the year, you report the additional quantities via your personal link, which you receive from us by e-mail, and pay them directly. All prices plus VAT; with a valid EU VAT number the reverse charge procedure applies.
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 LUCID, 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 appoint us as your representative in your existing registration. 5. We confirm the appointment in LUCID, and the packaging register informs you about it by e-mail. From receipt of that e-mail you may 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?
3 dates: the authorised representative must be appointed since 12.08.2026, before your next delivery. Companies registered in LUCID before 12.08.2026 must add the authorised representative to their registration by 12.11.2026 (§ 68 (2) VerpackDG). 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 1 June 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 representative obligation applies per destination country: anyone who also delivers directly to end users in 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 by 12 months unless you cancel it in text form, for example by e-mail, 30 days before the end. You can end your appointment of us in LUCID yourself at any time (section 5 (6) VerpackDG). When the contract ends, we end the representation in LUCID; from then on you need another authorised representative for further deliveries to Germany.