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.
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.
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.
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 15 VerpackG). 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.
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 € per year. On top of that comes the licence fee of the dual system for your actual packaging volume; its amount depends on weight and material type. You receive 1 invoice per year with both items. All prices plus VAT; with a valid EU VAT number the reverse charge procedure applies.
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 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.
Process and deadlines
How does the power of attorney work?
German law requires the power of attorney to be granted in writing and in German. With us this happens electronically: after your payment you receive the document through the signature service Skribble and sign it in your browser with a qualified electronic signature. The first time you identify yourself once, see the next question. No paper and no post are needed.
Why do I have to identify myself?
Because otherwise the signature is not valid. 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, there is no way around it other than paper and post. In practice it 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 check is a one-off, 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 31 VerpackG) 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. On top of that come about 10 minutes once for the identity check and the signature on the power of attorney, and about 15 minutes for your LUCID registration with our guide. 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.
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.