Do I need a German authorised representative?
Since 12 August 2026, companies without an establishment in Germany that place packaged goods on the German market may be required to appoint an authorised representative there. This page sets out the criteria that determine whether the requirement is likely to apply to your business, and clears up two things that are widely misunderstood. It is general information, not legal advice.
The three conditions
The obligation generally becomes relevant when all three of the following are true at the same time. If one of them does not apply to you, the picture may look different.
- You have no establishment in Germany. No branch, no subsidiary, no registered office. A German warehouse or fulfilment centre you rent is usually not an establishment in this sense.
- You are treated as the producer for German purposes. Under the regulation, the producer is whoever first places the packaging on the German market — which is not automatically the company that manufactured the goods. If you ship directly to customers in Germany, that first placement is typically yours.
- Your goods reach end users in Germany. Selling directly to consumers or to other end users, whether through your own shop or a marketplace.
If you are unsure about the second point in particular, that is the one worth clarifying first. It determines whether the obligation sits with you or with someone else in your supply chain.
Two things that are widely misunderstood
"The requirement was postponed to 2035"
This is the most common misreading we see, and it is worth understanding precisely. In December 2025 the European Commission proposed suspending the representative requirement until 2035. That proposal covered producers established inside the EU only — producers based outside the EU were excluded from it from the start.
The proposal has also not been adopted. In June 2026 the Council discontinued negotiations on it after reservations from a large majority of member states, and a European Parliament committee vote is expected around October 2026, after the deadline had already passed. The requirement therefore took effect as originally planned on 12 August 2026.
For a seller based in the United Kingdom, the United States, Switzerland, China or anywhere else outside the EU, the 2035 discussion has no bearing on the German obligation.
"One representative covers the whole EU"
It does not. The appointment is national. A representative in Germany covers Germany. If you also ship to France, Spain or Italy, each of those markets is assessed separately and may require its own representative and its own registration. Some providers offer representation in several countries, but that is several appointments bundled into one contract, not a single EU-wide one.
What a representative does and does not take over
Where the obligation applies, the representative generally assumes the extended producer responsibility duties in your name — arranging system participation, submitting data reports, and communicating with the authorities.
One duty stays with you. According to the Zentrale Stelle Verpackungsregister, registration in the LUCID packaging register is a personal obligation that cannot be transferred. You register yourself, and then name your representative inside the portal. Any provider promising to do the registration for you is describing something the register does not permit.
How to find out where you stand
There is no official list of authorised representatives, which is why comparing providers takes some work. Before you approach anyone, it is worth being clear on three things: which markets you actually ship to, roughly what packaging weights and materials you send per year, and whether you also place electrical goods or batteries on the market, since those carry separate obligations.
For anything that turns on your specific circumstances — particularly whether you count as the producer — a qualified advisor or the Zentrale Stelle Verpackungsregister itself is the right place to ask. This page cannot answer that for your business.
Last updated: . Regulatory positions can change; we review this page when they do.