If you sell packaged goods into Germany, you may have heard that foreign companies need a local authorised representative for German EPR. For packaging EPR in Germany, that is not currently mandatory under the German Packaging Act (Verpackungsgesetz / VerpackG). Today, a company without a branch in Germany can appoint an authorised representative for packaging compliance, but this is optional, not compulsory. The German packaging authority’s LUCID guidance says this expressly, and notes that this option has existed since 3 July 2021.
What is an authorised representative in German packaging EPR?
In the German packaging system, an authorised representative is a person or company based in Germany that a foreign business may appoint to handle certain packaging-law obligations on its behalf. According to the Central Agency Packaging Register (ZSVR), this option is available to international companies that have no branch in Germany.
However, this does not mean the representative can do everything. ZSVR states that LUCID registration remains a personal obligation of the obligated company itself. In other words, even if you appoint an authorised representative, your business must still be the one registered in the LUCID Packaging Register. The representative can then handle other ongoing packaging-law tasks during the term of the authorisation.
Is an authorised representative mandatory in Germany for packaging EPR
At the moment, no. Under the current German Packaging Act, appointing an authorised representative is optional for foreign companies without a German establishment. ZSVR’s official guidance says this directly: international companies can appoint one, but “doing so is optional.”
That means a non-German company currently has two routes for German packaging compliance:
- Handle the packaging EPR obligations itself, or
- Appoint a German authorised representative to take over certain obligations on its behalf.
Which packaging obligations can a representative handle
According to ZSVR, an authorised representative may take over most packaging-law obligations except the company’s own LUCID registration. The representative can handle tasks such as:
- concluding a system participation agreement with a dual system,
- making data reports to LUCID,
- submitting declarations of completeness, where applicable,
- fulfilling certain take-back obligations, and
- participating in the deposit scheme for relevant single-use beverage packaging.
This can be useful for overseas sellers that want local operational support, but it is still a business choice rather than a current legal requirement.
Why is there confusion about this?
The confusion comes from new EU packaging rules and Germany’s planned national implementation.
At EU level, Regulation (EU) 2025/40 on packaging and packaging waste entered into force in 2025 and applies from 12 August 2026.
In Germany, there is also a planned Verpackungsrecht-Durchführungsgesetz (VerpackDG) to adapt national law to the new EU regulation. Public Bundestag lobbying-register material states that the German government has adopted a cabinet draft to align German packaging law with Regulation (EU) 2025/40 and that the EU packaging rules are to be implemented from 12 August 2026.
So the key point is this:
- Current German packaging law: authorised representative is optional.
- Future position: rules may change as Germany implements the EU packaging regulation, but businesses should not treat that future regime as already in force unless and until the relevant legal provisions are adopted and apply.
What should foreign sellers do now?
If you place packaged goods on the German market today, you should focus on the obligations that already apply:
- register your company in LUCID,
- determine whether your packaging is subject to system participation,
- sign up with a dual system where required,
- report packaging volumes correctly, and
- decide whether you want to manage compliance directly or use a German authorised representative for the non-registration parts.
Summary
As of 8 April 2026, a non-German company does not currently need to appoint a local authorised representative for German packaging EPR. Under the current VerpackG, appointing one is optional. The option has existed since 3 July 2021. Future EU-driven reforms may change the framework from 12 August 2026, but that is separate from the position under the current German packaging law.