LUCID Registration & Mandatory Authorised Representative
Germany Makes Packaging EPR Authorised Representatives Mandatory for Foreign Manufacturers
Germany’s packaging compliance rules have changed. Since 12 August 2026, manufacturers without an establishment in Germany must appoint an authorised representative to handle their Extended Producer Responsibility (EPR) obligations under German packaging law.
The change follows the EU Packaging and Packaging Waste Regulation (PPWR) and Germany’s new Packaging Law Implementation Act (Verpackungsrecht-Durchführungsgesetz, VerpackDG), which replaced the previous German Packaging Act. Under the previous system, appointing an authorised representative was voluntary. It is now a legal requirement for affected foreign manufacturers.
For businesses selling packaged products into Germany, including through Amazon, other online marketplaces or their own online stores, this makes the authorised representative an important part of the German packaging compliance setup.
What is a German packaging authorised representative?
A manufacturer without an establishment in Germany must appoint an authorised representative to assume its Extended Producer Responsibility obligations in Germany.
The appointment must be made through a written power of attorney in German, and a manufacturer may appoint only one authorised representative for these obligations.
Once appointed, the authorised representative assumes the manufacturer's packaging-law obligations (with one important exception) and performs these obligations in its own name. For these responsibilities, the representative is treated as the manufacturer under the PPWR.
This is therefore much more than simply providing a German address or appearing as a contact in the LUCID Packaging Register.
Does the authorised representative register the company in LUCID?
No. This is an important distinction.
The manufacturer's initial registration in the LUCID Packaging Register remains the manufacturer's own legal obligation. The manufacturer must also make changes to its own registration information. These responsibilities cannot be transferred to the authorised representative.
After registration, however, the manufacturer can nominate its authorised representative through LUCID.
The representative receives the nomination and must actively accept it. Only after acceptance is the representative entered in the public register and able to perform the relevant packaging compliance activities through the manufacturer's LUCID account.
What obligations does the authorised representative take over?
The precise obligations depend on the packaging being placed on the German market.
For packaging subject to system participation, the authorised representative can become responsible for:
- concluding the required system participation agreement with one or more German system operators;
- reporting packaging quantities as required under German packaging law; and
- submitting the annual Declaration of Completeness (Vollständigkeitserklärung) where the applicable statutory thresholds are reached.
Other packaging categories can have different obligations. Certain transport packaging, sales and secondary packaging, primary-production packaging, reusable packaging and other specified categories can, for example, be subject to take-back and recovery obligations.
This is why German packaging compliance should be assessed based on the manufacturer's actual packaging types and distribution model rather than treating LUCID registration as a standalone administrative exercise.
Foreign manufacturers should pay particular attention to historical compliance
One of the most important aspects of the new guidance from Germany's Central Agency Packaging Register (ZSVR) concerns previous non-compliance.
If a manufacturer or its former authorised representative failed to meet packaging obligations in the past, the currently appointed authorised representative may be required to remedy those outstanding obligations.
This can include incomplete system participation or a Declaration of Completeness that should have been submitted but was not. The ZSVR explains that authorities may direct the current authorised representative to correct such outstanding obligations because the representative is treated as the manufacturer for these purposes.
Foreign businesses should therefore make sure their historical German packaging compliance is in order before appointing a new representative.
What happens if packaging obligations are not fulfilled?
Packaging compliance in Germany is not simply an administrative formality.
Intentional or negligent violations can constitute administrative offences under the VerpackDG. Where the ZSVR identifies concrete indications of an infringement, it informs the competent German state enforcement authority.
Companies selling into Germany should therefore ensure that their LUCID registration, system participation, packaging-volume reporting and authorised representative arrangements are consistent.
Can an authorised representative terminate the appointment?
Yes.
Under the new LUCID procedure, an authorised representative can terminate its appointment directly without requiring the manufacturer's consent. The manufacturer can also end the appointment.
However, terminating the LUCID appointment does not automatically terminate the underlying contract, nor does it eliminate responsibilities relating to obligations that arose during the period of appointment. Certain continuing obligations may therefore remain after the LUCID appointment ends.
Who needs an authorised representative in Germany?
The new requirement is particularly relevant for manufacturers established outside Germany that place packaged goods on the German market.
This can include companies selling:
- through Amazon Germany or other online marketplaces;
- directly to German consumers through their own websites;
- through German distributors or retailers; or
- through other cross-border sales channels.
Whether a particular company qualifies as the relevant "manufacturer" and which packaging obligations apply should be assessed based on the specific supply chain and packaging configuration.
EaseCert can support your German LUCID and packaging compliance
EaseCert supports international manufacturers and sellers with German packaging compliance, including LUCID-related requirements and the new authorised representative framework.
Our LUCID Registration Service is designed to help foreign businesses establish the required German packaging compliance setup and understand the steps that apply to their business.
Order the EaseCert LUCID Registration Service
Before accepting an authorised representative appointment, we may review the manufacturer's existing German packaging compliance, including previous LUCID registration, system participation and packaging reporting. This is particularly important under the new rules because outstanding obligations from earlier periods may need to be addressed.
Selling packaged products in Germany?
If your company is established outside Germany and sells packaged products to German customers, now is the time to review your LUCID and packaging EPR setup.
Get started with German LUCID and packaging compliance through EaseCert
This article is based on the August 2026 guidance for authorised representatives published by Germany's Stiftung Zentrale Stelle Verpackungsregister (ZSVR) concerning the PPWR, VerpackDG and technical changes to the LUCID Packaging Register.
Frequently Asked Questions
Do foreign manufacturers need an authorised representative for packaging compliance in Germany?
Yes. Since 12 August 2026, manufacturers without an establishment in Germany must appoint an authorised representative to handle their Extended Producer Responsibility (EPR) obligations under German packaging law.
Can the authorised representative register the manufacturer in LUCID?
No. The initial registration in the LUCID Packaging Register remains the manufacturer's own legal obligation. The manufacturer is also responsible for making changes to its registration information. These responsibilities cannot be transferred to the authorised representative.
How is an authorised representative appointed in Germany?
The appointment must be made through a written power of attorney in German. The manufacturer then nominates the authorised representative through LUCID. The representative must actively accept the nomination before it becomes effective in the LUCID Packaging Register.
Can a manufacturer appoint more than one authorised representative?
No. A manufacturer may appoint only one authorised representative for its German Extended Producer Responsibility obligations.
What packaging obligations does the authorised representative take over?
The exact responsibilities depend on the packaging types involved. For packaging subject to system participation, obligations can include concluding a system participation agreement, reporting packaging quantities and submitting a Declaration of Completeness where the applicable statutory thresholds are reached.
Does the authorised representative become legally responsible for the manufacturer's packaging compliance?
Yes. For the packaging-law obligations transferred to the authorised representative, the representative performs the obligations in its own name and is treated as the manufacturer under the applicable PPWR framework.
Can an authorised representative be responsible for previous packaging compliance problems?
Potentially, yes. Germany's Central Agency Packaging Register (ZSVR) states that the current authorised representative may be required to remedy certain outstanding obligations resulting from previous non-compliance by the manufacturer or a former authorised representative. This can include incomplete system participation or a missing Declaration of Completeness.
Can an authorised representative terminate its LUCID appointment?
Yes. The authorised representative can terminate the appointment directly through LUCID without requiring the manufacturer's consent. The manufacturer can also terminate the appointment.
Does terminating the LUCID appointment end all responsibilities?
No. Ending the appointment in LUCID does not automatically terminate the underlying contract and does not remove responsibility for legal obligations that arose during the period of appointment. Certain continuing obligations may therefore remain.
Does EaseCert support LUCID registration and German packaging compliance?
Yes. EaseCert supports international manufacturers and sellers with German packaging compliance, including LUCID-related requirements and the authorised representative framework. You can order the EaseCert LUCID Registration Service here.