Germany's packaging representative rule: the EU's October 21 relief does not cover sellers outside the EU

Since August 12, 2026, a company with no branch in Germany that sells packaged goods directly to German end users must appoint a packaging EPR authorised representative in Germany, the German packaging register ZSVR says. On October 21, EU governments agreed a position that would lift a similar duty for small producers, but only for producers established in the EU.

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What changed

Before, such an appointment was usually voluntary, Cifnews notes. Under the new law that took effect on August 12, 2026, it is required for companies based abroad that have no branch in Germany and sell empty packaging or packaged products directly to end users there, without an intermediary retailer. According to the German packaging register ZSVR (Zentrale Stelle Verpackungsregister), the representative must:

• have a registered office or branch in Germany and not be affiliated with your company;
• hold a separate authorised representative login for the LUCID packaging register;
• sign a written agreement with you in German (the German version is binding if there are translations), with handwritten or qualified electronic signatures from both sides.

You can appoint only one. The representative takes over the producer obligations, but registration in LUCID stays your own job. Existing registrants add the representative from the "Authorised representative" tile on the LUCID dashboard; the link takes effect once the representative confirms it, and they appear in the public register the next day (ZSVR help).

Separately, the EU is simplifying the PPWR rule that makes producers appoint a representative in each member state where they sell. On October 21, the Council agreed its position: producers established in the EU would not need one in a member state where they place less than 1 tonne of packaging per calendar year. The Commission must review the suspension by December 31, 2030, before it is scheduled to expire in 2032. A day earlier, the European Parliament adopted its own position, aimed at EU-based small and micro enterprises (under 50 staff and under EUR 10 million turnover or balance sheet) and with no tonnage threshold (LexisNexis, October 20). The two now negotiate the final text.

What it means for your business

If you sell from the US, Canada, China or anywhere else outside the EU and ship parcels straight to German customers, the October 21 news does not change your to-do list: neither EU position, as described by the Council and in published summaries of the Parliament text, extends the relief to producers outside the EU, and the German requirement already applies. If you are an EU-based seller shipping into Germany from another member state, the relief could matter once it is adopted. The threshold is set by weight, so here is what 1 tonne a year means in orders:

Our arithmetic: 1 tonne = 1,000,000 g, divided by packaging weight per order. Weigh your own packaging; product packaging counts too.

Which situations need a German representative today, per ZSVR's wording (sales directly to end users, no German branch):

A product authorised representative (the "EU rep" many sellers already have for product safety) is a different role under different laws. Cifnews notes that it does not automatically meet the German packaging requirement; ZSVR's conditions (German seat, LUCID representative login, German-language agreement) apply either way.

Who is affected

• Marketplace and webshop sellers outside the EU (including Etsy, eBay and Amazon sellers) who ship packaged goods to buyers in Germany.
• Chinese and other non-EU factories and brands that sell directly to German consumers or businesses that are the final users.
• EU-based small sellers shipping into Germany from another member state, who should watch the final EU text.

What to do now

1. Check whether you sell directly to end users in Germany and have no German branch. If both are true, you need a representative now.
2. If you are registered in LUCID, log in and look for the authorised representative reminder; your registration number stays.
3. Pick a provider with a German office and a LUCID representative login, sign the agreement in German, and submit the request from the LUCID dashboard. Confirmation by the representative is what makes it valid.
4. Keep your own LUCID data up to date and keep reporting packaging volumes through your dual system: the representative does not take over registration.
5. If you are EU-based, note the proposed 1 tonne threshold, but do not stop complying until the final law is published.

General information, not legal, tax or customs advice. Rules change often: check the official sources above or a licensed customs broker before you act. SuanSupply is not affiliated with any government agency or marketplace named here.