New Requirement in Germany: Foreign Companies Must Appoint an Authorized Representative

Effective August 12, 2026, new requirements apply in Germany to foreign companies that supply packaged products directly to German end consumers. Companies without a branch in Germany must then appoint an authorized representative in Germany to assume responsibility for producer responsibility regarding packaging consumption.

The change is related to the European Packaging and Packaging Waste Regulation (PPWR) and the new German implementing legislation.

Which companies are subject to this requirement?

The requirement applies to companies that:

• are located outside Germany;
• do not have an actual place of business or a registered branch in Germany; are not registered in the Commercial Register;
• deliver packaging or packaged products directly to end customers in Germany.

This includes, among other things, sales through online stores and other forms of distance selling. End users include not only private consumers, but also, for example, restaurants, hospitals, and similar organizations that do not resell the packaging they receive.

A German Gewerbeanmeldung—that is, a business registration with the Gewerbeamt—does not in and of itself constitute a full-fledged German branch office. A branch office registered in the German commercial register, on the other hand, can be considered a branch office. In that case, a separate authorized representative is generally not required.

No direct delivery to end customers?

Not every foreign company that exports products to Germany is automatically subject to the new requirement.

If a company supplies exclusively to a German importer, wholesaler, or other intermediary who then markets the products in Germany, responsibility for the packaging may fall to this German business partner. In that case, the foreign company may not be required to appoint an authorized representative.

What responsibilities does the authorized representative assume?

The authorized representative assumes the obligations related to extended producer responsibility for packaging on behalf of the foreign company. These may include, among other things:

• entering into a system participation agreement;
• reporting packaging quantities to the German packaging registry LUCID;
• submitting declarations of completeness;
• fulfilling applicable buyback obligations; and
• participation in a national deposit-return system for beverage containers subject to a deposit.

There is one important exception: the foreign company must register with the LUCID Packaging Registry itself. Changes to its own registration information also remain the company’s responsibility.

The authorized representative must be contractually appointed before the first relevant delivery in Germany and then registered in LUCID. This requires a written agreement in German. The authorized representative must also be established in Germany and registered as an authorized representative in LUCID.

Support from Zentek

Zentek GmbH & Co. KG offers foreign companies an authorized representative service, enabling them to act as an authorized representative in Germany. This service is combined with an agreement to participate in a German collection and recycling system.

The annual costs depend on the amount of packaging placed on the market in Germany:

• Less than 10,000 kg per year: €350
• More than 10,000 kg per year: €500

Check whether your organization is subject to the new requirement and whether all the necessary information has been correctly entered into the LUCID packaging registry.

What should companies do now?

Companies that sell products in Germany should check the following points:

1. Do we ship directly to German end customers? → Yes → Step 2 | No → Nothing
2. Do we have an actual business location in Germany that is registered in the commercial register? → Yes → Nothing | No → Step 3
3. Appoint a representative in Germany yourself, or appoint an authorized representative through a partner such as Zentek.

The German Zentrale Stelle Verpackungsregister may request that companies for which no authorized representative has yet been registered in LUCID complete this registration within a specified time frame. Therefore, do not wait to review this until you receive an official warning, as penalties may follow.

This article provides general information and does not constitute legal advice. If in doubt, have your specific sales and distribution structure reviewed or contact Zentek.

Sources: Central Packaging Register – Authorization and Regulation (EU) 2025/40 (PPWR).