EPR Obligations EU → Authorized representative → 🇩🇪 Germany
Authorized Representative in Germany 2026:
Who Needs One and Why
In Germany the answer depends on the product. For packaging, only distance sellers without a German branch need a representative. For electrical equipment and batteries, every producer without a German establishment does.
Last reviewed: · Sources linked below
Short answer: for packaging, § 5 VerpackDG has required an authorized representative since 12 August 2026 — but only from producers that have no German branch and sell directly to end users in Germany. For electrical equipment and batteries, producers without a German establishment register with stiftung ear through an authorized representative (Bevollmächtigter). The LUCID registration itself always stays with the producer.
Authorized representative in Germany at a glance
- Packaging
- § 5 VerpackDG, since 12 August 2026: only producers without a German branch that sell directly to end users in Germany.
- Electrical equipment
- Producers without a German establishment need an authorized representative (Bevollmächtigter) for the stiftung ear registration (ElektroG).
- Batteries
- Producers without a German establishment register with stiftung ear through an authorized representative (BattDG, EU Battery Regulation).
- How many
- Packaging: only one representative.
- Form
- Packaging: contract in German. The producer enters the representative in LUCID; the appointment takes effect once the representative confirms.
- Registration
- The LUCID registration stays with the producer and is free of charge.
- Official fee
- stiftung ear charges €50.60 (net) for confirming a representative under the ElektroG.
- Exemption?
- Proposal – not yet law For small EU-established packaging producers only.
Do I need an authorized representative in Germany?
Check two things: do you have a branch or establishment in Germany, and do you sell directly to end users there?
| Your situation | Packaging | Electrical equipment | Batteries |
|---|---|---|---|
| Company established in Germany | No | No | No |
| Online shop in another EU country shipping to end users in Germany, no German branch | Yes (§ 5 VerpackDG) | Yes | Yes |
| Seller outside the EU (for example US, UK, China) selling directly to end users in Germany, no German branch | Yes (§ 5 VerpackDG) | Yes | Yes |
| Foreign company with a German branch | No § 5 duty | Depends on whether the branch counts as an establishment — we check this | Depends on whether the branch counts as an establishment — we check this |
| Foreign company that does not sell directly to end users in Germany | No § 5 duty | Yes, if you are the producer and have no German establishment | Yes, if you are the producer and have no German establishment |
Not sure whether you count as the producer? Ask for a free check.
Why the answer depends on the product
Germany has three laws and two registers, and each law draws the line differently. Packaging falls under the VerpackDG and the LUCID register of the ZSVR (Zentrale Stelle Verpackungsregister). Electrical equipment falls under the ElektroG, batteries under the BattDG and the EU Battery Regulation — both registered with stiftung ear.
The purpose is the same in all three: a company without a presence in Germany needs a party inside Germany that the register can address and that fulfils the producer's duties there. For packaging, § 5 VerpackDG limits this to producers that sell directly to end users — the group the EU Packaging Regulation (Art. 45 PPWR) addresses as well. For electrical equipment and batteries it applies to every producer without a German establishment.
What changed on 12 August 2026: the VerpackDG, together with the PPWR, replaced the old VerpackG. The § 5 representative duty for packaging is new since that date.
Packaging: how the appointment works (§ 5 VerpackDG)
For packaging, the representative is added to your own LUCID registration — it does not replace it. According to the ZSVR, the steps are:
- Choose one representative. A producer can appoint only one authorized representative in Germany.
- Sign the contract in German. The appointment contract has to be in German.
- Enter the representative in LUCID. The producer does this in its own LUCID account.
- Wait for confirmation. The appointment takes effect once the representative confirms it in LUCID.
The LUCID registration with the ZSVR stays in the producer's name and is free of charge. If you registered before 12 August 2026, your registration remains valid; changes to the registration data have to be made by 12 November 2026.
Electrical equipment and batteries: registration through the representative
For electrical equipment and batteries, a producer without a German establishment cannot register on its own: the registration with stiftung ear runs through the authorized representative.
| Product | Rule | Official stiftung ear fees (net) |
|---|---|---|
| Electrical and electronic equipment (ElektroG) | Registration per brand and device type before placing on the market; insolvency-proof guarantee for consumer (B2C) equipment; producers without a German establishment need a representative | Registration €9.50 per device type; confirmation of the representative €50.60 |
| Batteries (BattDG, EU Battery Regulation) | stiftung ear registers producers; joining a producer responsibility organisation is mandatory since 1 January 2026; producers without a German establishment register through a representative | Registration €16.40 per category |
Processing times at stiftung ear vary; plan several weeks for the financial guarantee. These are the register's own fees — the representative's service fee comes on top.
Registers, deadlines and fines in full: EPR in Germany.
What happens without a representative
For electrical equipment and batteries, no representative means no registration — and the registration has to exist before the products are placed on the market. For packaging, § 66 VerpackDG provides for fines of up to €200,000, €100,000 or €10,000 depending on the offence; fines linked to the PPWR apply from 12 February 2027.
Marketplaces check too: Amazon.de requires the 13-digit LUCID number and, for electrical equipment, the stiftung ear registration. Non-compliant offers may be deactivated, or Amazon may comply on the seller's behalf. eBay may hide listings without the packaging EPR number.
Would the proposed EU exemption help?
Only small producers established in the EU, only for packaging — and only once it is law. It would not change the representative duty for electrical equipment under the ElektroG.
Proposal – not yet law EU exemption for small EU-established producers. The European Commission's Environmental Omnibus of 10 December 2025 proposes suspending the authorized-representative duty for producers established in the EU. The European Parliament adopted its position on 20 October 2026 (as reported: an exemption for EU micro and small enterprises until 2035). The Council's negotiating mandate of 21 October 2026 covers packaging only: EU-established producers placing less than 1 tonne of packaging per year in another member state would not need a representative there until 1 January 2032. It does not cover batteries. Trilogue negotiations follow. None of this is law yet, and none of it helps sellers established outside the EU — until a final text is adopted, the current duty applies.
Dates that matter for Germany
| Date | What applies |
|---|---|
| 18 Aug 2025 | EU Battery Regulation: EPR regime; stiftung ear registers battery producers |
| 1 Jan 2026 | Batteries: joining a producer responsibility organisation is mandatory |
| 12 Aug 2026 | VerpackDG in force; § 5 representative duty for packaging |
| 12 Nov 2026 | Existing LUCID registrations: changes to registration data due (§ 68 VerpackDG) |
| 31 Dec 2026 | Dual-system participations concluded before 12 August 2026 end at the latest |
| 12 Feb 2027 | PPWR-related fines under § 66 VerpackDG apply |
Full calendar: EPR deadlines 2026–2027.
How Certify helps
- Free obligation check. Tell us what you sell into Germany, through which channels (Amazon, eBay, your own shop) and where your company is established. We tell you which representative duties apply to you — and which do not.
- Registration and representation. Certify prepares the registrations and, where the law requires it, acts as your authorized representative. Certify offers an authorized representative in all EU member states.
- Ongoing compliance. Certify supports the recurring declarations and reports, so your registration numbers stay valid for marketplaces and authorities.
This page explains the obligation. If you already know that you need a representative, the practical steps are on our sister site: appointing an EPR authorized representative (register-epr.com).
FAQ: authorized representative in Germany
Who needs an authorized representative for packaging in Germany?
Since 12 August 2026, § 5 VerpackDG requires one only from producers that have no German branch and sell directly to end users in Germany. This applies to sellers from other EU countries and from outside the EU.
Do I need a representative for electrical equipment and batteries?
Yes, if you are the producer and have no German establishment. For electrical equipment you need an authorized representative (Bevollmächtigter) for the stiftung ear registration; battery producers without a German establishment also register with stiftung ear through an authorized representative.
Does the representative replace my LUCID registration?
No. The LUCID registration stays with the producer. The producer enters the representative in LUCID, and the appointment takes effect once the representative confirms it.
Can I appoint more than one representative in Germany?
For packaging, no: a producer can appoint only one authorized representative, and the contract has to be in German.
What does stiftung ear charge for the representative?
stiftung ear charges 50.60 euros net for confirming an authorized representative under the ElektroG. The registration itself costs 9.50 euros net per device type. The representative's own service fee is separate.
I am an EU company. Is the representative duty being abolished?
Not yet. An exemption for EU-established producers that place less than 1 tonne of packaging per year in another member state is being negotiated at EU level. It is a proposal, it concerns packaging, and until a final text is adopted the current duty applies.
- ZSVR: Authorising a representative
- ZSVR: What changed on 12 August 2026
- VerpackDG – Verpackungsrecht-Durchführungsgesetz (gesetze-im-internet.de)
- § 66 VerpackDG – administrative fines
- § 68 VerpackDG – transitional provisions
- stiftung ear: costs and fees
- stiftung ear: press release on battery registration (18 August 2025)
- Amazon.de: extended producer responsibility
- EUR-Lex: Regulation (EU) 2025/40 (PPWR), Art. 45
- Council of the EU: negotiating mandate of 21 October 2026 (document 14765/26)
This page is general information, not legal advice. Last reviewed 5 November 2026.
Related guides
Representative rules differ from country to country and from product to product:
Check whether you need a representative in Germany
Tell us what you sell to German customers and where your company is established. You receive a structured answer on which German registrations and which representative roles apply to you. Your message is delivered directly to Certify — specialists in EU-wide producer responsibility compliance. Free first consultation, no obligation.