Sell to Germany.
Here is what you need to know:
New Packaging Regulations. New Responsibilities.
Since August 12, 2026, the European Packaging and Packaging Waste Regulation (PPWR) has applied across the European Union.
Affected businesses established outside Germany that supply packaged products directly to German end users are required to appoint an Authorized Representative based in Germany.
This currently applies to eligible businesses established both within and outside the European Union.
The requirement is part of a broader set of obligations concerning packaging registration, recycling system participation and packaging quantity reporting.
Who Is Affected?
You may need a German Authorized Representative if your company:
-
Is established outside Germany.
-
Sells packaged products directly to German end users.
-
Operates an international online shop shipping to Germany.
-
Sells through online marketplaces such as Amazon, eBay or Etsy.
-
Ships consumer goods in sales or shipping packaging.
Even small businesses and low packaging volumes may be subject to these requirements.
The exact obligations depend on your business model, packaging types and distribution channels.
What Happens If You Don’t Comply?
German packaging regulations are legally enforceable.
Certain violations, including failure to participate in a required packaging recycling system, can result in fines of up to €200,000.
Businesses that fail to meet applicable registration and system participation obligations may also be prohibited from placing the affected packaged products on the German market.
Online marketplaces and fulfilment service providers have their own verification obligations under German packaging law.
Compliance is therefore essential for maintaining access to German customers.
What Does an Authorized Representative Do?
An Authorized Representative acts on behalf of a foreign manufacturer within the scope of the applicable packaging legislation and the authorization granted.
The relevant activities can include:
-
Managing packaging system participation.
-
Submitting required packaging quantity reports.
-
Handling relevant administrative communication.
-
Maintaining documentation relating to the authorized activities.
-
Supporting ongoing compliance with applicable reporting requirements.
The manufacturer remains responsible for providing accurate and complete information about its business and packaging quantities.
What Is LUCID?
LUCID is Germany’s official packaging register, operated by the Central Agency Packaging Register (ZSVR).
Manufacturers subject to registration obligations must register their business in LUCID.
The initial registration must be completed by the manufacturer itself.
Once the Authorized Representative has been properly appointed and the relevant authorization is established, the representative can perform the activities covered by the mandate.
How SellToGermany Makes It Simple
-
Create Your Account
Enter your company and contact details. -
Upload Your Documents
Upload the required company document and a signed copy of the German authorization agreement. -
Preliminary Review
We review your company details and documents before issuing the invoice. -
Declare Your Packaging
Enter your estimated packaging quantities for the relevant calendar year. -
Receive and Pay Your Invoice
Your invoice will be made available in the customer portal. You will also receive an email with payment instructions. -
Complete the LUCID Appointment
After payment, you will receive the representative ID required to complete the appointment in LUCID. -
Send the Paper Originals
Send us two signed originals of the German authorization agreement. We will countersign one copy and return it to you. -
Activation
Once all requirements have been met, we activate the mandate and handle the agreed reporting and system-participation activities.
What happens after you submit your application?
Once you have completed the application and uploaded a signed copy of the authorization agreement, our team will review your company details and documents.
After the preliminary review has been successfully completed:
-
Your invoice will be issued and made available in the customer portal.
-
You will receive an email notification with payment instructions.
-
Once payment has been received, we will provide the representative ID required to complete your LUCID registration or appoint SellToGermany as your authorized representative.
-
You must send us two signed paper originals of the German authorization agreement.
-
We will countersign one original and return it to you.
-
Your mandate will be activated once the required originals have been received and accepted and the necessary LUCID steps have been completed.
Only after activation can SellToGermany submit the relevant packaging quantities to LUCID and arrange participation in the German dual system on your behalf.
You can track outstanding tasks, document status, invoices and payments in your customer portal at any time.
Simple, Transparent Pricing
Annual Representative Service - €169 per calendar year (excluding VAT, where applicable)
Our annual fee includes:
-
No setup or onboarding fees
-
Digital onboarding and document management
-
Ongoing representation and compliance administration
-
Annual reporting support and reminders
-
One annual reconciliation based on your actual packaging quantities
German dual-system participation costs are calculated separately and depend on your packaging materials and quantities.
If supplementary system participation is required during the calendar year, a €25 net administration fee per completed supplementary order applies, in addition to the relevant dual-system participation costs.
All applicable charges will be shown to you for approval before an order is placed.
How annual reporting and billing works
German packaging compliance operates on a calendar-year basis.
Before the beginning of each reporting year—or before you first place packaged goods on the German market—you provide your estimated packaging quantities for that calendar year.
Based on these quantities, the portal calculates:
-
the annual SellToGermany service fee;
-
the applicable German dual-system participation costs; and
-
the total amount payable for the relevant calendar year.
After your information and documents have been reviewed, an invoice will be made available in the portal.
You will also receive an email with a link to the invoice and the available payment options.
At the beginning of the following calendar year, you submit your actual packaging quantities for the previous year. We compare these actual quantities with the total quantities already covered through your initial and any supplementary system participation.
-
If your actual quantities are higher, you will receive an additional invoice for the positive difference in dual-system participation costs. The annual reconciliation itself is included in your annual service fee.
-
If your actual quantities are lower than the total quantities already placed into system participation through SellToGermany, no refund or credit will be issued. Quantities ordered through SellToGermany cannot be reduced or withdrawn once the system-participation order has been completed.
We therefore recommend providing a careful and realistic initial estimate without adding an unnecessary safety margin.
Customers joining SellToGermany with a pre-existing system-participation contract must disclose that contract during onboarding.
SellToGermany may, following review and where operationally possible, administer the existing arrangement for its remaining contractual period.
This transitional support does not give the customer a continuing right to select the dual-system provider used within the SellToGermany service.
After the pre-existing arrangement has ended, system participation managed through SellToGermany will be placed with a dual-system provider selected by SellToGermany.
SellToGermany may change its selected provider where necessary for operational, commercial or compliance reasons.
During the authorisation period, the customer must not independently place, transfer or amend quantities with another dual-system provider where those quantities fall within the services managed by SellToGermany, unless SellToGermany has agreed to this in writing beforehand.
Any potential adjustment or refund under a pre-existing system-participation contract concluded directly by the customer remains governed exclusively by that separate contract and the relevant provider’s terms.
SellToGermany does not guarantee or fund refunds arising from such external contractual arrangements.
What happens if my packaging quantities increase during the year?
You do not need to report every operational fluctuation.
However, if your revised annual forecast indicates that your packaging quantities will exceed the quantities already covered by system participation, you must notify SellToGermany before the additional quantities are placed on the German market.
SellToGermany can arrange supplementary system participation.
Each completed supplementary order is subject to an administrative fee of EUR 25 net, plus the applicable system-participation costs and any applicable VAT.
All amounts are shown for approval before the order is placed.
Multiple changes received before processing may be consolidated into one supplementary order. Lower actual quantities do not automatically create a refund or credit.
Why is the authorization agreement in German?
The authorization is used for the German regulatory process and must meet the applicable German formal requirements. We provide an English translation for convenience, but the German version is the legally relevant document that must be signed and submitted.
Why Choose SellToGermany?
Simple. A straightforward online process designed for international businesses.
Transparent. Clear pricing without a separate onboarding fee.
Convenient. Company details, packaging declarations and documents in one place.
Secure. Your business data is hosted in Germany.
Focused. A specialized service for German packaging compliance.
Ready to Get Started?
Make German packaging compliance one less thing to worry about.