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4.7 Can an appointed third party or broker submit data reports?

No, the Verpackungsgesetz (Packaging Act) prohibits the instruction of a third party for data reporting. Data reporting must be completed personally by the producer under obligation or an appropriately authorised contact person within the producer's company. This must also be confirmed with each report.

Exception: international producers under obligation without a branch within Germany can appoint an authorised representative to fulfil their duties under the Verpackungsgesetz on their behalf. (This does not apply, however, to registration.) Further information can be found in our knowledge base dedicated to authorising a representative.