Authorising a representative

Yes. You need an authorised representative if you are a company based abroad that sells empty packaging – or packaged products – directly to end users in Germany and do not have a branch in Germany.

The authorised representative assumes full responsibility for all obligations on your behalf, and will fulfil these in their own name. The only exception is registration with the LUCID Packaging Register. Likewise, you will also continue to carry out any changes to your LUCID registration details. Once appointed, the authorised representative will take care of all further activities relating to the LUCID Packaging Register and fulfil your other packaging law obligations (e.g. system participation) on your behalf. These include, in particular:

• Concluding a system participation agreement with one or more system operator(s)

• Submitting reports about packaging volumes to the LUCID Packaging Register

• Submitting declarations of completeness to the LUCID Packaging Register

• Compliance with return obligations for packaging that is not subject to system participation under section 39 VerpackDG (German Packaging Law Implementation Act)

• Participating in a nationwide deposit scheme for single-use beverage packaging subject to deposit

• The authorised representative can be any natural or legal person with a registered office or branch in Germany,

• who enters into a written agreement (in German) with you establishing the appointment, and

• has a separate authorised representative login for the LUCID Packaging Register.

Only natural or legal persons who are not affiliated with the company can offer their services as authorised representatives. 

No. The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) does not publish a list of authorised representatives registered with the LUCID Packaging Register. However, various service providers offer this authorised representative service. You are responsible for checking which service provider is suitable for your needs.

First of all, you select a suitable service provider and enter into an authorisation agreement with them. You then enter the appointment of this authorised representative in the LUCID Packaging Register. The authorised representative can be any natural or legal person with a registered office or branch in Germany who enters into a written agreement (in German) with you establishing the appointment and has a separate authorised representative login for the LUCID Packaging Register.

Please note: only natural or legal persons who are not affiliated with the company can offer their services as authorised representatives. 

Detailed information can be found in our knowledge base dedicated to authorised representatives.

If you are not yet registered with the LUCID Packaging Register, please start the registration process. In the first step ('Master data'), you enter the company name or the ID of your authorised representative in the 'Authorised representative' section.

The EU Packaging and Packaging Waste Regulation (PPWR) and the German Packaging Law Implementation Act (VerpackDG) introduce new obligations for companies not based in Germany. If you are required to appoint an authorised representative under the new legislation, you must name this authorised representative when you first register with the LUCID Packaging Register. If you do not provide this information, you will not be able to complete your registration with the LUCID Packaging Register.

Under the EU Packaging and Packaging Waste Regulation (PPWR) and the German Packaging Law Implementation Act (VerpackDG), companies based abroad and without a branch in Germany must appoint an authorised representative to fulfil their obligations under packaging law and must add that authorised representative to the company's entry in the LUCID Packaging Register. If you are already registered with the LUCID Packaging Register, you must update your registration details and add your authorised representative. You will find the 'Authorised representative' tile on your LUCID dashboard. Use this tile to indicate your authorised representative.

1. Click 'Edit' in the tile.

2. Click on the 'Appoint an authorised representative' button.

3. Then enter the company name or the ID of the authorised representative you have concluded an agreement with. 

4. Scroll down to the 'Declarations' section and check the boxes to save the name.

5. Then press 'Submit request'.

You have stated in your master data that your company's registered office is outside of Germany. Under the EU Packaging and Packaging Waste Regulation (PPWR) and the German Packaging Law Implementation Act (VerpackDG), you are required to appoint an authorised representative to fulfil your packaging law obligations in Germany. This means that you must adjust your registration details accordingly and add your authorised representative to your entry in the LUCID Packaging Register. Please proceed as follows:

1. Either click on the 'Appoint an authorised representative now' button at the end of the notification or go to your LUCID dashboard and click 'Edit' in the 'Authorised representative' tile.

2. Click on the 'Appoint an authorised representative' button.

3. Then enter the company name or the ID of the authorised representative you have concluded an agreement with. 

4. Scroll down to the 'Declarations' section and check the boxes to save the name.

5. Then press 'Submit request'.

Your authorised representative has to be registered with the LUCID Packaging Register. Check with your service provider to see if they are already registered as an authorised representative and have the necessary identification number (ID).

The EU Packaging and Packaging Waste Regulation (PPWR) and the German Packaging Law Implementation Act (VerpackDG) introduce new obligations for companies based outside of Germany. If you change the registered office filed in the master data, and that change includes a move from Germany to another country, you must file all the details regarding your authorised representative. If you fail to do so, you will not be able to complete the change. 

Further information can be found in our knowledge base dedicated to authorised representatives.

Yes. Your authorised representative can terminate their appointment for your company in the LUCID Packaging Register themselves. You will receive an e-mail, informing you of the termination.