For an answer to the question, please see the following excerpt from our FAQ page.
Any party who imports packaged goods that typically accumulate with private final consumers into Germany and places them onto the market here for the first time is subject to registration and system participation. This can be:
- any party located abroad that ships the goods to Germany;
- any party located in Germany that orders the delivery.
As a matter of principle, the party who bears legal responsibility for the goods at the time they cross the border is regarded as the 'importer'.
Further information can be found in our informational booklet on importers.