For an answer to the question, please see the following excerpt from our FAQ page.
Any party who is the first to import packaged goods into Germany, and place them on the German market, is considered an importer and subject to registration. The importer can be
- located outside of Germany, shipping goods to Germany; or
- located in Germany, ordering the shipment.
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 knowledge base "Guidance for importers".