At a glance: appointing an authorised representative
Are you a company based abroad that sells empty packaging – or packaged products – directly to end users in Germany, and you do not have a branch in Germany? If so, you will be required to appoint an authorised representative as from 12 August 2026. On this day, the EU Packaging and Packaging Waste Regulation (PPWR) will come into force, as will the German Packaging Law Implementation Act (VerpackDG).
The authorised representative will assume all your obligations under extended producer responsibility – with one exception: registration in the LUCID Packaging Register. This is a personal duty that you have to fulfil yourself. You must appoint your authorised representative and enter their details in the LUCID Packaging Register before you make empty packaging or packaged products available for the first time on the German market. There is no exemption from this obligation.
Which packaging law obligations does an authorised representative have to fulfil?
The authorised representative assumes full responsibility for all obligations under the PPWR and the VerpackDG on your behalf, and will fulfil these in their own name. The only exception is registration in the LUCID Packaging Register. This is a personal duty that you have to fulfil yourself. Likewise, you will also 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 as well as your other obligations under packaging law 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 under section 39 VerpackDG
Participating in a nationwide deposit scheme for single-use beverage packaging subject to deposit
Throughout the entire duration of the contract, the authorised representative will be responsible for fulfilling these obligations on your behalf.
How does appointing an authorised representative work?
Select a suitable service provider
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) establishing the appointment, and
has a separate authorised representative login for the LUCID Packaging Register.
Please note: only individuals who are not affiliated with your company can offer their services as authorised representatives.
If a person working in your company carries out the registration on your behalf and maintains the registration details, please specify this person as a contact person in your producer registration in the LUCID Packaging Register – not as an authorised representative.
Enter into an authorisation agreement
As a company under obligation based abroad, you must first enter into an agreement with your authorised representative setting out the terms under which they will assume these obligations.
Please note that you can only appoint one authorised representative.
You must conclude a written agreement with your authorised representative – in German. If there are versions of the agreement in other languages, the German version will be binding.
The agreement must bear the handwritten signature or qualified electronic signature of both parties.
Please note that authorised representatives charge fees for their services; contact your authorised representative for details.
Enter the authorisation details in the LUCID Packaging Register
Once you have concluded the agreement with your authorised representative, the next steps will depend on whether you are registering with the LUCID Packaging Register for the first time or if you are already registered. In both cases, the authorised representative will need to already have a login, and an ID, for the LUCID Packaging Register. Only then will you be able to select and appoint the authorised representative there. Authorisation will only take effect once the ZSVR has confirmed it.
If you are not yet registered with the LUCID Packaging Register, please start the registration process. In the first step ('Master Data'), in addition to your own company details, also enter the company name or the ID of your authorised representative in the 'Authorised Representative' section.
Please note that you must provide the details of an authorised representative; otherwise, you will not be able to complete your registration.
With the implementation of the PPWR and the entry into force of the VerpackDG on 12 August 2026, companies based abroad and without a branch in Germany must appoint an authorised representative and register them with the LUCID Packaging Register. If you are already registered with the LUCID Packaging Register, you must update your registration details and subsequently specify your authorised representative. A pop-up window reminding you of this requirement will be displayed after logging in to the LUCID Packaging Register from 12 August 2026 onwards.