compliance teamEPR in Germany: a practical guide for foreign sellers
Step 1
Identify the producer
Step 2
Appoint a representative where required
Step 3
Register personally and license the volumes
Step 4
Report consistently and keep the evidence
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
Start with the producer, not the brand
German packaging responsibility attaches to the Hersteller: the party that first places the packaging on the German market. It is not decided by a brand name, a warehouse or a checkout page. Record the seller, its country of establishment, whether it has a German branch, the customer and the route by which the product reaches Germany.
Domestic precedence matters. Where a German company is first in the chain, for example a German importer buying for resale, that German company is the producer. A foreign seller shipping directly to a German end user is the producer itself, whether the order came from a marketplace or its own shop.
Four duties, in a fixed order
Since 12 August 2026 a producer without an establishment in Germany that sells directly to German end users must appoint an authorised representative. Then comes the register entry, which the producer must complete personally. Then a contract with one of the ten authorised dual systems. Then volume reports, filed to the system and repeated identically in the register.
The order is not a preference. A foreign producer cannot complete a first register entry while the representative field is empty, and a register entry on its own licenses nothing. Skipping a step leaves a documented producer that is not participating in any system.
Keep the other streams separate
Electrical equipment follows the ElektroG and its own register, including an insolvency-proof guarantee for equipment sold to households. Batteries follow the BattDG, in force since 7 October 2025. Products listed in Annex 1 of the single-use plastics fund act carry their own registration, levy and a separate German-established representative duty.
A device with a battery in a box can therefore create three or four files. One German-established entity can serve several of those representative roles, but no single registration ever covers them all. German transposition of the EU textile directive is due by 17 June 2027 and nothing is operating yet.
Conclusion
Scope comes before a form. Connect the legal entity, its German establishment, the product, the sales channel and the EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. The packaging register, the central agency, the dual systems and the marketplaces control their own procedures, timing and decisions.