Your register login asks for an authorised representative. What now?
Step 1
Read the prompt as the duty it reflects
Step 2
Agree the German-language mandate
Step 3
Name the representative in your master data
Step 4
Confirm the entry and replace the 2027 contract
| 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 |
Why you are seeing it
Since 12 August 2026 every already-registered producer without a German establishment is prompted at each login to name a missing authorised representative. The register passed one million registrations in April 2024, from more than 160 countries and with over 400,000 from China, so this is a very large cohort being told the same thing at the same time.
The prompt is a reminder, not a block. Whether an account without a representative becomes functionally restricted has not been verified, and we will not claim it is. What is certain is that the underlying duty has applied since 12 August 2026.
What the retrofit actually involves
The flow runs from the dashboard tile for the appointed representative, through naming the representative, a set of declarations, and a submission. Before you can select a provider there, that provider must already hold its own representative identifier in the register.
On our side the work is a German-language mandate signed by both parties, our identifier handed to you, the designation tracked until the central agency confirms it, and a dated check of your public register entry. There is no registration session to run, which is why the retrofit is priced below a first registration.
The deadline nobody will give you
The central agency names no deadline for adding a representative to an existing registration. Section 68(2) VerpackDG sets 12 November 2026 for updating registration master data, and that plausibly covers the representative entry, but it is not stated explicitly. We treat it as an interpretation and say so.
The honest position is that the duty applies now, the gap between 12 August and any interpreted deadline is legally untidy, and Germany has an active cease-and-desist industry. Whether trading without a representative in that gap is actionable is a question for counsel, not for a marketing page.
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.