German EPR, explained carefully.

German packaging EPR allocates responsibility for packaging placed on the German market. Since 12 August 2026 it runs on the PPWR and the VerpackDG, which replaced the repealed 2017 packaging act. Three duties form the base: an entry in the packaging register, participation in a dual system, and volume reports. A foreign seller without a German establishment must also appoint an authorised representative.

The party that first places the packaging on the German market carries the responsibility. A foreign seller shipping directly to German end users is that party itself, whether the order arrives through a marketplace or its own shop. Where a German company is first in the chain, for example a German importer buying for resale, that German company is the producer instead.

Yes. The packaging register operated by the Zentrale Stelle Verpackungsregister is free, online, available in German and English, and its producer entries are public and updated daily. Anyone can search an entry, including its number, identity, tax number, packaging types, brand names and, for a foreign company, the authorised representative.

No, and neither can anyone else. Registration is a strictly personal duty of the producer, and so is every later change to registration data. A registration performed by a third party does not fulfil the duty, even with your credentials. We prepare every field, guide the short session you run yourself, and then verify the result in the public register.

Since 12 August 2026, a producer with no establishment in Germany that makes packaging available to German end users, including by distance contract, must appoint an authorised representative established in Germany. Germany exercised the third-country option, so producers established inside and outside the EU are caught on the same terms. The central agency states that no exemption is possible.

The representative is deemed to be the producer and fulfils the producer duties in its own name: concluding the dual-system contract, filing volume reports, filing completeness declarations, take-back duties and deposit-system participation. The single carve-out is registration in the packaging register and changes to registration data, which stay personal to you. A producer may have only one representative at a time.

It must be a written authorisation in German, signed by both parties either by hand or with a qualified electronic signature. A bilingual version is allowed and the German version governs. A simple click-to-sign electronic signature is not accepted, because it does not satisfy German written form. The designation takes effect only when the central agency confirms it.

We do not know and we will not guess. No processing time for confirming a representative designation is published. We track the status and tell you when it changes rather than promising a date.

No, and no provider is. Germany deliberately chose a light regime with no approval, vetting or licensing of authorised representatives, and the central agency publishes no directory of them. Any provider claiming official approval is describing something that does not exist.

Since 12 August 2026 producers already registered without a German establishment are prompted at each login to name a missing authorised representative. It reflects a duty that already applies. The central agency names no deadline for adding it; the 12 November 2026 date for updating registration master data plausibly covers it, but that is an interpretation and we do not present it as settled law.

No. The register accepts a home-country VAT or tax number, one per company, and no German tax number is required. That number must match the one used in the dual-system contract and in marketplace accounts. What you need established in Germany is the authorised representative, not the seller.

No. The German mandate is executed by handwritten signature or qualified electronic signature. There is no notarial or apostille step in this route. The final document list and signing method are confirmed before anything is issued.

Germany publishes no statutory tariff: ten authorised dual systems compete and price bilaterally, and the central agency may not advise on the choice or on prices. Entry prices for prepaid small-quantity licences observed across the ten systems on 18 August 2026 ranged from about €12 to €89 per year. Above those quantities the price follows the system's own tariff by fraction. Any market average quoted anywhere, including here, is an observation with a date, never an official rate.

Packaging that ends up as waste at a private consumer is system-relevant from the first gram, and for a cross-border e-commerce seller that includes the carton, tape and void fill used to ship the order. Where transport packaging moves between businesses the analysis is different and we review it separately rather than applying one answer to both.

Section 68(1) VerpackDG keeps contracts concluded under the repealed act valid at the latest until the end of 31 December 2026. Every producer selling into Germany needs a contract under the new law for 2027. It is a legal expiry with a fixed date, not an ordinary renewal, and it lands on the entire market at once.

Every report filed to your dual system must be repeated in the register without delay and identically. Types are the initial planned-volume report, in-year adjustments, the closing annual report for the previous year due by 1 June, and supplementary reports. A producer below 10 tonnes of system-relevant packaging in the previous year may file a single closing annual report instead of mirroring, which covers most cross-border sellers; we confirm that anchor for the dossier rather than assuming it.

Almost certainly not. It is due by 15 May, with no extension, only above 80 tonnes of glass, 50 tonnes of paper and board, or 30 tonnes of the listed lightweight fractions taken together. A standard e-commerce seller is far below all three, although the authorities may require one regardless of thresholds.

Section 66 VerpackDG sets statutory maxima of up to €100,000 for missing, incorrect, incomplete or late registration, up to €200,000 for missing system participation, and up to €10,000 for volume-report breaches. These are maxima available to the competent state authority, not amounts we predict. No provision fines a missing representative directly; enforcement runs through the blocked registration, the finable incorrect registration and separate distribution prohibitions. The penalty tier aimed at marketplaces applies only from 12 February 2027.

No pay-on-behalf arrangement for German packaging has been identified, which is consistent with a registration the law makes strictly personal. Amazon has validated listings against the public register since 1 July 2022, and since 12 August 2026 marketplaces must also obtain a self-certification covering the representative designation. Confirm the current position in your own seller account; we do not publish Amazon fees, field names or deadlines without dated evidence.

No. Packaging, electrical and electronic equipment, batteries and single-use plastics are separate regimes with separate registers, systems and evidence. Electrical equipment follows the ElektroG and its register, including an insolvency-proof guarantee for household equipment. Batteries follow the BattDG, in force since 7 October 2025. Each requires classification and a manual quote.

Retroactive licensing of earlier trading years is standard practice in the German market and providers sell licence years for past periods. We quote it separately and always before anything is filed. It does not promise immunity from any consequence, and it is never bundled silently into a current-year price.

No. A proposal to suspend the packaging and battery representative duties exists and public reporting on its status conflicts. Nothing has been adopted, so Article 45(3) PPWR and section 5(2) VerpackDG apply in full today. We watch the file quarterly and write the engagement so that an EU-wide suspension would convert it rather than strand you.

No. We can scope, prepare and coordinate the private work described in a written proposal. The register, the central agency, the dual systems and the marketplaces control their own processing, records, timing and decisions.