Is every business sale treated as a German importer route?

No. A sale to a German importer or reseller that resells the goods as supplied must be distinguished from a direct sale to a German business that uses the product. The first moves producer responsibility to the German company; the second does not.

Does a register entry license my packaging?

No. The register entry, the authorised representative, the dual-system contract and the volume reports are four separate controls. A register entry without a system contract documents a producer that is not participating.

Regulation (EU) 2025/40 · applies now

Connect the PPWR representative rule to Germany’s actual register route.

Q: Did PPWR create the German packaging register?

No. Germany already had a packaging register and kept it. What changed on 12 August 2026 is that the VerpackDG replaced the previous packaging act and made an authorised representative mandatory for producers without a German establishment.

PPWR has applied since 12 August 2026 and the VerpackDG took effect the same day, repealing the 2017 German packaging act. Article 45(3) with section 5(2) VerpackDG requires a producer with no establishment in Germany that sells directly to German end users to appoint an authorised representative established in Germany. Germany exercised the third-country option, so EU and non-EU producers are caught alike, and no exemption exists.

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Rules in force · indicative scope only · no authority or marketplace outcome guaranteed

Germany · PPWR

12 · 08 · 2026

Representation: A written mandate in German, signed by both parties by hand or with a qualified electronic signature. The representative is deemed to be the producer and acts in its own name. The designation takes effect only when the central agency confirms it, and no processing time is published.
Register and licence: Registration in the packaging register is free and strictly personal to the producer. Licensing is separate: ten authorised dual systems compete, and one contract with any of them covers Germany.
Transition: Every system-participation contract concluded under the repealed act expires at the latest at the end of 31 December 2026. The penalty tier aimed at marketplaces applies only from 12 February 2027.

Four controls, not one number

Keep mandate, register entry, licence and reports distinct.

01 · SCOPE

Identify the producer

Map the selling entity, establishment, contract, marketplace and importer for each sales flow.

02 · REPRESENT

Agree the German mandate

A written authorisation in German, signed by hand or with a qualified electronic signature. It is not fiscal representation, and no approval scheme for representatives exists.

03 · REGISTER

Complete the entry yourself

Registration and every later change of registration data are a personal duty of the producer. We prepare each field and verify the public entry.

04 · LICENSE

Contract and report

One dual-system contract covers Germany, and every report filed to it is repeated identically in the register.

Route matrix

“B2B” is not enough information.

A German importer or reseller and a direct German business end-user do not lead to the same analysis. The test is whether the buyer resells the goods in the form supplied. Confirm who first places the packaging on the German market, and remember that a fulfilment warehouse is not an establishment.

Marketplace sale into Germany

A distance sale to a German end user. If the seller has no German establishment the representative duty applies, and no platform arrangement relieves it.

Own webshop — direct sale

Treated identically to a marketplace sale. German law does not distinguish the selling technique: both are distance sales to an end user.

Direct German business end-user

Do not label this automatically as a reseller sale. A business buyer that uses rather than resells the product is an end user, so the duty stays with the foreign seller.

German importer or reseller

Domestic precedence applies. Where a German company is first in the chain and resells the goods as supplied, that company is the producer and carries the duties.

German seat or registered branch

The entity registers and reports itself and is outside the representative duty. A fulfilment warehouse is not an establishment of the seller.

Mixed channels

Separate every flow. A reseller share can move responsibility to German buyers while direct and marketplace shares stay with you.

What to prepare now

Build one evidence chain per selling entity and route.

01
Confirm the seller
Legal entity, establishment, contracts and importer of record.
02
Map each route
Marketplace, own webshop, end-user and reseller flows kept separate.
03
Classify packaging
Annual grams by material fraction, including everything a fulfilment partner adds.
04
Choose a system
One contract with one of the ten authorised dual systems, for the calendar year.
05
Keep evidence current
Mandate, confirmed designation, register entry, contract, reports and invoices reconciled.

Indicative packaging service references

Amazon Starter €249 first year / €199 renewal · Standard €349/year + €150 setup

The dual-system licence, VAT and other third-party costs remain separate, and registration is free. Starter eligibility and every service scope require a written human review.

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Watch items

Keep the duty, the interpretation and the proposal apart.

Three things are often merged and should not be. The representative duty applies now and admits no exemption. The 12 November 2026 date for updating registration master data plausibly covers adding a representative to an existing entry, but that is an interpretation and not an explicit rule. And a proposal to suspend the representative duty EU-wide exists, with conflicting public reporting on its status; nothing has been adopted, so it changes nothing today.

Questions about PPWR and the VerpackDG in Germany

Did PPWR create the German packaging register?

No. Germany already had one and kept it. What changed on 12 August 2026 is that the VerpackDG replaced the previous packaging act and made an authorised representative mandatory for producers without a German establishment.

Does PPWR replace the register entry or the dual-system contract?

No. Registration, system participation and volume reports survived the rewrite unchanged in substance. The representative sits in front of them, not instead of them.

Is an own webshop treated differently from a marketplace?

No. Both are distance sales to a German end user and carry the same duties. There is no marketplace arrangement that relieves the seller, and no pay-on-behalf offering for German packaging has been identified.

Does the duty reach sellers established outside the EU?

Yes. Germany exercised the third-country opening clause in section 5(2) VerpackDG, so a producer established outside the EU is caught on the same terms as one established inside it.

Is every business sale a German importer route?

No. The test is whether the German buyer resells the goods in the form supplied. A business buyer that consumes the product is an end user, so the duty stays with you.

Does a small volume remove any obligation?

No. System participation applies from the first gram of packaging that reaches a private consumer, and the representative duty has no minimum. Below 10 tonnes a year the reporting is lighter, but the duties themselves are unchanged.

Can you guarantee a marketplace result?

No. We can prepare evidence for an agreed scope; Amazon and other marketplaces apply their own current fields, review and account decisions.

Primary sources · reviewed August 2026

General information only, not legal advice or an authority decision. Product, contract, marketplace and procedural facts require individual review.

Map the German route before presenting evidence to a marketplace.

One scope first; any work, price and timeline confirmed separately in writing.

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