Your German EPR Representative

Sell to Germany. We handle your German packaging EPR.

German EPR representation for international businesses shipping packaged products directly to end users in Germany. Clear scope, direct contact and practical LUCID administration.

Appointment follows only after eligibility review, a written German mandate and confirmation in LUCID.

Based in Germany

A direct German contact instead of an anonymous compliance call centre.

Small-seller focused

A deliberately clear scope for manageable packaging cases.

English-first onboarding

Structured, digital and understandable from the first review.

Legal background

What changed on 12 August 2026?

Regulation (EU) 2025/40 on packaging and packaging waste - the PPWR - generally applies from 12 August 2026. In Germany, the Packaging Law Implementation Act (VerpackDG) applies at the same time.

A business established outside Germany and without a German branch that supplies empty packaging or packaged products directly to end users in Germany must appoint a German authorised representative under the current rules.

End users can be private consumers or professional end users who do not resell the product in the form supplied.

Once effectively appointed, the authorised representative fulfils in its own name the applicable EPR obligations that legally fall to the representative.

Your company must complete its own LUCID producer registration and update its master data. These are personal duties that cannot be transferred.

Practical administration

What we handle for you

PerliTech first accepts only cases whose complete German packaging activity fits the service model. After an effective appointment, PerliTech fulfils the applicable EPR obligations that legally fall to the authorised representative. You remain responsible for accurate information and your personal LUCID duties.

  • German packaging EPR representation within the agreed scope
  • Coordination and management of the required system participation agreement
  • Packaging quantity reporting in LUCID and annual closing quantity reporting
  • Ongoing overview of relevant reporting deadlines
  • Administrative communication connected with the German packaging EPR process
  • Structured documentation of submitted quantities and reporting status
  • Practical support around the German LUCID process
Focused scope. Fewer surprises.

PerliTech Standard EPR Scope

The standard service is designed for smaller businesses with ordinary sales, grouped and shipping packaging that typically becomes waste with private consumers or comparable sources.

Typical materials

  • Paper, cardboard and carton
  • Plastic
  • Glass
  • Aluminium
  • Ferrous metals
  • Other ordinary system-participating packaging materials
<10 t

Primary focus: below 10 tonnes per previous calendar year

This is not an exemption from EPR or system participation. Under the current ZSVR reporting rule, producers below 10 tonnes of system-participating packaging in the previous calendar year can generally submit one bundled annual closing quantity report in LUCID by 1 June of the following year instead of mirroring every system report immediately 1:1 in LUCID.

Not currently eligible for PerliTech’s standard representation service

  • German deposit scheme and deposit-bearing single-use beverage packaging
  • Complex beverage packaging obligations and reusable or deposit systems
  • Packaging with special take-back arrangements
  • Non-system-participating industrial or transport packaging with special return duties
  • Complex hazardous or special-product packaging cases
  • Cases requiring a declaration of completeness
  • Highly complex multi-entity EPR structures
  • Quantities outside the defined small-seller scope unless individually agreed

PerliTech currently does not accept standard representation mandates where German deposit obligations, complex reusable systems, special take-back obligations or other packaging-law duties outside the service model apply. You may still request an individual review. If products, packaging, quantities, brands, sales model, German establishment or other relevant activities change later, inform PerliTech before placing affected packaging on the German market so the continuation of the mandate can be reviewed.

Previous activity matters

Already sold to Germany? We need to know.

If your company supplied packaged goods to German end users before appointing PerliTech, earlier packaging obligations may still matter. Depending on the case, missing system participation, historical quantities, missing reports or an outstanding declaration may need review or remediation.

  • Disclose all previous sales and shipments to Germany truthfully and completely.
  • Provide previous LUCID, dual-system and quantity-reporting information.
  • Expect additional document requests where the history is unclear.
  • PerliTech may require remediation, quote extra work or decline a case that is too complex for the current scope.
Built for international sellers

Who this service is for

Especially suitable for manageable direct-to-Germany business models that need one clear German contact.

Typical sales channels

  • Shopify stores
  • WooCommerce stores
  • Amazon sellers
  • eBay sellers
  • Etsy sellers
  • Independent online shops
  • Brands and small manufacturers selling directly into Germany

Primary markets

  • United Kingdom
  • Switzerland
  • United States
  • Canada
  • Australia
  • Other non-EU countries
  • EU businesses without a German establishment, subject to a current legal-status check
Clear from the start

Your route to German EPR representation

  1. 1

    Enquiry, eligibility & history check

    After your enquiry, we review whether your business fits our scope and whether earlier German sales may have created outstanding obligations. PerliTech then decides whether the case can be accepted in principle.

  2. 2

    Written German mandate

    Both parties conclude the required German-language contract and sign it by hand or with a qualified electronic signature.

  3. 3

    Appointment in LUCID

    After the written German-language representative agreement has been properly concluded, you name PerliTech as your authorised representative in LUCID. The appointment becomes effective through the applicable LUCID/ZSVR confirmation process.

  4. 4

    EPR administration

    After the appointment becomes effective, PerliTech fulfils the applicable EPR obligations that legally fall to the authorised representative.

  5. 5

    Ongoing changes & annual close

    You report relevant changes before they affect the mandate. PerliTech reviews the case, reconciles actual annual quantities and administers the required closing report.

Personal, structured, realistic

Why PerliTech?

Selling to Germany should not mean learning every German packaging workflow yourself. PerliTech combines direct communication with a process- and IT-oriented way of working.

  • Based in Germany with direct personal contact
  • No anonymous compliance call centre
  • Focused on small and manageable businesses
  • Clear eligibility criteria before mandate acceptance
  • Structured digital onboarding and documentation
  • English-first international communication
  • Transparent responsibilities throughout the mandate
  • Direct review when products, packaging or sales models change

Frequently asked questions

Clear answers before you submit an enquiry.

What is EPR?

Extended Producer Responsibility means that the responsible producer finances and organises defined obligations for packaging placed on a market, including system participation and quantity reporting.

What does PPWR mean?

PPWR is the common abbreviation for Regulation (EU) 2025/40 on packaging and packaging waste. It generally applies from 12 August 2026.

Why do I need a representative in Germany?

Under the current German rules, foreign businesses without a German establishment that supply packaging or packaged products directly to German end users must appoint a German authorised representative.

Does this apply to companies outside the EU?

Yes, it can. Third-country sellers shipping directly to German end users are the primary target group for this service. Eligibility is checked before appointment.

Does this also apply to EU companies?

Under the current rules it can apply to businesses in other EU states without a German establishment. A pending EU proposal could change this for certain EU businesses, but it is not current law. We check before contracting.

Do I still need my own LUCID registration?

Yes. Producer registration and changes to your registration master data remain your company’s personal duties.

Can PerliTech register my company in LUCID for me?

No. PerliTech can provide practical guidance, but cannot take over the personal producer registration or master-data changes.

What does PerliTech handle after the appointment?

Once effectively appointed, PerliTech fulfils in its own name the applicable EPR obligations that legally fall to the authorised representative. Your own LUCID registration and master-data changes remain personal duties.

What is a German dual system?

A dual system organises the nationwide collection, sorting and recycling of system-participating packaging. A participation agreement finances these services for the declared quantities.

Does less than 10 tonnes mean I am exempt from EPR?

No. The threshold does not remove registration, system participation or other EPR duties. It only affects the simplified LUCID reporting rhythm under the current rule.

Which packaging materials are covered by the PerliTech standard service?

Ordinary system-participating packaging made from paper/cardboard/carton, plastic, glass, aluminium, ferrous metals and comparable standard materials, subject to eligibility review.

Do you handle German bottle deposits / Einwegpfand?

PerliTech currently does not accept a standard mandate where German deposit obligations for single-use beverage packaging apply. Ordinary glass packaging is not automatically deposit-bearing, so we review the exact case before acceptance.

Do you handle reusable packaging?

PerliTech currently does not accept a standard mandate where complex reusable or deposit systems apply. The case can still be reviewed individually before any mandate is accepted.

Do you handle large or complex packaging volumes?

The primary focus is below 10 tonnes in the previous calendar year. This is not an EPR exemption. Before accepting a mandate, PerliTech checks whether the complete activity fits the service model.

What information do you need from me?

Company and sales-channel details, German establishment status, packaging types and quantities, LUCID and system status, product brands, shipment estimates and a complete history of previous German sales.

Can Amazon, eBay or other marketplaces check my EPR status?

Online marketplaces can request and verify EPR registration information. Their platform checks do not replace your legal packaging obligations.

Is PerliTech a certified EPR agent?

There is no official EPR-agent certification claimed here. PerliTech acts on the basis of the required written representative agreement and the applicable LUCID/ZSVR appointment process.

How does the appointment become legally effective?

Submitting the enquiry and a positive pre-check do not create a mandate. After eligibility, scope and any required history review, PerliTech decides whether the case can be accepted in principle. The parties then properly conclude the written German-language representative agreement. The manufacturer names PerliTech in LUCID, and the appointment becomes effective through the applicable LUCID/ZSVR confirmation process.

What must I do if my business changes during the mandate?

Inform PerliTech before relevant changes affect your German EPR position. This includes new packaging or product types, deposit or reusable systems, substantial quantity increases, new brands, a changed sales model, a German establishment or comparable changes. PerliTech then reviews whether the mandate can continue.

Are system participation costs included in the PerliTech fee?

Not automatically. System participation and recycling costs are separate third-party costs unless an individual offer explicitly states otherwise.

Can PerliTech give legal advice?

No. PerliTech provides administrative EPR and compliance services. Individual legal assessments are outside the standard service and can be referred to qualified legal professionals.

I already sold to Germany before appointing PerliTech. Is that a problem?

Not necessarily. You must disclose the history. Depending on registration, system participation and reporting, earlier periods may require review or remediation.

Can PerliTech simply start from the appointment date?

Not always. Certain unfulfilled packaging obligations may concern earlier periods and may need to be addressed before or after an appointment.

What if I previously sold without a dual-system contract?

The facts must be reviewed before mandate acceptance. Subsequent system participation or other remediation may be required, but the website cannot decide that automatically.

Why do you ask about previous German sales?

Because an authorised representative may have to address certain outstanding obligations from earlier periods. A truthful compliance history is essential before PerliTech accepts a mandate.

Contact

EPR enquiry

Do you have questions about EPR representation or want to check whether PerliTech is right for your case? Send us a short message - we will clarify everything else personally.

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Transparent basis

Official sources & legal background

The information on this page was last reviewed against the following official sources on 13 August 2026.

Legal status last reviewed: 13 August 2026