In force since 12 August 2026
Selling to another EU country and needing a representative there
A business that sends packaged goods straight to customers in another EU country has to appoint someone based in that country to handle its packaging duties there. The rules call this person an authorised representative for extended producer responsibility. It has to be done in writing, and separately for each country. For businesses based outside the EU the picture is different: each country decides for itself whether to require one.
Where a country does it differently
Austria requires a foreign seller without an Austrian base to appoint an Austrian representative. Austria also asks for more than a signed letter. The appointment has to be notarised, written in German or English, list which collection and treatment categories it covers, and record that the representative agrees to take on the duties.
Source: Unternehmensserviceportal (USP), Republic of Austria — read from this source on
In Germany an authorised representative takes on every extended producer responsibility duty except one: entry in the LUCID packaging register. Registering, and later changing those registration details, stays a duty of the business itself and cannot be handed over.
Source: Zentrale Stelle Verpackungsregister (ZSVR) — Packaging Act: Authorised representatives — read from this source on
A business based outside Germany that sells empty packaging or packaged goods straight to end users in Germany, with no branch there, appoints an authorised representative. That representative is entered in the LUCID register before anything is first made available on the German market. The German rules set out no exemption.
Source: Zentrale Stelle Verpackungsregister (ZSVR) — Packaging Act: Authorised representatives — read from this source on
Situations where this one comes up
A business puts its own name or logo on the packaging it sends out, and posts orders to customers in more than one EU country. It is not a very small business by the size test, or it is but buys its packaging from abroad.
A business registered outside the EU sends packaged goods directly to people in EU countries, rather than selling to a distributor who resells them.
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