In order to comply with the German Packaging Law (VerpackG) it is not mandatory for non-German companies to appoint a German representative.
The amendment to the Packaging Act of July 2021 has not changed this – it merely has added the option for foreign companies to appoint an authorised representative if they do not want to carry out the licensing themselves. In this case, the authorised representative will take care of participation in a dual system (e.g. Interseroh+ via Lizenzero) and data reporting in LUCID (internet platform of the Central Packaging Register Foundation (ZSVR)) on your behalf. The registration with LUCID would still be your responsibility.
As a foreign entrepreneur, you have two options:
- Fulfil your obligations directly yourself. This means:
- Register your company at the official packaging register as a producer:
- License your packaging with a dual system (e.g easily online with Lizenzero)
- Report your data (= name of your dual system (Interseroh+), and licensed volumes) to LUCID
- Appoint an authorised representative: Search for a German representative in order to fulfill the packaging licensing. This option might come with additional costs.