Deadline 12 August 2026

From 12 August 2026: no representative, no distribution.

Foreign companies that count as a producer in Germany and have no establishment there must, from 12 August 2026, appoint a Germany-based authorised representative and assign them via LUCID. This page says who is covered, who is explicitly not, and the five steps involved.

Who is covered

Not everyone needs a representative.

1 · Direct to end customersCOVERED

You sell packaged goods directly to end customers in Germany, through your own shop or a marketplace, and have no establishment here. You count as the producer.

2 · Sales to German resellersUSUALLY NOT YOU

If you sell to resellers, importers or chains established in Germany, from 12 August the German buyer will generally count as the producer under a strict reading of domestic priority. The duty moves to them.

3 · Own establishment in GermanyNOT COVERED

If you are established in Germany you need no representative; you fulfil the duties yourself. A German company or branch replaces the mandate.

What has to be done

Five steps, one of them cannot be delegated.

Registration stays with you

Registration in the LUCID packaging register is a strictly personal duty of the obligated company. No representative may do it in your place.
Choose a representative

They must be established in Germany, external to your company, and offer this service. Your own employee becomes a processor, not the representative.
Written mandate

The mandate is given in writing and submitted as part of the registration. A verbal arrangement is not enough.
Assignment via LUCID

The representative is named in the packaging register and assigned to your registration.
Confirmation by the representative

The representative must confirm the appointment in LUCID. Each producer may appoint only one representative for extended producer responsibility.

If you do not

The goods may then not be placed on the market.

Packaging may only be placed on the market if the registration duties are met. Placing it on the market without proper registration is an administrative offence, with fines of up to 100,000 euros. In practice most companies notice the problem at the marketplace first, when the listing is blocked.

Important and honest: a company without a representative today is not in breach. The duty begins on 12 August 2026. What matters today is lead time.

Our own count

5,527 Turkish companies in the register. 62 have a representative.

On 25 July 2026 we read the public producer register of the Central Agency Packaging Register in full for producers established in Türkiye: 5,655 entries, 5,527 of them active. Sixty-two had an authorised representative, spread across nine German providers. The number is not an accusation but a measure of time: the duty has not started yet and almost nobody is prepared.

Our role

We are the German side.

CheckFREE

We check the public register for you: whether you are registered and whether a representative is assigned. Then we settle the prior question: whom do you sell to in Germany? That answer decides whether the duty is yours at all.

Set-upMUNICH · IN WRITING

We set the mandate up: written authorisation, assignment in LUCID, confirmation, plus the dual-system contract. We take the representative role ourselves or bring in an established provider, depending on product group and volume.

AfterwardsONGOING

Volume reports, deadlines, correspondence with the agency and the dual system: in Turkish with you, in German with the authorities. If you want to go further, the other route is your own German company, and the mandate falls away entirely.

Send us your company name. We will check the register and tell you whether the duty applies to you. Not legal advice, but a register lookup and a clear next step.

Get a free check

FAQ

Answered briefly

Can the representative also do my registration?

No. Registration in LUCID is a strictly personal duty and stays with the obligated company. The representative takes on the remaining extended-producer-responsibility duties.

I only sell to German retailers. Does this affect me?

Under a strict reading of domestic priority, from 12 August the buyer established in Germany generally counts as the producer, so the duty is theirs. Because it depends on the actual supply chain, it should be checked case by case.

Can I appoint more than one representative?

No. Each producer may appoint only one representative for extended producer responsibility.

Am I currently in breach of the law?

No. The duty to appoint begins on 12 August 2026. Until then the mandate was an option, not an obligation. That is why only a very small share of foreign producers has one so far.

Does this also cover electrical goods and batteries?

No. Electrical goods and batteries are separate regimes with their own representatives and requirements. We work on the packaging side and refer electrical and battery cases to specialised providers.

This page gives general information as of 25 July 2026 and is not legal or tax advice. A binding assessment of your case is made by a licensed lawyer or tax adviser; we coordinate that.

From 12 August 2026: no representative, no distribution.

Not everyone needs a representative.

Five steps, one of them cannot be delegated.

Registration stays with you

Choose a representative

Written mandate

Assignment via LUCID

Confirmation by the representative

The goods may then not be placed on the market.

5,527 Turkish companies in the register. 62 have a representative.

We are the German side.

Answered briefly

Call or write to us.