The company under obligation under the Verpackungsgesetz (Packaging Act) must itself submit the data report to the LUCID Packaging Register. 

There is an exception for international companies without a branch in Germany (for example companies located in China, the UK, the USA, Poland or Italy): if such a company has appointed an authorised representative to fulfil its obligations under packaging law, the authorised representative must submit the data report for the party under obligation. In this case, all the international company has to do is register with the LUCID Packaging Register and enter its authorised representative.