Contractual agreements
To act as an authorised representative, a written agreement with an international producer is required.
At a glance: appointing an authorised representative
If you are an international online retailer, importer or manufacturer of goods and ship your packaged goods to Germany, the Verpackungsgesetz applies to you. International companies without a branch in Germany can appoint an authorised representative to fulfil their obligations on their behalf. If you do not make use of this option, you must fulfil the obligations yourself.
No matter what type of packaging you use (i) to distribute your goods commercially in Germany or (ii) to hand them over to your German customers: you have to be registered with the LUCID Packaging Register. Depending on the packaging type, you might also be required to pay for the recycling of your packaging and report your packaging volumes. To learn more about packaging types and associated obligations, check out our knowledge base dedicated to packaging types.
Who can be an authorised representative?
Natural or legal persons with a registered office in Germany who
have entered into a written agreement in German with a producer under obligation about the appointment and
have an authorised representative login for the LUCID Packaging Register.
Heads-up: Only individuals who are not affiliated with the company can offer their services as authorised representatives. Where in-house employees take care of fulfilling obligations under packaging law, these individuals are not registered as authorised representatives but as contact persons in your producer registration.
Which obligations under packaging law can be fulfilled by an authorised representative?
Apart from registering with the LUCID Packaging Register, the authorised representative assumes responsibility for all your obligations under the Verpackungsgesetz (Packaging Act) and fulfils them in their own name. Once you are registered and have appointed an authorised representative, you will no longer be able to access the LUCID Packaging Register (including reporting packaging volumes). The authorised representative is responsible for fulfilling the obligations under packaging law on your behalf during the entire term of the contractual appointment. That includes:
Concluding a system participation agreement with one or more system operator(s)
Submitting reports about packaging volumes to the LUCID Packaging Register (data reporting)
Submitting declarations of completeness to the LUCID Packaging Register
Fulfilling return obligations for transport packaging and large commercial or industrial retail and grouped packaging
Participating in a nationwide deposit scheme for single-use beverage packaging subject to deposit
How does appointing an authorised representative work?
You must conclude a written agreement in German with the individual you wish to authorise as a representative. Please refer to the PDF 'Contractual agreements' for more details.
As soon as you have entered into this agreement, you have to name your authorised representative in the LUCID Packaging Register;
if you are already registered with the LUCID Packaging Register, log in using your credentials and enter the details in the 'Authorised representative' tile.
If you are still in the process of registering your company, you can enter your authorised representative as you complete your registration.
For further helpful information on how to proceed in these two cases, and to find out what else you need to consider, take a look at the Checklist on authorising a representative.
Heads-up: Your authorised representative has to confirm their appointment in the LUCID Packaging Register. If all the requirements have been met, the ZSVR will confirm that the authorised representative has been added and will publish the related information in your company's entry in the public register of producers.
Further information
Not registered with the LUCID Packaging Register? Check out this video to find out how to enter your authorised representative directly during the registration process.
Short explanatory film: Authorising a representative (first-time registration)
Not registered with the LUCID Packaging Register? Check out this video to find out how to enter your authorised representative directly during the registration process.
Already registered with the LUCID Packaging Register? Check out this video to find out how to update your registration in the LUCID Packaging Register with your authorised representative.
Short explanatory film: Authorising a representative (existing registration)
Already registered with the LUCID Packaging Register? Check out this video to find out how to update your registration in the LUCID Packaging Register with your authorised representative.
Why is it important that all market participants comply with the obligations under German packaging law?
A level playing field is key if we want to protect our environment. Companies must ensure that their packaging harms the environment as little as possible. This is referred to as assuming 'producer responsibility', which is governed by the Verpackungsgesetz. Where packaging cannot be prevented, all market players that distribute packaged goods must be registered with the LUCID Packaging Register. Another factor is that high-quality recycling of packaging waste is only possible in a financially sound market. That is why you are required to pay for the recycling of your retail, grouped or shipment packaging by concluding a 'system participation agreement' with a system operator.