Selling to Germany or France: what packaging EPR registration do you need, and do foreign sellers need an authorised representative?
Germany: if you sell packaged goods directly to end users in Germany, you register in the LUCID Packaging Register; the register states that a foreign company with no branch in Germany must appoint an authorised representative to take on the extended producer responsibility. German packaging law has changed: the EU Packaging and Packaging Waste Regulation (PPWR) entered into force on 11 February 2025 and generally applies from 12 August 2026, when Germany's Packaging Law Implementation Act (VerpackDG) replaced the Packaging Act (VerpackG). Registrations under the old law count under the new one; any registration details that need updating must be updated by 12 November 2026. France: each producer subject to EPR needs one unique identifier (IDU) per EPR category, issued by ADEME; an importer bringing foreign-made products onto the French market counts as a producer. First establish whether you are the producer for that stream: if so, get the IDU; if not, obtain the relevant IDU from the producer or supplier and give it to the marketplace to check. A marketplace without proof of compliance may have to meet the obligation itself and pay the eco-contribution, but that does not waive the seller's obligations or promise a listing or free compliance services.
- Applies to
- Chinese sellers selling packaged goods to consumers in Germany or France (own website or marketplace).
Germany: LUCID packaging registration
| Point | What the official source says | Source |
|---|---|---|
| New law replaces old | Environment ministry: VerpackDG replaces the Packaging Act; the PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026 (European Commission packaging page) | Ministry press release, VerpackDG text |
| Transition for registered firms | Registration under §9 of the old law counts as registration under §6 (§6 requires prompt updates when registration data change); changes under §6(1) sentence 2 must be made by 12 November 2026; producers newly required to register must do so by 12 September 2026; old system participation runs at most to 31 December 2026 | VerpackDG §68 |
| Foreign sellers need a representative | Register: a company based abroad selling packaged goods directly to end users in Germany, with no branch in Germany, must appoint an authorised representative | LUCID registration page (undated) |
| Who runs the register | The Central Agency Packaging Register (ZSVR) runs LUCID | ZSVR public registers |
Under the old law (from 1 July 2022), all packaging had to be registered on pain of a distribution ban, and marketplaces had to check that sellers were registered and in a take-back system before listing their goods (ZSVR 2022 notice). We have not yet checked the new law's wording on marketplace checks and sales bans; see Unknowns.
France: EPR unique identifier (IDU)
| Point | What the official source says | Source |
|---|---|---|
| One IDU per category | Since 1 January 2022, each producer in an EPR scheme needs one ADEME-issued unique identifier per scheme concerned | ADEME IDU page |
| Importers are producers | An importer placing foreign-made products on the French market is the producer; marketplaces are responsible for EPR on third-party sales only if the seller has not met its own obligations | ADEME producers page |
| When the marketplace steps in | If the seller has met its EPR obligations and the marketplace has recorded the evidence, the marketplace is not bound; if not, it must meet the obligation instead and pay the eco-contribution | Ministry marketplace FAQ (L.541-10-9) |
| How sellers prove it | The seller provides the ADEME IDUs for the product categories it sells, including packaging | Same |
| Disclosure | A producer meeting EPR obligations states its IDU in its general terms of sale | ADEME FAQ |
What you can do yourself
- List the goods and packaging you sell into Germany and France (outer boxes, bags and fillers all count).
- Germany: register in LUCID; with no branch there, appoint an authorised representative first. If already registered, check whether any details need updating and update them by 12 November 2026 under the §68 transition.
- France: first establish whether you are the EPR producer for each category. If so, get the IDU under that scheme and add it to your terms of sale; if not, obtain the relevant IDU from the producer or supplier. Give the IDU to any marketplace you sell on.
- Report the quantities you actually place on the market at the intervals set by the country, category and take-back organisation, and keep records.
When to use a licensed professional
- If you are unsure which EPR categories apply, or whether you need a representative, ask an environmental compliance adviser or lawyer in Germany or France.
- Before signing with an authorised representative, have a lawyer check who is liable for what and the fees.
Check before you pay, and warning signs
- If someone offers "EPR registration", ask which country, which category, and whether it covers registration or a take-back system contract, and which filings the annual fee covers.
- "You can sell on a marketplace without registering" or "one number covers the whole EU" are warning signs; each country runs its own scheme.
Unknowns
- The new VerpackDG §6 wording on foreign sellers, authorised representatives and marketplace checks: not yet checked against the text.
- Penalties and sales bans under the new German law: not checked.
- French eco-contribution amounts: set by each category's take-back organisation; not listed here.
- Packaging EPR in other EU countries: this page covers Germany and France only.
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