German Authorised Representative for UK sellers
Since 12 August 2026, a company established abroad without a German branch that sells empty packaging or packaged products directly to end users in Germany without an intermediary retailer must appoint an authorised representative. LUCID producer registration remains a personal duty of the producer.
What the representative can take over
The authorised representative assumes the producer’s transferable extended-producer-responsibility obligations for Germany. The producer’s own LUCID registration is the key exception and must be completed by the producer.
What existing producers do
A UK company that already has a LUCID registration should normally update the existing record and specify its authorised representative rather than create a second producer registration.
Frequently asked questions
Can EPRORA be appointed before the first German sale?
The authorised representative should be appointed and entered in LUCID before the first relevant packaged products are made available directly to German end users where the requirement applies.
Can our UK employee be the German statutory representative?
The German authorised-representative role has specific eligibility requirements, including a German office or branch and the required LUCID representative login. An ordinary employee contact is not automatically the statutory representative.
Does the representative replace LUCID registration?
No. Producer registration in LUCID remains the producer’s own legal duty.
Related UK Germany EPR guides
Product passports, serial numbers, QR codes and production integration
EPRORA can extend the same product and packaging data into Digital Product Passports, serial-number and QR-code-based product identity, supported marketplace/shop workflows and the Production Connector for production or enterprise-system integration.
Keep your shop. Add the German compliance layer.
Existing LUCID registrations, marketplaces and shops can remain in place. EPRORA organises the German Authorised Representative, LUCID status, packaging data and evidence workflow around them.
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