German Authorised Representative for Hong Kong sellers
Since 12 August 2026, a qualifying company established outside Germany without a German branch that sells empty packaging or packaged products directly to end users in Germany must appoint an authorised representative. Producer registration in LUCID remains the producer’s own duty.
What the representative can take over
The authorised representative assumes transferable German extended-producer-responsibility obligations. LUCID producer registration itself remains a personal duty of the producer.
Already registered? Do not start again
A Hong Kong company already registered in LUCID should normally update the existing record and specify the authorised representative instead of creating a duplicate registration.
Digital 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 product identity, supported marketplace/shop workflows and Production Connector integration for production or enterprise systems.
Frequently asked questions
When must the representative be appointed?
Where the rule applies, the representative must be appointed and entered in LUCID before the relevant packaged products are first made available directly to German end users.
Can a normal German logistics contact be the statutory representative?
Not automatically. The statutory role has specific eligibility and LUCID requirements.
Does the representative replace LUCID registration?
No. Producer registration in LUCID remains the producer’s own duty.
Related Hong Kong Germany EPR guides
Keep the Hong Kong business and sales channels. Add the German compliance layer.
Existing LUCID, marketplace accounts, stores and the manufacturing supply chain can remain in place. EPRORA organises the representative, LUCID status, packaging data and evidence around them, with optional DPP, serial, QR and production workflows.
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