German Authorized Representative for U.S. 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 authorized representative. LUCID producer registration remains a personal duty of the producer.
What the representative takes over
The authorized representative assumes the producer’s transferable extended-producer-responsibility obligations in Germany. The producer’s own LUCID registration remains the key personal duty.
What existing producers do
A U.S. company already registered in LUCID should normally update its existing record and specify the authorized representative instead of creating another producer account.
Frequently asked questions
When should the representative be appointed?
Where the rule applies, the representative should be appointed and entered in LUCID before the relevant packaged products are first made available directly to German end users.
Can our U.S. employee be the statutory German representative?
The German authorized-representative role has specific eligibility requirements, including a German office or branch and the required LUCID representative login. A normal company contact is not automatically the statutory representative.
Does the representative replace LUCID registration?
No. Producer registration in LUCID remains the producer’s own duty.
Related U.S. Germany EPR guides
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-based product identity, supported marketplace/shop workflows and the Production Connector for production or enterprise-system integration.
Keep the revenue engine. Add the German compliance layer.
Existing LUCID registrations, marketplaces and stores can remain in place. EPRORA organizes the German Authorized Representative, LUCID status, packaging data and evidence workflow around them.
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