Cross-border sales to Germany

German packaging EPR for sellers from Poland

A practical guide for businesses established in Poland that sell packaged products directly to end users in Germany.

Current position

If your business is established in Poland, has no establishment in Germany and supplies packaged products directly to end users in Germany, the current German rules generally require a German EPR authorised representative. The manufacturer still completes its own LUCID registration; the appointed representative handles the delegable EPR obligations after appointment.

Check requirements LUCID

Country-specific context

Polish e-commerce sellers shipping directly to German customers need a Germany-specific assessment even when they already meet Polish packaging obligations.

Who needs to act?

01Assess who first places the relevant packaging on the German market. The seller, manufacturer and importer can have different roles. A small business, a low order volume or a marketplace account does not by itself settle which obligations apply.

02Official registration in the LUCID packaging register is free. The obligated business performs its own registration. Prepare the legal entity, address, brands and packaging types; use an existing valid registration instead of creating a duplicate.

03A German authorised representative is a separate issue from obtaining a LUCID number. Businesses established abroad without a German establishment must assess the applicable appointment requirements. EPRORA supports the mandate and documentation workflow; duties retained by the producer do not disappear.

When the rule matters

The key questions are whether the seller is established in Poland, whether it has an establishment in Germany, and whether it supplies packaged products directly to German end users. The sales channel — own web shop or marketplace — does not by itself remove the obligation.

What the seller still does

The manufacturer completes its own initial LUCID registration and identifies the authorised representative. The appointment becomes effective only after the representative confirms it in LUCID.

What can be automated

Company data collection, contract preparation, payment, packaging calculations, marketplace imports, reminders, reporting and compliance documents can be handled digitally. The platform keeps the customer in one guided workflow while the personal LUCID step remains with the manufacturer.

Marketplace sales

Amazon, Shopify, eBay and other channels can feed Germany-bound order data into the packaging engine. Only the data needed for EPR calculation should be retained, with marketplace and merchant fulfillment treated separately.

Regulatory status — September 2026

The Commission proposed in December 2025 to suspend the PPWR intra-EU authorised-representative rule until 2035. That proposal remains in the legislative process; the Council discontinued negotiations on the EPR suspension proposals in June 2026. Germany’s current ZSVR guidance states that businesses established abroad without a German establishment must appoint an authorised representative from 12 August 2026 when the German conditions apply.

Common questions

Does selling through a marketplace remove the German EPR requirement?

No. The sales channel alone does not determine producer status. The actual supply chain, establishment and fulfillment model must be assessed.

Who completes the first LUCID registration?

The manufacturer completes its own initial LUCID registration. The representative can prepare and guide the process and confirms the appointment in its own LUCID account.

Practical next steps

Check Germany as the destination market even when the business or shop is based elsewhere. Establish the seller, importer, recipient and fulfilment model before classifying the packaging. Domestic registration in another country does not automatically replace German requirements.
Official registration in the LUCID packaging register is free. The obligated business performs its own registration. Prepare the legal entity, address, brands and packaging types; use an existing valid registration instead of creating a duplicate.
Record product identifiers, packaging components, material, weight, destination and reporting period. Separate product packaging from shipping packaging. Reconcile quantities across channels and retain supporting records rather than estimating missing weights or double-counting orders.

Check requirements

Small sellers and independent shops

Start with the products and packaging actually shipped. An Etsy shop, eBay business or small independent store can prepare the same core records without an enterprise IT project. Use the self-check to identify the relevant next step, not to assume that every service is required.

Manufacturers and exporters

Manufacturers can connect product specifications, supplier evidence, batches, serial numbers and QR identifiers to a Digital Product Passport workflow. DPP scope and mandatory dates depend on the product category; voluntary preparation is not a claim that every product already needs a passport.

Explore the platform

Packaging representation for your EU sales markets

Use the self-check to record the EU countries you sell to. Then explicitly choose each supported country for which you wish to appoint EPRORA. Selecting a sales destination does not itself grant a mandate.

A separate mandate and annual subscription for each country

Each newly appointed country has its own applicable annual subscription and one-time mandate setup fee. Regular annual renewal does not repeat the setup fee. The self-check shows the country-by-country charges, first-year total and subsequent annual fees. Applicable VAT and third-party costs are itemised separately.

A country rules and monitoring package does not replace representation or the annual subscription for another country. Additional services are shown separately from the mandate.

Country-specific mandate documents

Each appointed country has its own mandate documents. Review the details, complete any blank fields and sign the relevant documents. Generating a document or making a payment alone does not activate the mandate.

A German LUCID registration or a German mandate does not replace a separate appointment for other sales markets. Existing registrations and packaging scheme agreements are taken into account when processing your appointment.

Countries available for separate appointments

Germany

France

Netherlands

Belgium

Luxembourg

Austria

Lithuania

Estonia

Latvia

Poland

Italy

Greece

Hungary

Czechia

Slovakia

Spain

Portugal

Ireland

Check your sales countries and fees