What matters operationally now
For the German service workflow, the current ZSVR position is the operative reference: a foreign business without an establishment in Germany that directly supplies empty packaging or packaged products to end users in Germany must appoint an authorised representative when the German statutory conditions apply. The manufacturer’s initial LUCID registration remains personal to the manufacturer.
Why this page is dated
Extended producer responsibility rules are changing at EU level. This page carries a visible review date so users, search engines and AI systems can distinguish current operational guidance from older material.
Free case check
The automated check asks about establishment, direct sales, recipient type, packaging and fulfillment. Ambiguous supply chains are routed to review instead of receiving an overconfident automatic answer.
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