Germany is the first country to publish a hard deadline for the new authorised representative duty. If you're a foreign producer with an existing LUCID registration, mark 12 November 2026.
TL;DR — Germany's LUCID transition period ends 12 November 2026 — non-EU sellers must appoint a German authorised representative before then.
The new duty since 12 August
From 12 August 2026, a company based abroad that sells packaged products directly to German end-users without a German branch must appoint an authorised representative. The AR assumes all EPR obligations under the PPWR and the German VerpackDG — with one important exception.
The one thing the AR cannot do
Registration in the LUCID Packaging Register remains your personal duty (höchstpersönlich). You must register yourself and enter your AR's details in LUCID. After that, the AR handles everything else: system participation, volume reports and declarations of completeness.
The 12 November transition window
For sellers already registered in LUCID, a transition applies: you must update your registration and specify your authorised representative by 12 November 2026. After that date, a LUCID registration without an AR is non-compliant.
The mandate must be in German
The written agreement with your authorised representative must be in German. If other language versions exist, the German version is binding.
The practical takeaway: if you sell to German consumers, appoint your German AR now and update your LUCID registration before 12 November 2026. Missing the date means a non-compliant registration and the enforcement consequences that follow it.
Source: LUCID Packaging Register — Authorised representatives.
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