Appointing a representative in Germany: what's actually required

Published 14 August 2026 · by Jennifer Rogalski-Koschel, authorised representative · 5 minute read

Sellers are being quoted for notarisation, apostilles and certified translations before they've even seen a contract. For the German appointment, none of that is part of the requirement. Here is what the law actually asks for, in full, and what to ask before you agree to anything.

The short version

  • A written mandate in the German language, signed by both sides.
  • Signed either by hand or with a qualified electronic signature. A scan or a tick-box isn't enough.
  • No notary. No apostille. No certified translation.
  • Only one representative per producer, effective once the authority confirms it.

The formal requirement, in full

It is genuinely short. The appointment must be made in writing, in German, and signed by both the producer and the representative. Signing is by hand on paper, or with a qualified electronic signature — the kind issued by a licensed trust service provider after checking who you are, not a picture of a signature dropped into a PDF.

The German text is the binding one. An English version alongside is common and useful, but it's a reading copy, not the contract.

That's the whole formal requirement. Everything else — the recycling contract, the reporting, the deadlines — happens after, and is the representative's work rather than a formality you have to satisfy. If you are still working out whether the rule applies to you, start with the overview.

What is required

  • Written contract in German
  • Signed by both parties
  • By hand, or with a qualified electronic signature
  • Your own registration in the packaging register, done personally
  • The representative's ID entered in your register entry

What is not

  • A notary
  • An apostille
  • A certified or sworn translation
  • Travelling to Germany
  • A German bank account or address
  • A power of attorney drawn up separately

Where the confusion comes from. Other countries and other kinds of appointment do sometimes need notarisation, and a provider covering several markets may list it as a possible extra "depending on the country". That's fair enough as a general caveat — but it isn't a German requirement, and it's worth asking specifically rather than assuming it applies to you.

Why an apostille can't be the answer here

An apostille is a certificate that makes a public document usable in another country — a birth certificate, a court judgment, a notarised deed. The appointment isn't a public document. It's a private contract between you and the person you're appointing. There's nothing for an apostille to certify.

The timing question, which is a real one

If you sign in August, are you paying a full year for four and a half months? Two different things are going on, and they don't work the same way.

The recycling licensing runs by calendar year. Licensing in August covers the rest of that year, and you licence again in January. That isn't a provider being sharp — it's how the register year works, and it would happen with any of them.

The representative's own fee is contractual. So it depends entirely on their terms, and it's a fair question to ask outright: does your fee cover a calendar year, or twelve months from signature? In August the difference is most of what you're paying.

Five things worth asking before you agree

  1. Does your fee run by calendar year or from signature? In the second half of the year this changes the real price substantially.
  2. Are the recycling charges passed on at cost, or with a margin? Both are legitimate. You just want to know which.
  3. What exactly are the possible extras, for Germany specifically? Not "depending on the country" — for Germany.
  4. What happens when I want to leave? Ending an appointment requires a final quantity declaration so the period can be closed off. Ask how that's handled.
  5. Who signs on your side, and how? If they can't answer how the qualified signature works, that's worth noticing.

Two things you still have to do yourself

Register in the packaging register. It's free, takes about ten minutes, and German law reserves it for the producer personally. Nobody may do it for you — not a representative, not an agency, not a lawyer. Step by step here.

Enter the representative's ID in your own entry. Two minutes, and it's what tells the authority who acts for you. Later changes to your entry are personal too.

One representative, and only one. You can't appoint a second alongside the first, and the appointment only takes effect once the authority has confirmed it. If you're switching, the existing one has to be ended first.

What to do if a quote doesn't match this

Ask which provision it's based on. That's not a hostile question and any competent provider will have an answer — the rules are public and short. If the answer is vague, or if the only place the extras appear is a line of small print above a button that says "place binding order", slow down.

None of this makes the obligation itself go away, and I'm not suggesting the market is full of bad actors. But this is a new requirement, a lot of people are buying under time pressure, and the formal part is much simpler than it's often made to look.

Work out what it would cost you

Your parcel count and roughly what a parcel weighs. Fifteen seconds, no account, no email address — and if your volume doesn't justify the German market, I'll say so.

Open the calculator

General information, not legal advice, current as of August 2026. This describes the German appointment only. Other member states run their own systems with their own formalities, and some of them do involve steps that Germany doesn't.

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