Selling to Germany from another EU country: why your own licensing doesn't count

If you're in France, Italy, Spain, Poland or the Netherlands, you probably already licence your packaging at home. It's a reasonable assumption that this covers you across the single market. It doesn't — and that surprises more sellers than any other part of these rules.

Why the single market doesn't help here

Free movement of goods means you can sell your ceramics from Lyon to Leipzig without customs. It doesn't mean waste law follows you. Extended producer responsibility — the principle that whoever puts packaging on a market pays for its recycling — is implemented nationally. Each country runs its own register, its own schemes, its own reporting.

So the cardboard box that ends up in a bin in Leipzig is recycled by German infrastructure, financed by German schemes. Your French contribution paid for French collection. What you actually have to do in Germany is set out here. There's no mechanism that moves money between them, which is why there's no mechanism that lets one licence cover both.

What changed on 12 August 2026

The obligation to register and licence has applied to distance sellers for years. What the EU packaging regulation added is the representative: if you sell directly to German consumers and have no establishment here, someone in Germany has to carry those obligations in their own name.

The reasoning is practical. A German authority can write to a seller in Lisbon, but making anything happen is another matter. So the law wants a named person in the destination country who can be reached and held responsible.

What you actually do

1. Keep your home licensing as it is Nothing about your national obligations changes. You'll now report two sets of quantities: what stays in your own market, and what goes to Germany.
2. Appoint a representative in Germany Written contract in German, signed by both sides with a qualified electronic signature. Only one representative is allowed per company.
3. Register yourself in the German register Free, about ten minutes, and personal to you — nobody may do it on your behalf. Step-by-step guide here. You enter your representative's ID while you're there.
4. Let them licence the German share Your representative signs the contract with a German recycling scheme and reports the quantities — to the scheme and to the register, matching.

Splitting the quantities

This is the part people worry about and it's simpler than it sounds. You report to Germany only the packaging that goes to German recipients. If a thousand parcels leave your workshop and eighty go to Germany, those eighty are the German figure. The other nine hundred and twenty stay with your national scheme, exactly as before.

Most shop platforms will give you a shipment count by destination country in a couple of clicks. That number, times the weight of a typical parcel, is your German quantity.

Do I need a representative in every country?

Wherever you sell across a border directly to consumers without an establishment there, that country can require one. The obligations are national, so each market is judged separately — and the thresholds and details differ.

For many small shops the honest conclusion is that some markets don't earn their paperwork. Two parcels a year to Portugal is not worth an annual fee and a registration. Germany, France and Italy are usually the ones where the volume justifies the cost, and that's a calculation worth doing per country rather than assuming either way.

What it costs for the German share

Three things, and only two of them cost money. The register entry is free. The recycling charge follows the weight and material of the packaging that goes to Germany — for a small shop, often a few tens of euros a year, with a minimum annual charge of around €29 that applies however little you send. The representative charges an annual fee; mine starts at €55.

Put your German parcel count in here and you'll have your own figure in about fifteen seconds. No account, no email address.

General information, not legal advice, current as of August 2026. This describes the German position; for obligations in your own country, ask the authority there.