If you sell into Germany and someone asked you about packaging compliance, you'd probably say the word VerpackG.
That law was repealed on 12 August 2026.
12 August 2026 — the day VerpackG was repealed. UK sellers into Amazon.de with no German establishment needed an authorised representative that morning.
It was replaced by the EU Packaging and Packaging Waste Regulation — PPWR — working alongside a new German implementing act, the Verpackungsdurchführungsgesetz. VerpackDG, if you want to say it out loud, which you don't.
This matters less as trivia and more because the replacement brought a requirement that didn't exist before, and it applies to exactly the sellers least likely to have noticed: UK businesses shipping into Amazon.de without a German entity.
What actually changed
Under the old regime, a UK seller registered with LUCID, joined a dual system, filed their declarations, and that was compliance. You did it yourself, from Manchester or wherever, and it worked.
Article 45(3) of PPWR added a step. If you have no establishment in Germany and you sell packaged goods directly to German end users, you are the producer of that packaging — and you must appoint an Authorised Representative established in Germany to carry your EPR obligations.
Two words in there do a lot of work.
"No establishment." Not "no warehouse." Not "no German sales." An establishment means a registered presence. Using FBA doesn't give you one. Using a German 3PL doesn't give you one. If your company is registered at a UK address and nowhere else, you have no establishment in Germany, and the mandate applies to you.
"You are the producer." This is where most UK sellers' mental model breaks. You didn't manufacture the box. Your supplier in Shenzhen did, or your co-packer in Leicester. It feels like someone else's packaging. Under the regulation, the first party to place that packaging on the German market is the producer, and if you're the one selling to the German consumer, that's you.
The bit that stops your stock moving
Here's the sentence worth reading twice:
A producer that is not registered, or has not joined a dual system, may not supply that packaging in Germany at all — and distributors and fulfilment providers must not handle it.
That is not Amazon being cautious. That's a legal prohibition that lands on your fulfilment provider.
Which reframes what an inbound rejection actually is. If your shipment gets refused, the instinct is to open a case, argue, escalate, assume someone misread something. But a fulfilment provider handling packaging from an unregistered producer is itself non-compliant. They're not being difficult. They're declining to break the law on your behalf.
Amazon has been blocking listings for German EPR non-compliance since 15 June 2022. The enforcement mechanism isn't new. What's new is a second way to fail it — you can be registered, in a dual system, fully paid up, and still be non-compliant because you have no authorised representative on file.
What the appointment actually requires
Three specifics that catch people out.
It has to be written. Not a verbal arrangement with your VAT agent. Not a line in an email.
It has to be in German. Section 5 of VerpackDG requires the authorisation itself in German. A translated copy isn't the instrument.
It has to exist before your first supply. Appointing a representative in November doesn't retrospectively cover the stock you sent in September.
That last point is the one that makes this awkward rather than merely administrative. If you've been shipping into Germany since August without a representative, you can appoint one now — and you should, today — but you can't make the intervening period compliant. The exposure already happened.
What it costs to get this wrong
Section 66(3) of VerpackDG sets the penalty tiers:
→ Up to €200,000 for failing to join a dual system → Up to €100,000 for failing to register, or for a missing or incorrect completeness declaration → Up to €10,000 for most other breaches
Those are ceilings, not invoices. German regulators are not known for maximum-fining a 20-unit-a-week seller into oblivion. But the numbers tell you how the legislator ranks these failures, and "not joining a dual system" sitting at the top is worth noting — that's the one most sellers think of as a recycling fee rather than a legal obligation.
The practical cost is almost never the fine. It's the four weeks your bestseller is unsellable in your second-largest market, in Q4, while you work out which of three registrations is the broken one.
The five-step clean-up
If you sell into Germany from the UK, do this in order. It's about two hours of work and most of it is waiting.
1. Log into LUCID and read what it tells you. The register now automatically flags foreign producers with a missing authorisation when they log in. If there's a prompt sitting there asking for representative details, that's your answer and you can stop diagnosing. Screenshot it with the date — useful later if you need to show you acted promptly.
2. Establish whether you actually have an establishment. Not a warehouse. A registered presence. If you're a UK limited company with no German branch, no GmbH, no registered office there, the answer is no and you need a representative. Don't let a freight forwarder tell you otherwise; they're not the ones liable.
3. Appoint the representative properly. Written authorisation, in German, naming the specific obligations being carried. Your existing German VAT agent may offer this as a service — many do — but check that what they're giving you is an EPR authorisation under VerpackDG and not a tax representation that happens to be in the same document. They're different mandates.
4. Reconcile all three registrations against each other. Your LUCID number, your dual system contract, and your authorised representative record have to describe the same producer. Mismatched company names between LUCID and your dual system is the single most common reason a registration looks complete and isn't. Check the legal name character by character, including the suffix. "Ltd" and "Limited" are not the same string to a validation script.
5. Put the numbers where Amazon reads them. Seller Central → Account Info → Compliance. Your LUCID registration number goes in the German EPR field. If the field is populated but the listing is still restricted, the number is usually failing validation against the ZSVR register rather than missing — which again points back to a name mismatch in step 4.
Two things I'd check even if you think you're fine
Your completeness declaration threshold. If your German volumes crossed the reporting threshold this year, you may owe a declaration you've never filed before. It's one of the €100,000 tier items, and it's easy to miss because nothing prompts you — the obligation attaches to your volume, not to a notification.
Every marketplace, not just Amazon. The obligation is on you as the producer, not on any individual channel. If you sell the same stock through Otto, Kaufland or your own Shopify store into Germany, the registration has to cover all of it. Sellers who fixed this for Amazon in 2022 and then launched a second channel are a recognisable category.
The honest summary
This isn't a new tax or a new fee. It's a change in who is permitted to carry your obligation, and the answer is no longer "you, from the UK."
If you have a German entity, nothing here applies to you. If you don't, you needed a representative on 12 August, and it's now October.
The reason it's worth two hours this week rather than two hours in December is that the failure mode isn't a letter. It's your listings going quiet in the middle of peak, at which point the fix takes as long as it takes and your competitors don't wait.
If your Amazon.de listings are already restricted on EPR grounds, Fin Method's Listing Suppression Recovery (£150 per suppressed listing) covers the diagnosis, the Seller Central fix, and the reinstatement request. For the backend compliance field updates that follow an authorised-representative appointment, Amazon Listing Amendments (£120 per listing) handles the data entry across each affected marketplace. Fixed price. Delivered in days, not weeks.