Services for manufacturers and distributors – Letter of Representation in accordance with § 10 of the German Packaging Ordinance


“We ensure complete licensing of your sales packaging!”


Letters of Representation according to § 10 of the German Packaging Ordinance have to be submitted to the local Chamber of Commerce (IHK) by all producers and distributers of packaging that place a certain amount of sales packaging on the market. The Letter of Representation has to give information about the packaging places on the market as well as proof of participation in an EPR system or an individual take-back system. Additionally, a differentiation to commercial quantities and transport packaging has to be provided. Only if these preconditions are met, will the manufacturer or distributor be allowed to surrender sales packaging to private consumers.


The Letter of Representation has to be added to the database of the German Chamber of Commerce (DIHK) and must be examined and given a qualified electronic signature by an authorised expert. Failure to submit the Letter of Representation is a regulatory offence.


As publicly appointed and sworn experts, we are authorised to examine and to confirm the Letter of Representation to the DIHK, as stipulated in § 10 par. 1 of the German Packaging Ordinance.


What we can do for you:


When submitting a Letter of Representation, many questions arise based on the product range offered by the responsible party, such as:


  • Contract structure evaluation
  • Clarification of definitions (e.g. packaging, packaging components, reusable packaging)
  • Attribution of packaging to the end-user
  • Differentiation of packaging according to distribution channels/source
  • Handling of returns or market losses
  • Handling additional purchases
  • Weight determination
  • Classification of packaging materials to the Packaging Ordinance material groups


We work thoroughly on realising the Letter of Representation at all levels, assist you with data gathering and confirm your Letter of Representation with the legally required electronic signature. Afterwards you will receive an audit report.

As an additional service, we offer to weigh your packaging for licensing. Further information can be found under “Weighing Laboratory”.



Please contact:


Silvia Tholen

Head of Business Unit "Weighing Laboratory, Letters of Representation"

Phone +49 541 77080-21


Last changed  01.10.2015

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Amtsgericht Osnabrück  |  Handelsregister Abt. B Nr. 17275  |  USt-IdNr.: DE 155 655 385