21 September 2026
Since 12 August 2026, a foreign company without a German branch that sells packaged products directly to end users in Germany has had to appoint an authorised representative for its extended producer responsibility obligations. The German Central Agency Packaging Register, ZSVR, sets fairly specific conditions: the representative must be established in Germany, must enter into a written agreement in German, must have the appropriate LUCID account and cannot be affiliated with the producer.
Then comes the unusual part.
ZSVR tells foreign companies that they are responsible for checking who provides the service, while explicitly stating that it does not publish a list of registered authorised representatives.
Registration with the LUCID Packaging Register remains the manufacturer’s personal responsibility and cannot be transferred to the authorised representative. At the same time, a foreign producer registering for the first time must enter the representative’s details in LUCID, and the appointment itself only becomes effective once the representative confirms it in the system.
Regulation has therefore created compulsory demand for an independent German provider while leaving the search and selection of that provider to the company itself.
The obligation exists. The directory does not.
The German rule captures a broader feature of European expansion that is easy to overlook when attention is focused on the regulation itself. A new requirement can create a buyer almost overnight, but it does not tell that buyer which local company can solve the problem.
The need may be specific even when the market is not
A large multinational will usually deal with a requirement like this through an existing legal, tax or compliance network. A smaller Chinese manufacturer or cross-border seller may already know that Germany is a market it wants to enter and may have no need for a consultant to design an entire market-entry strategy. At that moment, it needs something much more specific: an authorised representative that meets the regulatory requirements, understands the process and is willing to assume the relevant obligations.
The same pattern appears repeatedly in European expansion. Storing inventory in another country can trigger VAT obligations; a distributor may demand additional product documentation; a first local employee creates payroll and employment requirements; a new fulfilment model may change the customs setup. Each of these events creates a concrete purchase of local expertise.
The China Chamber of Commerce to the EU and Roland Berger surveyed 205 Chinese companies and organisations operating in Europe for their 2025/2026 report. Eighty-one per cent reported increasing uncertainty in the European business environment, while dense regulatory developments were described as creating a growing “compliance maze”. The sample covers companies of different sizes rather than Chinese SMEs alone, but it establishes one thing: compliance is already an operating issue for Chinese businesses in Europe, not simply a concern for companies considering entry.
Large groups can absorb more of that work internally. Smaller companies are more likely to have to buy it.
The buyer may start with the problem, not the service name
European professional-services firms naturally organise their websites around the services they sell: German Packaging EPR Authorised Representative, VAT Registration, European Fulfilment, Company Formation.
The buyer may arrive from the opposite direction. A registration has stopped, a marketplace has sent a compliance notice, inventory is about to move into another country, or the company wants to establish its first European entity and does not yet know which formal steps are required.
Chinese cross-border content shows that sequence.
| European provider describes the service as | Chinese-language content frames the problem as |
|---|---|
| German EPR authorised representative | 已经有LUCID账号，还需要授权代表吗？ — I already have a LUCID account. Do I still need an authorised representative? |
| VAT registration | 我需要注册哪些国家VAT？ – Which countries do I need to register for VAT in? |
| European fulfilment / overseas warehouse | 不同国家的海外仓怎么选？欧洲要做多仓布局吗？ — How should I choose warehouses in different European countries? Do I need a multi-warehouse setup in Europe? |
These are examples of how Chinese cross-border sellers frame European operating problems, not claims about the most popular Baidu keywords. On 雨果网 (Cifnews), current German EPR content asks whether a seller that already has a LUCID account still needs an authorised representative. Its VAT guidance asks directly which European countries a seller needs to register in, while its European logistics content starts from the practical choice between warehouses in different countries and a multi-warehouse setup.
The difference is therefore not simply translation. The European provider starts with a service it already understands; the Chinese buyer may start with a notice, a blocked process or a new commercial requirement.
A marketplace, customer or regulation creates the problem. The company researches it in Chinese, works out what the rule means, identifies the type of specialist it needs and only then begins comparing individual providers.
A European firm’s website can therefore be perfectly clear to someone already looking for “German EPR authorised representative services” and still miss the company that has not yet learned that this is the name of what it needs.
Google visibility is not visibility from China
StatCounter’s panel puts Baidu at 73.49% of mobile search in China in August 2026, against 1.03% for Google. Panel data is not a census, but no plausible sampling difference closes a gap of that size.
Search engines are only part of the research process. Chinese companies also use WeChat, industry media, domestic AI products, business communities, advisers and personal recommendations. Mainland China is not currently listed among the countries and territories officially supported for ChatGPT; Anthropic does not list mainland China among the regions where Claude.ai is officially offered; and Google’s Gemini documentation lists mainland China as “Workspace only”.
Chinese companies are not short of ways to research foreign markets. They are simply using a different mix of sources and tools from the one a European service provider sees when it checks Google, LinkedIn or ChatGPT.
Before a buyer knows your name, those channels help decide whether your company appears at all. After the buyer knows your name, they mostly help confirm what someone has already told them.
Search does not replace relationships
Professional services are trust-based purchases. A Chinese company is not going to appoint a lawyer, tax adviser or compliance provider merely because that firm appeared first in a search result, particularly when the mandate is large or risky. Recommendations, existing relationships, trade fairs, advisers and introductions remain central to how business gets done.
But a recommendation still has to be checked, and a company without an established European network may have nobody obvious to ask in the first place. The buyer needs to understand what a provider does, which countries it covers, whether it works with foreign clients and whether its expertise fits the problem.
There is broader evidence that digital channels reduce this kind of friction for smaller companies. A 2025 Long Range Planning study based on 714 listed Chinese SMEs found that commercial and social digital platforms positively influenced internationalisation. A separate European Economic Review study of Chinese manufacturers found that greater internet use reduced information frictions and the cost of searching for foreign suppliers.
Finding foreign counterparties costs time and money, and smaller companies have fewer internal resources to spend on it.
Try the test on your own firm
A European B2B provider can test this without buying anything from EnterChina.
Start by checking whether there is any meaningful Chinese-language page explaining what the company actually does – not an automatically translated homepage, but something from which a potential buyer could understand the firm’s services, markets and expertise.
Then search for the problem rather than for the company name. A German EPR provider should look at what a Chinese-speaking user encounters when asking whether an authorised representative is required or what to do after a packaging compliance change, rather than checking whether its own brand appears in search.
The most revealing test is to ask a Chinese-speaking person who does not already know the company to find several providers in the category. Which firms appear? What information is available about them? Is it obvious which countries and services they cover? Does your company appear at all?
If the person already knows your name, the test has started too late.
The European market can look much smaller from China
Europe has thousands of specialist B2B firms capable of supporting international companies. A German compliance provider may know packaging regulation in extraordinary detail, a Polish customs firm may already process Asian imports every day, a Spanish tax adviser may regularly register foreign businesses for VAT, and a French employment practice may know exactly what is required to hire a company’s first local employee.
Many of these firms already work internationally and have strong reputations in their own markets. Few have an economic reason to open a sales office in China or build a dedicated China team.
For a Chinese buyer, however, those thousands of companies are not the market. The market is the smaller group it can actually find, understand and verify when the need appears.
A capable provider that never enters that group loses the opportunity before a sales conversation has even started.
Where EnterChina fits
EnterChina’s Chinese platform, Xijinmenhu (西进门户), makes European B2B service providers easier for Chinese companies to find and understand. Each provider is presented in Chinese with its services, geographic coverage and the business problems it can solve.
When a Chinese company submits a specific requirement, we connect it only with providers in the existing directory that match that need. Providers are reviewed before publication, and the platform does not rank companies or recommend prices.
For European firms, the value is straightforward: visibility in the Chinese-language research process at the moment a company is looking for the expertise they already provide.
Sources
- Zentrale Stelle Verpackungsregister (ZSVR) — Authorised representative (PPWR), verpackungsregister.org/en/ppwr/authorised-representative; What changed on 12 August 2026, verpackungsregister.org/en/i-want-to-know-what-changed-on-12-august-2026.
- China Chamber of Commerce to the EU / Roland Berger — Report on the Development of Chinese Enterprises in the EU 2025/2026, en.ccceu.eu. Cited for: the 205-company sample, the 81% figure on rising uncertainty, and the “compliance maze” description.
- StatCounter Global Stats – Mobile Search Engine Market Share in China, August 2026, gs.statcounter.com/search-engine-market-share/mobile/china. Cited for: Baidu 73.49% and Google 1.03% of mobile search in China
- European Economic Review – Internetization, supplier search, and diversification of global supply chains, vol. 172 (2025). Cited for: the effect of internet use on information frictions and supplier-search costs.
- Long Range Planning – Digital platforms, internal digitalization, and internationalization of SMEs (2025). Cited for: the effect of commercial and social digital platforms on SME internationalisation.
- 雨果网 / Cifnews — 德国包装法需绑定授权代表，卖家常见9个问题解答！, cifnews.com/article/188217.
- 雨果网 / Cifnews — 进军欧洲市场必看！一文带你读懂欧洲VAT要点！, cifnews.com/article/165299.
- 雨果网 / Cifnews — 了解欧洲物流！仓储布局、成本计算一文看懂, cifnews.com/article/177796.