# Selling in Germany from France: five obligations and two deadlines before end 2026 > Legal notice, a "zahlungspflichtig bestellen" order button, a withdrawal button, packaging registration and, since 12 August 2026, a packaging authorised representative appointed in German: what Germany requires of a shop based in France, and the deadlines of 12 November and 31 December. - Original page: https://dotsland.com/en/selling-in-germany-from-france/ - Language: en - Published: 2026-10-13T23:02:43+02:00 - Updated: 2026-10-14T11:07:26+02:00 - Section: Digital Marketing - Publisher: Dotsland, https://dotsland.com/en/ --- ## In brief - Selling online to German consumers from France involves five obligations that are specific to German law or were tightened in 2026: the legal notice, the order button, the withdrawal button, packaging registration and the packaging authorised representative. - Since 12 August 2026, the German Packaging Act has been replaced by a new law implementing the EU regulation. A seller with no establishment in Germany must appoint an authorised representative, in writing and in German, before their first delivery. - Two deadlines fall before the end of the year: existing registrations must be updated by 12 November 2026, and contracts with a compliance scheme concluded under the old law expire on 31 December 2026 at the latest. - Failing to register can lead to a fine of up to €100,000; failing to join a compliance scheme, up to €200,000. To sell in Germany from France, an online shop must, on top of common EU law, follow five German rules: a complete legal notice, an order button labelled with a precise wording, a withdrawal button, registration in the packaging register and, since 12 August 2026, a packaging authorised representative established in Germany. Two of them have a deadline before the end of 2026. > **How we checked** > On 13 October 2026 we read the German texts in force on the official site of the Federal Ministry of Justice: the Digital Services Act (DDG), the Civil Code and the new Packaging Implementation Act, as well as the EU packaging regulation and the directive on online withdrawal. The sources are listed at the end of the article. ## What legal notice must you display to sell in Germany? Germans call it the *Impressum*. It now falls under Section 5 of the Digital Services Act (Digitale-Dienste-Gesetz), which requires information that is “easily recognisable, directly accessible and permanently available”: name and address of establishment, legal form and legal representative for a company, a means of fast electronic contact including the email address, the register and registration number, and the intra-EU VAT number when you have one. In substance it is not very different from a French legal notice, but the page must exist in German and stay one click away from every page. ## How should the order button be labelled? This is the most precise rule in German online sales law. Section 312j of the Civil Code requires the consumer to confirm expressly that they are committing to pay. If the order goes through a button, it may only carry the words **“zahlungspflichtig bestellen”**, order with obligation to pay, or an equivalent unambiguous wording. And the sanction is drastic: **the contract is not concluded** if the rule is not met. A button translated word for word from another language, such as “Confirm my order”, or a plain “Weiter” (next), does not meet the requirement. It is a ten-minute fix in the German version of the checkout, and one of the most often forgotten. ## Is the withdrawal button mandatory in Germany? Yes. The new Section 356a of the Civil Code transposes an EU directive applicable since 19 June 2026. For any distance contract concluded online, the seller must offer a **withdrawal function** labelled “Vertrag widerrufen” or an equivalent wording, visible and accessible throughout the withdrawal period. It leads to a form collecting the customer’s name, the contract concerned and the address for the acknowledgement, then to a confirmation labelled “Widerruf bestätigen”. The seller then sends without delay, on a durable medium, an acknowledgement stating the content, date and time. The same obligation has applied in France since the same date, with the words “renoncer au contrat ici”. A shop that has set it up in French simply needs to translate it, and check that the German version carries the right labels. Our article on [the withdrawal button](https://dotsland.com/en/withdrawal-button-cancel-contract-here/) sets out the French journey and a ten-minute test. ## What changed for packaging on 12 August 2026? The old German Packaging Act has been replaced by a law implementing EU Regulation 2025/40, applicable since 12 August 2026. The central register, known as LUCID, remains. Three obligations apply to a French seller delivering directly to German consumers, since the regulation treats them as the “producer” in the country of delivery. 1. **Register with the central register before the first delivery.** This registration cannot be delegated to a third party: the seller does it themselves, stating in particular their brands and the packaging concerned. 2. **Appoint an authorised representative.** This is the new part. The EU regulation requires a producer delivering to end users in another Member State to appoint, by written mandate, an authorised representative for extended producer responsibility in that country. The German law specifies that the mandate is written **in German**, that there is only one representative per producer, and that it must be appointed before the first making available, then declared to the register. 3. **Join a compliance scheme** for packaging that ends up with consumers, before making it available, declaring its material and weight. The EU regulation adds an obligation for marketplaces: before allowing a producer to sell to consumers, they must obtain its registration number in the consumer’s country. An unregistered seller therefore does not meet the condition the marketplace is required to check. ## Which deadlines fall before the end of 2026? The law sets up a transition, with two dates to note. | Date | What happens | Who is affected | | --- | --- | --- | | **12 November 2026** | Deadline for making in the register the changes the new law requires, including, on our reading, declaring the authorised representative | Every seller already registered under the old law | | **31 December 2026** | Latest end of validity of compliance scheme participations concluded before 12 August | Every seller who wants to keep delivering in 2027 | A registration made under the old law remains valid: you do not have to start again, but you do have to complete it. Sellers who were not registered and became subject to the new law had to register by 12 September 2026. ## What does an oversight cost? The new packaging law provides for a fine of up to **€100,000** for failing to register and up to **€200,000** for failing to join a compliance scheme. For the order button, the sanction is not a fine: the contract is simply not formed. ## The checklist before opening Germany 1. **Legal notice**: a page in German, one click away from every page, with all the information in Section 5. 2. **Order button**: “zahlungspflichtig bestellen”, checked on the live German site, not only in the translation file. 3. **Withdrawal button**: “Vertrag widerrufen”, then “Widerruf bestätigen”, and the automatic acknowledgement with date and time. 4. **Packaging register**: registration in your own name, updated before 12 November if you were already registered. 5. **Authorised representative**: just one, appointed in writing in German, declared to the register. 6. **Compliance scheme**: contract renewed under the new law for 2027, before 31 December. The same reasoning applies to every EU country where you deliver directly to consumers: the EU packaging regulation requires an authorised representative in each. If you also prospect German businesses by email, note that Germany requires their prior consent, even between businesses. ## What this says about the bigger picture The single market is built through EU regulations, but it is administered country by country: a national register, a national representative, labels in the customer’s language. The cost of entering a new country is no longer mainly technical, it is administrative, and it is paid before the first order. That is why opening a country should be prepared as a project, with a timeline and a checklist, rather than as a simple translation of the site. It is what we do through our [e-commerce and marketplaces expertise](https://dotsland.com/en/expertise/ecommerce-and-marketplaces/), and what we describe across all the usual failure points in our article on [opening a second country](https://dotsland.com/en/opening-a-second-country/). > **What this article is not** > Legal advice. It brings together the texts in force on 13 October 2026. For drafting the mandate or choosing a compliance scheme, work with a professional established in Germany. ## Sources All of these pages were opened on 13 October 2026. 1. Digitale-Dienste-Gesetz (DDG), Section 5, gesetze-im-internet.de (in German). [View](https://www.gesetze-im-internet.de/ddg/__5.html) 2. German Civil Code (BGB), Section 312j (in German). [View](https://www.gesetze-im-internet.de/bgb/__312j.html) 3. German Civil Code (BGB), Section 356a (in German). [View](https://www.gesetze-im-internet.de/bgb/__356a.html) 4. Directive (EU) 2023/2673, Article 1 (Article 11a of Directive 2011/83/EU) and Article 2, EUR-Lex. [View](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023L2673) 5. Verpackungsrecht-Durchführungsgesetz (VerpackDG) of 13 July 2026, Sections 5, 6, 7, 66 and 68 (in German). [View](https://www.gesetze-im-internet.de/verpackdg/) 6. Regulation (EU) 2025/40 on packaging, Article 3, point 15, and Article 45, EUR-Lex. [View](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32025R0040) ## FAQ ### What are the obligations for selling online in Germany from France? As of 13 October 2026, five obligations specific to German law or tightened in 2026: a complete legal notice (Section 5 of the Digital Services Act), an order button labelled “zahlungspflichtig bestellen”, a withdrawal button “Vertrag widerrufen”, registration in the central packaging register and, since 12 August 2026, appointing a packaging authorised representative by written mandate in German. ### Does a seller based outside Germany need a packaging authorised representative there? Yes, if they deliver directly to end users in Germany without being established there. EU Regulation 2025/40 treats them as the producer in the country of delivery and requires an authorised representative for extended producer responsibility, appointed in writing. German law requires the mandate to be written in German, to be unique, appointed before the first delivery and declared to the central register. ### Is my LUCID registration from before August 2026 still valid? Yes, it counts as a registration under the new law. But the changes it requires must be made before 12 November 2026, and compliance scheme contracts concluded before 12 August expire on 31 December 2026 at the latest. ### What is the risk if the order button is not compliant? The contract is not concluded. Section 312j of the German Civil Code provides that if the button does not carry “zahlungspflichtig bestellen” or an equivalent unambiguous wording, the contract is not formed. ### Can Dotsland help? Yes. We prepare a country opening as a project: obligations, timeline, translated and checked checkout, marketplaces. Start with the checklist above, then [get in touch](https://dotsland.com/en/contact-us/).