EPR authorised representative: who must appoint one, in which country, for which goods

The EU texts define the representative by where it is established

The four acts use the same idea. The packaging definition says it is a natural or legal person established in the country where the producer makes the packaging available for the first time, other than the country or third country where the producer is established, appointed to fulfil the producer's duties under the packaging extended-producer-responsibility chapter (Art. 3(20)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 20Click opens the article on EUR-Lex.). The battery definition has the same shape (Art. 3(48)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 48Click opens the article on EUR-Lex.). The frame for all of them is Directive 2008/98/ECDirective 2008/98/EC, Waste Framework DirectiveThe whole regulationClick opens the law on the EU Publications Office.: every country must allow a producer established in another EU country to appoint a person established on its territory to fulfil the producer's duties related to extended producer responsibility there, and may set registration, information and reporting requirements for that person (Art. 8a(5)Directive 2008/98/EC on waste, as amended by Directive (EU) 2018/851Article 8a, paragraph 5Click opens the article on EUR-Lex.).

There is a second kind of representative in the same acts, and it is not this one. The PPWR's "authorised representative" is someone a manufacturer mandates for named tasks about the manufacturer's product duties (Art. 3(19)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 19Click opens the article on EUR-Lex.). The Batteries Regulation has the same split, with its product-side representative tied to Chapters IV and VI (Art. 3(63)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 63Click opens the article on EUR-Lex.). The EPR one registers you and handles the waste side.

A producer responsibility organisation is also not the representative. It organises the financing, or the financing and the operations, of the duties for many producers, and you may entrust it with them (Art. 46(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 46, paragraph 1Click opens the article on EUR-Lex.). For packaging, where you have entrusted one, it meets the registration duty for you unless the country says otherwise (Art. 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex.). For textiles, the Directive lets an organisation appointed by written mandate meet the representative's duties if you wish (Art. 22a(4)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 4Click opens the article on EUR-Lex.). What the organisations are and which are compulsory is on EPR in the EU.

Packaging: Germany, Spain and France require a representative from a seller outside the EU

The Regulation sets a split. A producer established in another EU country must appoint one in each country it sells into. A country may require the same of a producer established in a third country (Art. 45(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 3Click opens the article on EUR-Lex.). The reason the Regulation gives is to avoid the risk of dodging the extended-producer-responsibility duties (recital 123). A country may also let the representative do the registration on a written mandate (Art. 44(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 3Click opens the article on EUR-Lex.). No packaging may be made available for the first time in a country unless the producer, or its representative where Article 45Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45Click opens the article on EUR-Lex. applies, is registered there (Art. 44(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 4Click opens the article on EUR-Lex.).

Germany. The VerpackDG replaced the old Verpackungsgesetz on 12 August 2026, and the ZSVR's page speaks of the VerpackDG and the PPWR. The statute names both cases of Article 45(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 3Click opens the article on EUR-Lex.: the producer established in another EU country and the producer from a third country, each without a German establishment, must name a representative before the first making available. The representative acts in its own name and counts as a producer for the duties it takes over (§ 5(2), § 5(3) VerpackDG). Registration is the one duty it does not take: "This is a personal duty that you have to fulfil yourself", and LUCID will not let you finish registering without the representative's details (ZSVR). The representative must have its own login and confirm the appointment in LUCID before it takes effect. If you are already registered, you update your registration and name the representative; the register shows a pop-up from 12 August 2026.

Spain. Article 17.2 covers producers established in another EU country or in a third country alike. If you name none, the first distributor or trader of the packaged product that has its seat in Spain is subsidiarily the party responsible (Art. 17.2 RD 1055/2022). The Ministry says that from 12 August 2026 an online platform is no longer this subsidiary producer (MITECO). The Ministry adds that the representative must register you and report for you, and that a scheme the producer joined cannot do these without a mandate from the producer (MITECO). What Spain adds for packaging, with the representative route, the collective systems, the penalties and the 2026 declaration, is on Spain packaging EPR.

France. The rule and its text are in the France section below.

Other countries. The EU text leaves a seller from outside the EU to each country's choice, and this page covers the three whose texts we read. Hungary also requires a representative from a foreign seller that places a circular product on its market as an e-commerce service, packaging included (Decree 80/2023, § 10(2)). Amazon states the same position for the other countries: some may require one from a producer outside the EU, others may not (Amazon). Where a country has not used the option, Article 45(3) puts no duty on a seller from outside the EU. The steps, fees and weights per country are on packaging EPR.

Electrical equipment: Germany registers a producer from abroad only through its representative

For a seller established in another EU country, the Directive tells each country to make its own sellers appoint a representative in the country they sell to, and says a distance seller not registered there is registered through that representative (Art. 17(2)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 17, paragraph 2Click opens the article on EUR-Lex., Art. 16(1)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 16, paragraph 1Click opens the article on EUR-Lex.). The appointment is by written mandate (Art. 17(3)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 17, paragraph 3Click opens the article on EUR-Lex.). For a seller from outside the EU, neither article says whether it registers directly or needs a representative.

Germany answers it. A producer without an establishment in Germany must appoint a representative, in writing and in German, for at least three months, and only one; § 8(2) extends the same duty to the distance seller described in § 3 no. 9 (d) (§ 8(1), § 8(2) ElektroG). The producer names the representative to the authority with a copy of the mandate, and the naming needs the authority's confirmation. As long as none is named, the obligations fall on the producer established in Germany that brought the goods in, where there is one (§ 8(3), § 8(4) ElektroG).

stiftung ear, the German register, says a foreign company "cannot register yourself" and needs a representative located in Germany. Any reliable and legally capable person with a branch in Germany can be one, and your own affiliated company can be named. Unlike the packaging register, it publishes a list of the representatives it has admitted, those that agreed to be listed (stiftung ear). Registration is made by the producer or, where one is appointed, by its representative (§ 6(1) ElektroG).

The same German law also works the other way: a business established in Germany that sells at a distance to end users in another EU country must appoint a representative there before it sells (§ 8(5) ElektroG). That is how Article 17(2) is enforced. The product-by-product rules, the number and the take-back duty are on WEEE registration.

In Spain the registration decree (Real Decreto 110/2015) names a representative only for sellers in other EU states, but the register’s guides require one of every distance seller, and a producer with no Spanish seat registers only through it. The import-control decree also requires one of an importer not established in Spain, without saying whether a seller outside the EU that ships to a buyer in Spain is that importer (art. 5(3) Real Decreto 993/2022): WEEE registration in Spain.

Batteries: the Regulation requires a representative from every distance seller

A producer who sells batteries by distance contract directly to end users, whether or not they are households, in a country where it is not established, from another EU country or from a third country, falls under point (d) of the producer definition (Art. 3(47)(d)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 47, point (d)Click opens the article on EUR-Lex.). That producer "shall appoint an authorised representative for extended producer responsibility in each Member State in which it sells batteries", by written mandate (Art. 56(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 56, paragraph 3Click opens the article on EUR-Lex.). Batteries built into appliances, light means of transport or other vehicles are included, so this reaches a seller of a product with a battery inside (Art. 55(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 2Click opens the article on EUR-Lex.). Chapter VIII, where these articles sit, has applied since 18 August 2025 (Art. 96(2)(c)Regulation (EU) 2023/1542, Batteries RegulationArticle 96, paragraph 2, point (c)Click opens the article on EUR-Lex.).

The register treats the representative as an equal route. A producer may make batteries available in a country only if it, or in the case of authorisation its representative, is registered there (Art. 55(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 2Click opens the article on EUR-Lex.). Germany requires every producer without a German establishment to appoint one, in writing and in German, only one, acting in its own name (§ 40(2) BattDG). Distributors may not make the batteries of a producer available if it, or its representative, is not properly registered, and fulfilment providers may not store, pack, address or ship them (§ 4(3) BattDG).

Amazon says it knows some countries are still adapting and have no procedure for a representative yet (Amazon). The duty in the Regulation does not wait for them. How the battery register, labels and dates work is on the EU Battery Regulation.

Textiles: the EU rule follows each country's scheme, and the Netherlands, Hungary and France already ask for a representative

The textile act mirrors the packaging split. A country must make a producer established in another EU country appoint a representative on its territory by written mandate, and may require the same of a producer established in a third country (Art. 22a(3)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 3Click opens the article on EUR-Lex.). A producer responsibility organisation appointed by written mandate can meet that duty for you if you wish (Art. 22a(4)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 4Click opens the article on EUR-Lex.). The producer who sells at a distance directly to end users from another country is the one this reaches (Art. 3(4b)(d)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 3, paragraph 4b, point (d)Click opens the article on EUR-Lex.). The countries must bring their law into force by 17 June 2027 and establish the schemes by 17 April 2028 (Article 2(1) of the DirectiveDirective 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 2, paragraph 1Click opens the article on EUR-Lex., Art. 22a(14)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 14Click opens the article on EUR-Lex.).

Three countries already ask. The Netherlands, since 1 July 2023: a producer that is not established there appoints a legal or natural person established in the Netherlands as its authorised representative for its obligations under the decree, which covers clothing and household textiles, not footwear (Besluit, Art. 1(2), Art. 2(1), Art. 8). Hungary: a producer established abroad that places a circular product on the Hungarian market as an electronic commerce service meets its duties through an authorised representative, who is liable for them. The rule names every circular product, not textiles alone (Decree 80/2023, § 10(2), § 10(3)). France, under the rule below. The textile scheme itself, the products and the 2028 date are on textile EPR.

France: one mandate rule in the Environment Code

Article 5 of Law no. 2026-602 of 8 July 2026 added Article L. 541-10-9-1 to the Environment Code. When a person not established in France is subject to extended producer responsibility under Article L. 541-10 or L. 541-10-9, it "désigne, par mandat écrit, une personne physique ou morale établie en France en tant que mandataire": unofficial translation, designates, by written mandate, a natural or legal person established in France as its representative to ensure its obligations under the producer responsibility regime. The representative is subrogated into all the obligations it accepts. The duty counts as met for products for which a person named in Article L. 541-10-9 and established in France ensures the obligations (Loi n° 2026-602, Art. 5; loi n° 2026-602 du 8 juillet 2026).

Three points about the text. Article 5 sets a later start, 1 September 2026, only for the new paragraphs II to V of Article L. 541-10-27; it sets none for L. 541-10-9-1. It names no product stream, no seller size and no sales channel: it covers any person not established in France that is subject to the producer-responsibility principle under the two articles. And Article L. 541-10-9 is the AGEC provision on online marketplaces and similar intermediaries, so the exception is the case where a marketplace established in France meets the obligations for your product (Ministry, ADEME).

ADEME's page on the unique identification number still says you "may" assign a representative to take on your duties and give the registering party your details, with no date, so it does not yet say the duty is compulsory (ADEME). Légifrance, the official site, returned an access block to our fetch, so the text above is the one Ineris reproduces. What the mandate means in practice for a seller outside France is on France packaging EPR. What Italy’s representative clause means for a seller outside the EU is on Italy packaging EPR.

The representative takes over your producer duties, and what that means differs by country

The EU definitions say the representative is appointed to fulfil the producer's obligations (Art. 3(20)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 20Click opens the article on EUR-Lex., Art. 3(48)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 48Click opens the article on EUR-Lex., Art. 17(2)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 17, paragraph 2Click opens the article on EUR-Lex.). The texts we read go no further than that, and the countries fill in the rest.

• Germany, packaging. It counts as a producer for the duties it takes over and acts in its own name. Duties that arose while it was named stay with it after the mandate ends (§ 5(3), § 5(6) VerpackDG). The ZSVR says it "assumes full responsibility for all obligations" under the PPWR and the VerpackDG (ZSVR).
• Germany, electrical equipment. stiftung ear says the representative is mandated to perform all the producer duties in its own name, and the legal obligations pass to it once the register confirms the mandate. Duties that arose while it was named stay with it after the mandate ends (stiftung ear, § 8(4) ElektroG).
• Spain. With no representative named, the first distributor or trader of the packaged product with a seat in Spain carries the producer duties instead (Art. 17.2 RD 1055/2022). The Ministry says an online platform is no longer that subsidiary producer from 12 August 2026 (MITECO).
• France. The representative is subrogated into the obligations it accepts (L. 541-10-9-1).

What the texts do not say is whether you stay liable next to the representative for the duties it took over. We found no official statement on that. For the one duty the German packaging law keeps with you, registering, the authority says it is yours alone.

Marketplaces and fulfilment providers check your registration number, held by you or, where the country provides, by your representative

The law asks a marketplace for your registration number and a self-certification, not for the contract with your representative. An online platform inside Section 4 of Chapter III of the Digital Services Act that lets consumers buy from you must obtain your registration number in the buyer's country and your self-certification that you comply with the EPR rules there (Art. 45(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 4Click opens the article on EUR-Lex., Art. 62(6)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 6Click opens the article on EUR-Lex., Art. 22a(13)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 13Click opens the article on EUR-Lex.). For packaging it does so before you use its services, and it must make best efforts to check that the information is complete and reliable (Art. 45(6)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 6Click opens the article on EUR-Lex.). That Section leaves out platforms run by micro and small enterprises, unless they are very large online platforms (Art. 29Regulation (EU) 2022/2065, Digital Services ActArticle 29Click opens the article on EUR-Lex.). A fulfilment provider gets the same information when you sign its contract, and suspends its service for your packaged goods if you do not correct what looks wrong; you can challenge the suspension in court (Art. 45(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 7Click opens the article on EUR-Lex., Art. 45(8)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 8Click opens the article on EUR-Lex., Art. 45(9)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 9Click opens the article on EUR-Lex.).

In Germany and Spain, where one is required, you cannot finish registering without one, so you have no number to give a marketplace.

• Germany. A distributor may not make packaging available when the producer is not registered, and a fulfilment provider may not serve an unregistered producer. The ZSVR gives platforms and fulfilment providers an automated comparison with the LUCID data (§ 13(3), § 13(4) VerpackDG). For electrical equipment a marketplace operator may not let the equipment of an unregistered producer, or one whose representative is not registered, be offered or made available (§ 6(2) ElektroG).
• Spain. Platforms obtain your number and a self-certification that you belong to a scheme and, if you sell from outside Spain, have a representative (MITECO).
• Amazon. Its Germany page tells a seller without a German branch it may appoint a representative, repeats that the LUCID registration stays personal, and asks for the LUCID number in Account Health. The page still refers to the old VerpackG (Amazon, Germany). The packaging page for the new Regulation says a producer based in the EU but not in the country of sale must appoint one, and that for a producer from outside the EU some countries may require it (Amazon, PPWR).
• Etsy. Its pages for Germany and Spain say a producer established outside the country needs an authorised representative there. The numbers go in Shop Manager, under Finances, Legal and tax information (Etsy, Germany and Etsy, Spain). Etsy's Germany page still names the VerpackG too.

How Amazon and Etsy collect the numbers, country by country and stream by stream, is on EPR in the EU.

No EU text sets a fee, and the one official figure is a register's

The representative is paid under its own contract. No EU text sets the amount, and the ZSVR says only that representatives charge fees and publishes no list of them (ZSVR).

The one figure we found from an authority is stiftung ear's example for a representative acting for two companies: EUR 120.20 once and EUR 270.00 a year, net of VAT. These are the register's own charges. Once: registering the two producers and confirming the representative for each. Yearly: their quarterly fees and guarantee checks. They are not the representative's price. The page says further fees can arise, for example by quantity placed on the market, and gives the example no year (stiftung ear). The scheme fees you pay besides are on EPR fees.

Without a required representative, registration stalls and marketplaces stop the goods

Each EU country sets the penalty. The EU texts require penalties that are effective, proportionate and dissuasive (Art. 68(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 68, paragraph 1Click opens the article on EUR-Lex., Art. 93Regulation (EU) 2023/1542, Batteries RegulationArticle 93Click opens the article on EUR-Lex., Art. 22Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 22Click opens the article on EUR-Lex.), and the countries add the rest.

• Germany, packaging. LUCID will not complete the registration without the representative's details, and no packaging may be made available for an unregistered producer. Failing to register, or making packaging available unregistered, can each cost a fine of up to EUR 100,000 (ZSVR, § 13(1) VerpackDG, § 66(1) nos. 1 and 8, § 66(3) VerpackDG).
• Germany, electrical equipment. Failing to name a representative is a fine of up to EUR 100,000 (§ 45(1) no. 7, § 45(2) ElektroG).
• Spain. The representative registers you; without one you have no Spanish number to give a platform (Art. 44(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 4Click opens the article on EUR-Lex., Art. 45(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 4Click opens the article on EUR-Lex., MITECO).

Who checks and what has happened to sellers is on EPR in the EU.

Choosing, changing and ending a representative

• One at a time. Germany lets you name only one per producer, for packaging, for electrical equipment and for batteries. To change an electrical-equipment representative, the old mandate must be ended in the register first, and only then is the new one confirmed (stiftung ear).
• Ending it ends the registration. When the mandate ends, stiftung ear confirms the end and revokes the registrations (stiftung ear). For packaging, you tell the ZSVR without delay, and the naming ends when the ZSVR confirms the end (§ 5(6) VerpackDG).
• Who may act. For German packaging the representative cannot be affiliated with you. For German electrical equipment an affiliated company can be named.
• The list. stiftung ear publishes a list of admitted electrical-equipment representatives. The ZSVR publishes none.

What the law leaves open

• Which other countries require a representative from outside the EU. PPWR Article 45(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 3Click opens the article on EUR-Lex. and Article 22a(3)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 3Click opens the article on EUR-Lex. of the waste Directive leave it to each country, and we read the national texts of Germany, Spain, France, Hungary and, for textiles, the Netherlands. Hungary requires a representative from foreign sellers that place a circular product on its market as an e-commerce service. For any other country, no EU text decides it.
• Whether you stay liable beside the representative. The texts we read do not say, except that registration in Germany stays yours.
• Whether France's rule needs a separate mandate per stream. The text speaks of one written mandate and names no stream. We found no official guidance on whether one representative can hold all of them.
• How electrical equipment from outside the EU is treated outside Germany. Article 17(2)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 17, paragraph 2Click opens the article on EUR-Lex. is written for sellers established in an EU country, and each country fills the gap.