EPR Authorized Representative 2026: Who Needs One, Where?

Short answer: if you sell packaged products directly to end users in an EU member state where you are not established, you need an authorized representative there — whether your company sits in the EU or outside it (Art. 45 PPWR, since 12 August 2026). For electrical equipment and batteries, EU law sets comparable duties for distance sellers, and several countries go further: France requires a representative for every EPR stream, Spain from every packaging producer established abroad, Germany from every producer of electrical equipment and batteries without a German establishment.

Authorized representative at a glance

What it is: A person or company established in the member state, appointed by written mandate to fulfil a producer's EPR obligations there.
Packaging: Art. 45 PPWR, since 12 August 2026: producers — EU or non-EU — that sell packaged products directly to end users in another member state. One representative in each member state they sell into.
Electrical equipment: WEEE Directive, Art. 17, applied through national laws: distance sellers established in one member state appoint a representative in the member state they sell into. For sellers outside the EU, national law decides.
Batteries: EU Battery Regulation, Art. 56(3), EPR regime since 18 August 2025: according to law-firm analysis, distance sellers from another member state or a third country appoint a representative in each member state where they sell batteries.
Countries that go further: France (all EPR streams, every producer not established in France), Spain (packaging: every producer established abroad), Germany (electrical equipment and batteries: every producer without a German establishment).
Not needed: In the member state where your own company is established.
Exemption?: Proposal – not yet law For small EU-established packaging producers. It would not help sellers established outside the EU.

What it is and why
The three EU rules
Do I need one?
Country overview
Proposed exemption
What it does
How Certify helps
FAQ

What an authorized representative is — and why the law asks for one

An EPR authorized representative is a person or company established in a member state that fulfils a foreign producer's extended producer responsibility (EPR) obligations in that state, on the basis of a written mandate. EU law spells it "authorised representative"; the national names are Bevollmächtigter (Germany, Austria), mandataire (France), representante autorizado (Spain), rappresentante autorizzato (Italy) and autoryzowany przedstawiciel (Poland).

The reason is practical. EPR runs through national registers, national schemes and national authorities. A seller that ships parcels in from another country has no address in the destination country and nobody there who answers for its products. The representative closes that gap: it is a party inside the country that registers and authorities can deal with, and that carries the producer's duties there.

Two things the representative is not. It is not a fiscal (VAT) representative — that is a separate role under tax law. And it does not make registration unnecessary: in Germany the LUCID registration stays with the producer, and in France every EPR stream still needs its own identification number (UIN).

The three EU rules behind the duty

There is no single EU rule on authorized representatives: packaging, electrical equipment and batteries each have their own. A seller of packaged electronics with a built-in battery has to check all three.

Product	EU rule	Who has to appoint a representative
Packaging	Art. 45 of the Packaging Regulation (PPWR, Regulation (EU) 2025/40), applies since 12 August 2026	Producers that sell packaged products directly to end users in another member state (distance sellers), whether established in the EU or outside it — in each member state where they first make packaging available, other than their own. For other non-EU producers, member states may require one.
Electrical and electronic equipment	Art. 17 of the WEEE Directive 2012/19/EU, applied through national laws	Member states must make sure that distance sellers established on their territory appoint a representative in the member state they sell into, and must allow producers from other member states to appoint one. Appointment is by written mandate. For sellers outside the EU, national law decides.
Batteries	Art. 56(3) of the Battery Regulation (EU) 2023/1542, EPR regime since 18 August 2025	According to law-firm analysis: producers that sell batteries — including batteries built into devices — by distance contract directly to end users, and are established in another member state or a third country, appoint a representative by written mandate in each member state where they sell.

For packaging, the European Commission has asked member states to enforce the representative duty in a "constructive and pragmatic" way while an exemption is being negotiated. That is guidance on enforcement, not an exemption: the duty applies.

Do I need one? Six typical situations

The decisive questions are where your company is established and whether you sell directly to end users in the destination country.

Your situation	Authorized representative needed?
You sell only in the member state where your company is established	No. The duties apply in member states other than your own.
EU online shop shipping packaged goods to consumers in other member states	Yes, for packaging, in each destination country (Art. 45 PPWR). An exemption for small quantities is under negotiation. Proposal – not yet law
Seller outside the EU (for example US, UK, China) shipping directly to end users in the EU	Yes, for packaging, in each destination country. The proposed exemption does not cover you.
You sell electrical equipment or devices with batteries directly to end users abroad	Usually yes: the WEEE and battery rules add their own representative duties, with national differences. See the country pages below.
Non-EU manufacturer supplying an EU importer or distributor, no sales to end users	Depends on the country: for these producers, member states may require a representative. Often the importer counts as the producer.
You sell only through a marketplace	Check per country. France treats the duty as met where a France-established marketplace handles compliance; in Spain, Amazon's paid fallback service does not replace your own registration.

Not sure which row is yours? Ask for a free check — you get an answer for your countries and products.

Country overview: where a local representative is required

National rules sit on top of the EU rules, and they differ. The five countries we are asked about most often have their own page; for the others, the link leads to the full country guide. "See guide" marks points we have not yet verified against an official source.

Country	Packaging	Electrical equipment	Batteries
Italy	Italy-based representative with Italian VAT number and PEC for sellers without an Italian establishment; PPWR representative for direct sales to end users	Registro AEE before the first sale; registration directly or through a representative (according to ERP Italia)	Registro Pile; EU battery rule for distance sellers
France	Mandataire for every producer not established in France, since 10 July 2026	Same duty (all EPR streams)	Same duty (all EPR streams)
Germany	Only without a German branch and with direct sales to end users (§ 5 VerpackDG)	Required without a German establishment	Required without a German establishment
Spain	Representante autorizado for producers established in another EU member state or outside the EU	Check case by case	EU battery rule for distance sellers
Poland	Art. 45 PPWR applies; national implementation pending	Mandatory for foreign distance sellers (Art. 26(2) WEEE Act)	EU battery rule; national implementation pending
Austria	Bevollmächtigter for foreign distance sellers to private consumers	Bevollmächtigter for foreign distance sellers	Bevollmächtigter for foreign distance sellers
Belgium	Representative established in Belgium and registered with EPRiBEL, since 12 August 2026	See guide	See guide
Sweden	EU-established producers appoint an "auktoriserat ombud", since 12 August 2026	EU distance sellers: Sweden-established representative; non-EU sellers may register directly	EU distance sellers: Sweden-established representative; non-EU sellers may register directly
Portugal	Mandatory for foreign distance sellers to end users, since 1 January 2022	Mandatory for foreign distance sellers to end users, since 2018	Mandatory for foreign distance sellers to end users, since 1 January 2022
Ireland	See guide	Irish representative for distance sellers outside Ireland	Irish representative for distance sellers outside Ireland
Denmark	According to the Danish register: EU companies need a Danish representative; non-EU companies may register directly	See guide	Representative required, also for non-EU companies
Czech Republic	Art. 45 PPWR; representatives report to EKO-KOM	See guide	See guide

Is the duty being relaxed?

Possibly, for small EU-established packaging producers — but not yet, and not for sellers outside the EU.

Proposal – not yet law EU exemption for small EU-established producers. The European Commission's Environmental Omnibus of 10 December 2025 proposes suspending the authorized-representative duty for producers established in the EU. The European Parliament adopted its position on 20 October 2026 (as reported: an exemption for EU micro and small enterprises until 2035). The Council's negotiating mandate of 21 October 2026 covers packaging only: EU-established producers placing less than 1 tonne of packaging per year in another member state would not need a representative there until 1 January 2032. It does not cover batteries. Trilogue negotiations follow. None of this is law yet, and none of it helps sellers established outside the EU — until a final text is adopted, the current duty applies.

We track the negotiations on our PPWR 2026 page and update the country pages when a final text is adopted.

What the representative does — and what stays with you

The representative is your legal address for EPR in the country: the contact for the register, the schemes and the authorities, in the national language. What exactly it does depends on the country and on the mandate:

Registration: in Spain the representative enters the producer in the national producer register and reports the data; in Germany the producer enters the representative in the LUCID register and the appointment takes effect once the representative confirms it.
Form: the EU rules require a written mandate. Germany requires the packaging contract in German; in Poland the contract for electrical equipment must be in writing, otherwise it is void.
Country by country: a representative has to be established in the country it acts in, so each destination country needs its own appointment. In Germany a packaging producer can appoint only one representative.

What stays with you: the data on what you actually place on each market, and the scheme fees for your products.

How Certify helps

Free obligation check. Tell us what you sell into the EU, through which channels (Amazon, eBay, your own shop) and where your company is established. We tell you which representative duties apply to you — and which do not.
Registration and representation. Certify prepares the registrations and, where the law requires it, acts as your authorized representative. Certify offers an authorized representative in all EU member states.
Ongoing compliance. Certify supports the recurring declarations and reports, so your registration numbers stay valid for marketplaces and authorities.

This page explains the obligation. If you already know that you need a representative, the practical steps are on our sister site: appointing an EPR authorized representative (register-epr.com).

Start the free obligation check

FAQ: EPR authorized representative

What is an EPR authorized representative?

An EPR authorized representative is a person or company established in an EU member state that fulfils a foreign producer's extended producer responsibility obligations in that state on the basis of a written mandate. EU law spells it authorised representative.

Who needs an authorized representative under the PPWR?

Since 12 August 2026, producers that sell packaged products directly to end users in another member state must appoint an authorized representative in each member state where they first make packaging available, other than their own. This applies to producers established in the EU and outside it. For other non-EU producers, member states may require one.

Do EU companies need a representative, or only sellers from outside the EU?

Both. The PPWR duty depends on selling directly to end users in another member state, not on being established outside the EU. A German online shop shipping to consumers in Italy is covered just like a seller from the United States.

Is one authorized representative enough for the whole EU?

No. The duty applies separately in each member state you sell into, and the representative has to be established in that member state. Germany, for example, allows only one representative for packaging and requires the contract in German.

Is the duty being abolished for small sellers?

Not yet. An exemption for small EU-established producers is being negotiated: the Council's mandate of 21 October 2026 would exempt EU-established producers placing less than 1 tonne of packaging per year in another member state until 1 January 2032, and the European Parliament adopted its own position on 20 October 2026. This is a proposal, not law, and it does not help sellers established outside the EU.

Does selling through a marketplace replace the representative?

Check each country separately. France treats the duty as met where a France-established marketplace handles compliance for the seller. In Spain, Amazon enrols sellers without a Spanish packaging registration number in a paid fallback service, which does not replace the seller's own registration.

Do I need a representative for electrical equipment and batteries too?

Often yes. The WEEE Directive and the EU Battery Regulation contain their own representative rules for distance sellers, and national laws differ: Germany requires a representative from every producer without a German establishment, Poland from every foreign distance seller of electrical equipment, and France for all EPR streams.

Sources (official and legal references)

This page is general information, not legal advice. Last reviewed 5 November 2026.

Related guides

Representative rules differ from country to country and from product to product:

🇮🇹 Representative in Italy 🇫🇷 Representative in France 🇩🇪 Representative in Germany 🇪🇸 Representative in Spain 🇵🇱 Representative in Poland 🇦🇹 Austria 🇧🇪 Belgium 🇸🇪 Sweden 🇵🇹 Portugal 🇮🇪 Ireland 🇩🇰 Denmark 🇨🇿 Czech Republic 🇳🇱 Netherlands 📦 PPWR 2026 📅 Deadlines 🇪🇺 All countries

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EPR Authorized Representative 2026:Who Needs One, and in Which Country?