How to appoint an EPR authorised representative in 2026

By the end of this guide you will have an EPR authorised representative appointed in every country and for every waste stream that asks for one, with a signed mandate behind it and the appointment showing on the national register.

It is for sellers supplying EU customers from outside the EU, and for producers selling into EU countries where they have no company. There is no single representative that covers the whole EU, and whether you need one depends on the waste stream.

What your representative will need from you

An appointment is mostly paperwork about you, so it goes faster if these six things already exist somewhere other than your head.

1. Your legal identity. Registered company name and address, your trade register number, and your European or national tax number. The packaging register asks for all of it, and nobody can file in your name without it.

2. The countries where your goods reach a customer first. Not where you ship from and not where your stock sits. The country where the product first reaches an end user is the country that can ask you for a representative.

3. The waste streams you place in each of those countries. Packaging, electricals, batteries, single-use plastics, textiles. One country can need a separate appointment for each one.

4. Your brand names. Registers list producers brand by brand, so a brand you forgot to declare is a brand that looks unregistered to an authority or a marketplace.

5. Last year's volumes, by material and by country. Your representative files those numbers, and for packaging the deadline is 1 June for the previous calendar year.

6. Someone who can sign for your company. Every rule below asks for a written mandate, and Germany asks for it to be written in German.

If you are not yet sure which of your products fall under which stream, settle that first with our guide on how to check if EPR applies to your business, then come back.

Where the duty comes from and why it changes by stream

European waste law sets the route, not the details. Directive 2008/98/EC, the Waste Framework Directive, makes every Member State let a producer from another Member State appoint someone established on its own territory.

That person then carries the producer's extended producer responsibility (EPR) duties in that country. The same paragraph lets each country set its own requirements for anyone acting as a representative there, which is why the paperwork looks different in Berlin and in Paris.

On top of that route, each waste stream has its own rule about who is obliged to use it.

Batteries are the strictest of the five. The packaging and textile rules leave the third-country case to each Member State, while the battery rule simply says a distance seller established outside the country must appoint a representative in every Member State where it sells.

The other authorised representative is a different job

Packaging law uses the same words for two roles, which is the single most common mix-up on this topic.

This guide is about the first one. The second is explained in our glossary entry on what an authorised representative does for product compliance.

In practice the two roles sit with two different companies, so a provider offering to be "your EU representative" should be asked which of them they mean.

Step 1. Work out where you actually need one

Build a short grid before you contact anybody. One line for every country and waste stream pair you sell into, and one last column that says required, not required or find out.

Fill it in from the table above, then correct it against the country pages, because national law can go further than the EU minimum. Our country overview and the register directory show who runs what.

Leave the unknowns as unknowns. A cell you guess at is a cell you pay for twice, once for a representative you did not need and once for the country you missed.

Step 2. Read the local rulebook before you shop

Two markets most sellers touch show how far apart the mechanics sit. Germany writes its own rules stream by stream, while France has one rule that covers every stream a producer falls under.

German electrical law has required a representative for years from any producer without a German establishment, and it says exactly what the appointment has to look like.

German packaging law takes the opposite line on one point. A representative can carry your duties, but never the register entry itself, which stays yours whatever you sign.

Both are worth reading in the original before you sign anything. The German conditions sit in ElektroG paragraph 8, and the French rule in article L541-10-9-1 of the environment code.

So one company can need a German representative for its chargers under German law, a French mandataire for everything, and a packaging appointment in both under the EU rule that started on 12 August 2026. Write the rule you found next to each cell of your grid.

Step 3. Decide who holds the mandate

Whoever you pick has to be established in the country itself. A company in Ireland cannot be your representative in Spain, and no provider can be one representative for the whole EU, however the sales page is worded.

Beyond that the field is wider than most sellers realise. In Germany, the law lets a distributor, an electronic marketplace operator or a fulfilment service provider hold the mandate, as long as they are established there. Three routes are worth pricing against each other.

1. A specialist representative service. Their business is the register, so they are quickest in countries you barely know. Ask how many producers they already represent, because for German electricals the authority has to approve a representative that already holds twenty registrations.

2. Your own subsidiary or branch. If you already have a company in that country, it can carry the duty and you keep the data in-house.

3. A partner you already work with. Your distributor or your fulfilment provider is already established there. It costs less, but their mandate ends the day the commercial relationship does.

Whichever you pick, they act in their own name. Once mandated they are treated as the producer for the duties they took on, which is precisely why countries care so much who they are.

Step 4. Sign a mandate that says what it covers

The rules above that spell out a form all ask for the same instrument, a written mandate. What it has to contain is largely left to the two of you, so a thin mandate is legal and useless. Spell out six things.

Have your representative confirm the mandate in writing on their side too. For packaging, the register entry carries their name and address next to yours, and a register entry is hard to correct once it is wrong.

Step 5. Put the appointment on the register

A signed mandate on its own changes nothing. The appointment only counts when the register in that country knows about it, and for packaging the register entry then shows your representative's name and address next to yours.

Germany is the strictest version of this step. You name your representative to the authority without delay and attach a copy of the mandate, and the naming takes effect only once the authority confirms it.

Plan for that gap. Both the packaging rules and the battery rules stop you making products available in a country until you or your representative are registered there.

Keep two things once the register replies.

1. The registration number. Marketplaces and business customers ask for it, and from 12 August 2026 packaging law makes marketplaces collect it before they let you sell.

2. The confirmation itself. It is your evidence that the appointment is live, which the same marketplace rule makes you self-certify where a representative is required.

Step 6. Feed it and end it cleanly

An appointment is a standing arrangement, not a one-off purchase. Three habits keep it worth what you pay for it.

1. Send the data on time. Your representative files what you give them. For packaging the register report is due by 1 June for the previous calendar year, and EPR reporting is where most of the annual work actually sits.

2. Report changes as they happen. New brands, new categories, a new address, or stopping sales in that country. Battery law asks for notice without undue delay, and packaging law asks the same of any change to what you registered.

3. Overlap the mandates when you switch. In Germany the old appointment ends only when the authority confirms it ends, your former representative stays answerable for the period it covered, and while nobody is named the duty falls on the German company that puts your goods on the market.

The pattern behind all three is the same. The register is the record, so anything that has not reached the register has not happened yet.

Where Repax fits around your representative

Repax is not an authorised representative and does not file in your name. That job needs a company established in the country, carrying the liability, and we are neither.

What we do is the part your representative keeps asking you for.

1. One spec per product. Materials, weights and components structured once, so packaging, batteries and electricals come out of the same catalogue instead of three spreadsheets.

2. Sales data connected. Volumes come from your shop or your ERP, per country, rather than from a manual count at deadline.

3. A report per register. The same product data generates whatever shape the next filing takes, which is what you hand your representative in each country.

4. Documents attached to the product. Certificates and specs sit on the product they belong to, so an audit question is a lookup instead of a hunt.

You can see the product data model on the Repax Core page, and what it costs on our pricing page.

Red flags to check before you sign

Most bad appointments look fine on the day they are signed. These are the six that come back later.

1. "One representative for the whole EU." Not possible. Every rule quoted above puts the representative in the destination country.

2. "We cover all your streams." Ask which register, which stream, which country. In Germany a representative can never hold your packaging registration, whatever the contract says.

3. A mandate in English only. Germany requires German. A mandate the authority will not read is not an appointment.

4. No confirmation from the authority. In Germany the appointment counts only once the authority confirms it, and until you or your representative are registered you may not put products on that market.

5. A provider that will not say how many producers they represent. For German electricals, once a representative holds twenty registrations, the authority has to have approved that representative itself.

6. "You are no longer responsible." You still hold extended producer responsibility, marketplaces still make you self-certify, and duties that arose during a mandate survive it ending.

Frequently asked questions about appointing an authorised representative

Short answers to the questions producers ask before they start.

How long does this take

Signing the mandate takes days. Getting it onto the register is the part with a queue, and in Germany the appointment is not live until the authority confirms it, so treat a few weeks as normal and do not book a launch date against it.

Can one representative cover several countries for me

Not as one appointment. A representative has to be established in the country whose duties it carries, so five countries means five appointments. One provider group can arrange all five through local entities, which is a commercial convenience, not a single legal appointment.

Does appointing one move the responsibility off me

It moves the work and, for the duties in the mandate, the representative is treated as the producer. You still hold the extended producer responsibility itself, you still supply the data, and marketplaces still ask you to self-certify that a representative is in place where one is required.

Can my marketplace or my distributor be my representative

In Germany, yes for electricals, if they are established there. A distributor, a marketplace operator or a fulfilment provider can all hold the mandate. Check the same question separately in every other country, because the list of who qualifies is national.

What happens if I stop selling in a country

Tell the authority through your representative, and end the mandate in writing. Do not simply stop paying. The battery and packaging rules both ask for notice of a permanent stop, and a registration nobody closed still reads as an active producer.

Do I still need a PRO if I have a representative

Yes, in most markets. A representative carries your duties towards the authority, while a producer responsibility organisation is the scheme that collects and recycles. Joining one is a separate decision, covered in our guide on how to choose a producer responsibility organisation.