Rules read on 2026-08-18 · From the national register pages; legal review pending.
At a glance — how the 27 implement the regime
| Regime | Member States | Count |
|---|---|---|
| Without a local establishment the local importer generally carries it | Italy | 1 |
| Representative regime for sellers established outside the EU | France | 1 |
| A representative may carry the obligation | Finland | 1 |
| Representative required when the company has no establishment there | Austria, Denmark, Spain | 3 |
| Registration by the producer itself only — cannot be delegated | Germany | 1 |
| Not read from an official source yet | Belgium, Bulgaria, Croatia, Cyprus, Czechia, Estonia, Greece, Hungary, Ireland, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Sweden | 20 |
What Article 45(3) asks
The Regulation applies the representative to one situation at Union level: cross-border distance sales to end users. The seller established in another Member State (or outside the Union) appoints an authorised representative in the Member State where the consumer is, and that representative fulfils the producer’s registration and reporting obligations there.
Article 45(4) adds the marketplace rule: providers of online platforms must obtain information on the registration of the producers that sell through them in the Member State of the consumer before they let them sell — which is why the registration number matters even for a small seller.
Where national law goes further, or not at all
Some Member States allow — or require — a representative for any non-established producer, distance sales or not; one does not allow delegation of the registration at all (Germany, LUCID: the producer registers itself); others let the local importer carry the obligation when the seller has no establishment. The grouping above is read from each register page and dated; « not read yet » is shown as such.
What the representative does — and does not
- Registers in the national register in the producer’s name and reports the volumes — the producer stays liable for the data.
- Contracts, where the state requires it, the scheme for the packaging placed on that market.
- Does not replace the producer’s own registration in the Member States where the producer is established.
- Does not exist in the UK, the US states or the Canadian provinces: there the obligation moves to another party instead (see our pages for exporters).
How PPWR Connect helps here
The obligation check answers, per Member State, whether the obligation falls on you, on your importer or through a representative, with the reason and the national source; the EPR matrix keeps the representative’s registration number where you record it. We do not act as a representative and do not file for you.
Five questions
- Do I need an authorised representative in every Member State I ship to?
- Under Article 45(3), for cross-border distance sales to end users, yes — in the Member State of the consumer. For B2B sales the answer depends on the national regime read above.
- Can a representative register for me in Germany?
- No. Germany requires registration by the producer itself (LUCID); the representative regime does not apply there.
- Does a representative exist outside the EU?
- Not in the EU sense. The UK, the US states and the Canadian provinces move the obligation to a locally established party or to the brand owner; nobody is appointed.
- Is the representative liable instead of me?
- The representative fulfils the obligations in your name; how liability is shared is set by national law and your mandate. Not legal advice — verify with the register.
- Does PPWR Connect act as a representative?
- No. It tells you where a representative is required and keeps the registration data; it never files or acts in your name.
Primary sources
What the Regulation and the sourced national rules imply — an indication provided for information, not legal advice. Verify with the official register before appointing a representative.