EPR authorised representative: which countries, and is it included?

Yes, in each country where you sell directly to consumers and are not established. An EPR authorised representative is required for packaging under Regulation (EU) 2025/40, Article 45(3), and for batteries under Regulation (EU) 2023/1542, Article 56(3). For electronics, you register through one where you are not registered yourself (Directive 2012/19/EU, Article 16(1)). Eldris includes the representative wherever the law requires one, appointed under the power of attorney you sign. Where a country bills the representative's fee separately, that line passes it through at cost and says so.

Which law asks for a representative, stream by stream

Each stream has its own EU act and its own article. For packaging and batteries, a producer that sells to consumers in a member state where it has no establishment appoints an authorised representative there. For electronics, it registers in that country through an authorised representative where it is not registered there itself.

An authorised representative is the party a producer appoints in a member state where it has no establishment, and its registration in that country is made through it. The duty is national, not European. Each member state where you sell to consumers counts on its own, and one representative does not cover the whole bloc.

A seller of packaged electronics with batteries can need a representative under all three acts in one country. One appointment can serve several streams where a line says so: the Lithuania lines on the price list name one authorised representative shared across all registered streams.

EU-established or based outside the EU: the countries that count

The test is the same for both: a representative in every EU country where you sell directly to consumers and are not established. A seller based outside the EU is established in none of them. An EU company needs one in each other member state it sells to, but not at home.

Take a company established in Germany that sells to consumers in France, Italy and Spain. At home it needs no representative, because it is established there. In each of the other three it needs one for packaging and batteries, and for electronics where it is not registered there itself. A seller based in the UK or the US with the same sales needs one in all four countries, Germany included.

The sales channel does not change this. A direct sale to consumers in another country, through a marketplace or your own website, makes your packaging available there for the first time. You then register there (Regulation (EU) 2025/40, Articles 3(1)(15) and 44(2)). A German registration does not cover France. The three acts apply in the 27 EU member states; Norway keeps its own registers outside the EU, and UK battery rules have no representative route. Each page on the country index states the rule for its market.

What the Eldris price covers for the representative

The representative is included in the Eldris price wherever the law requires one. The exception is a line whose price list passes the representative's fee through at cost: on the 2026 list, that is Portugal packaging. Your quote shows such a fee on its own line, at cost.

Each country price covers the registration with the national authority and scheme, and the representative where one is required. Third-party fees sit outside it: scheme memberships, authority fees, and recycling contributions above any allowance in the line. They are listed against each line and invoiced at cost, either by the scheme or authority or by Eldris, never marked up. The scheme's published tariffs for each market are on the scheme and authority fees page.

Holding a German LUCID number already does not lower the Germany packaging price. LUCID registration is free, and the line charges for the representative and the dual-system participation. Eldris sells the full registration for a country, with the representative inside it; the representative is not sold on its own. What every line includes, and what it passes through, is on the pricing page.

Who acts as your representative, and who you deal with

The representative is appointed under the power of attorney you sign for each country. That document names EldrisAi OÜ as your single point of contact. You deal with Eldris, and need not deal with the parties appointed in your name.

After payment, the portal asks for six documents, one of them a signed power of attorney for each country. Eldris sends pre-filled templates, and you sign exactly as your name appears in your passport. Most are signed online. Some countries add a step: Poland signs in ink, and Italy may need notarisation, which Eldris confirms before you sign.

The power of attorney lets Eldris register you with schemes and national registers, and report your data to them. It also lets Eldris appoint the authorised representative, each party acting in your name. Eldris then files with each national authority and scheme, the representative included, and handles correspondence with the authorities from then on. Your registration numbers and certificates arrive in your Eldris dashboard. If you already hold a representative contract in a country, say so before you pay: taking it over is quoted separately.

PPWR representative or EPR authorised representative: one role for packaging

For packaging they are the same appointment. The PPWR representative is the packaging representative under Regulation (EU) 2025/40, Article 45(3), and it is one of the three a seller may need. Batteries and electronics each have their own article and their own register.

Sellers meet both names because the packaging rule sits in the PPWR. Batteries and electronics sit in acts of their own. 'EPR representative' is the wider term, covering the representative for each stream in each country. A seller of packaged goods to consumers in a country needs the packaging one there, plus the battery and electronics ones where those streams apply. Neither replaces the other. The question to ask is not which name applies, but which streams you sell in each country.

The EPR representative is also a different role from the EU Responsible Person that product-safety law asks for. The packaging representative guide covers that difference and the PPWR's own rules. The German WEEE representative guide covers one register's process, and the PPWR overview covers the regulation as a whole. The short answer sits with the others on the questions sellers ask.

Frequently asked questions

Does one representative cover the whole EU?

No. The duty is set country by country, so you need one in each member state where you sell directly to consumers and are not established. A representative in Germany does not act for you in France. Within one country, a single appointment can serve several streams where that country's line says so.

Does my EU company need a representative in its home country?

No. The duty applies where you sell to consumers and are not established, so your home member state is not one of them. You need one in each other member state where you sell directly to consumers: for packaging and batteries, and for electronics where you are not registered there yourself.

Can I buy the representative without the registration?

No. Eldris sells the full registration for a country, with the representative included where the law requires one; the representative is not sold on its own. If you already hold registrations elsewhere, say so before you pay, and the portal asks for those numbers country by country.

I sell only to businesses. Do I still need one?

The rule set out here is about direct sales to consumers. If you sell only to businesses, ex-works, or with your buyer acting as importer, reply to your quote before you pay. The answer depends on the details, and Eldris confirms it for your case.

Do I need a representative in the UK or Norway?

Different rules apply. UK battery rules have no representative route. Since 12 August 2025, a marketplace is the producer for electricals that a non-UK seller sells through it to UK households. Norway keeps its own registers outside the EU. Each country page says what applies there.

Who do I contact about my representative?

Eldris. The power of attorney you sign names EldrisAi OÜ as your single point of contact, and Eldris handles correspondence with the authorities. You do not need to deal directly with the parties appointed in your name.