In force since 12 August 2026

Selling to another EU country and needing a representative there

A business that sends packaged goods straight to customers in another EU country has to appoint someone based in that country to handle its packaging duties there. The rules call this person an authorised representative for extended producer responsibility. It has to be done in writing, and separately for each country. For businesses based outside the EU the picture is different: each country decides for itself whether to require one.

Worth knowingThe rules use the same phrase, authorised representative, for a different job to do with product paperwork. Same words, different role.

Where a country does it differently

Austria requires a foreign seller without an Austrian base to appoint an Austrian representative. Austria also asks for more than a signed letter. The appointment has to be notarised, written in German or English, list which collection and treatment categories it covers, and record that the representative agrees to take on the duties.

Source: Unternehmensserviceportal (USP), Republic of Austria — read from this source on

In Germany an authorised representative takes on every extended producer responsibility duty except one: entry in the LUCID packaging register. Registering, and later changing those registration details, stays a duty of the business itself and cannot be handed over.

Source: Zentrale Stelle Verpackungsregister (ZSVR) — Packaging Act: Authorised representatives — read from this source on

A business based outside Germany that sells empty packaging or packaged goods straight to end users in Germany, with no branch there, appoints an authorised representative. That representative is entered in the LUCID register before anything is first made available on the German market. The German rules set out no exemption.

Source: Zentrale Stelle Verpackungsregister (ZSVR) — Packaging Act: Authorised representatives — read from this source on

Read the whole national picture for Austria, Germany.

Situations where this one comes up

Find someone who acts as a representativeThis site lists people and companies who say they act as a representative, organised by the country they act in. Nobody here is checked, rated or ranked — each listing is what that person wrote about themselves, and the conversation happens directly between the two parties.

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