[{"data":1,"prerenderedAt":847},["ShallowReactive",2],{"nav-latest-post-en":3,"blog-post-epr-authorised-representative-packaging-en":8,"translations-epr-authorised-representative-packaging-en":824,"related-epr-authorised-representative-packaging-en":833},{"stem":4,"title":5,"category":6,"cover":7},"en\u002Fblog\u002Fepr-authorised-representative-packaging","EPR authorised representative: what to do if you ship into another EU country","E-commerce","\u002Fassets\u002Fblog\u002Fmandataire-rep-emballages-ecommerce.jpg",{"id":9,"title":5,"about":10,"author":11,"body":12,"carriers":782,"category":6,"cover":7,"coverAlt":783,"date":784,"description":785,"draft":786,"extension":787,"faq":788,"meta":795,"navigation":796,"path":797,"seo":798,"seoTitle":799,"sources":800,"stem":4,"tags":814,"translationKey":822,"updated":784,"__hash__":823},"blog_en\u002Fen\u002Fblog\u002Fepr-authorised-representative-packaging.md","Extended producer responsibility for packaging and authorised representatives in the European Union","maelle",{"type":13,"value":14,"toc":758},"minimark",[15,73,76,79,82,87,94,97,100,104,107,202,205,212,216,219,233,239,242,262,266,273,280,283,303,307,314,321,364,371,375,378,381,387,393,399,405,411,414,418,421,431,518,524,530,533,539,546,550,557,560,566,570,607,611,614,621,633,640,644,647,708,711,715,720,723,727,730,734,737,741,744,748,751,755],[16,17,18,25],"blockquote",{},[19,20,21],"p",{},[22,23,24],"strong",{},"In short:",[26,27,28,35,46,53,59,66],"ul",{},[29,30,31,34],"li",{},[22,32,33],{},"Selling domestically is fine."," Crossing a border is what triggers everything.",[29,36,37,38,41,42,45],{},"As soon as you ship to a consumer ",[22,39,40],{},"in another EU country",", you need a ",[22,43,44],{},"representative in that country",". One per country.",[29,47,48,49,52],{},"A representative is a ",[22,50,51],{},"local company that takes on your obligations",". Like a fiscal representative for VAT.",[29,54,55,58],{},[22,56,57],{},"Your sales channel changes nothing."," Amazon, Shopify or a phone order: identical.",[29,60,61,62,65],{},"It only changes ",[22,63,64],{},"who checks you",". Large marketplaces must verify. Carriers and your own store do not.",[29,67,68,69,72],{},"Without registration it is not a fine: ",[22,70,71],{},"you have no right to sell in that country",".",[19,74,75],{},"You sell from your own online store. A customer in Germany orders, you pack the box, you send it. You have no office, no company and no tax number in Germany.",[19,77,78],{},"In the eyes of EU law you have nonetheless placed packaging on the German market. And since 12 August 2026, you are supposed to have a representative there.",[19,80,81],{},"This is the subject worrying the most people right now, and the one explained worst. Here is what matters.",[83,84,86],"h2",{"id":85},"why-the-rule-exists","Why the rule exists",[19,88,89,90,93],{},"When your parcel arrives at someone's home, the cardboard goes into the recycling bin. Collecting and recycling it costs the local authority money, and the EU rule says the taxpayer should not pay, the seller should. So every country runs a common pot funded by the people who ship: Citeo in France, LUCID in Germany, the national schemes in Spain and Portugal. That is ",[22,91,92],{},"EPR",", extended producer responsibility.",[19,95,96],{},"As long as seller and buyer are in the same country, it runs by itself.",[19,98,99],{},"Ecommerce broke that. Your cardboard ends up in a German bin, but you, in Germany, do not exist: no address, no company, nothing to inspect. The representative exists to plug exactly that hole.",[83,101,103],{"id":102},"your-case-in-one-table","Your case, in one table",[19,105,106],{},"Take a swimwear shop based in Porto. Shopify site, four people, shipping from a small unit.",[108,109,110,126],"table",{},[111,112,113],"thead",{},[114,115,116,120,123],"tr",{},[117,118,119],"th",{},"The order goes to",[117,121,122],{},"Representative?",[117,124,125],{},"Why",[127,128,129,144,159,174,188],"tbody",{},[114,130,131,138,141],{},[132,133,134,135],"td",{},"A consumer in ",[22,136,137],{},"Lisbon",[132,139,140],{},"No",[132,142,143],{},"You are at home.",[114,145,146,151,156],{},[132,147,134,148],{},[22,149,150],{},"Madrid",[132,152,153],{},[22,154,155],{},"Yes, in Spain",[132,157,158],{},"You are placing packaging on a market where you do not exist.",[114,160,161,166,171],{},[132,162,134,163],{},[22,164,165],{},"Lyon",[132,167,168],{},[22,169,170],{},"Yes, in France",[132,172,173],{},"Same.",[114,175,176,181,186],{},[132,177,134,178],{},[22,179,180],{},"Berlin",[132,182,183],{},[22,184,185],{},"Yes, in Germany",[132,187,173],{},[114,189,190,197,199],{},[132,191,192,193,196],{},"A ",[22,194,195],{},"Barcelona boutique"," reselling your swimwear",[132,198,140],{},[132,200,201],{},"You are not selling to the end customer.",[19,203,204],{},"Result: three representatives, and nothing in Portugal.",[19,206,207,208,211],{},"The fact that the site runs on Shopify changes ",[22,209,210],{},"nothing"," in that column.",[83,213,215],{"id":214},"the-rule-in-two-questions","The rule, in two questions",[19,217,218],{},"Ask them country by country:",[220,221,222,228],"ol",{},[29,223,224,227],{},[22,225,226],{},"Am I selling to the person who will use the product?"," Not a reseller, not a wholesaler: the end customer.",[29,229,230],{},[22,231,232],{},"Is that person in an EU country other than mine?",[19,234,235,238],{},[22,236,237],{},"Two yeses: representative required in that country."," Otherwise, nothing to do.",[19,240,241],{},"Three misconceptions to clear:",[26,243,244,250,256],{},[29,245,246,249],{},[22,247,248],{},"\"My website is Portuguese, so the sale happens in Portugal.\""," No. What counts is where the cardboard ends up in the bin.",[29,251,252,255],{},[22,253,254],{},"\"I am too small.\""," There is no threshold. A lighter reporting regime exists below 10 tonnes of packaging per year per country, but registration is still due from the first parcel.",[29,257,258,261],{},[22,259,260],{},"\"My carrier handles it.\""," No, and it is written in the text.",[83,263,265],{"id":264},"what-a-representative-is-and-what-it-involves","What a representative is, and what it involves",[19,267,268,269,272],{},"A company established in the destination country, appointed by written contract, which ",[22,270,271],{},"takes on your obligations",". Not an adviser: the obligations become theirs. Same principle as a fiscal representative for VAT.",[19,274,275,276,279],{},"What you end up with is a ",[22,277,278],{},"registration number"," in that country. That is the centrepiece: it is the number a marketplace will demand.",[19,281,282],{},"Three things to know before you start:",[26,284,285,291,297],{},[29,286,287,290],{},[22,288,289],{},"One representative per country."," Three countries, three contracts, three annual cost lines.",[29,292,293,296],{},[22,294,295],{},"Allow lead time."," The authority has up to twelve weeks to issue the number once the file is complete.",[29,298,299,302],{},[22,300,301],{},"Ask who files the application."," Depending on the country it is the representative, or you personally. Clarify before signing.",[83,304,306],{"id":305},"since-when-exactly","Since when, exactly",[19,308,309,310,313],{},"The idea of a representative has been around since 2008. But until now, each country had to ",[22,311,312],{},"allow"," you to appoint one if you wanted. It was an open door, not an obligation, and almost nobody walked through it.",[19,315,316,317,320],{},"What changed is the verb. The EU regulation now says the producer ",[22,318,319],{},"shall appoint"," a representative. An option became an obligation.",[108,322,323,332],{},[111,324,325],{},[114,326,327,329],{},[117,328],{},[117,330,331],{},"Since when",[127,333,334,344,354],{},[114,335,336,341],{},[132,337,338],{},[22,339,340],{},"European Union",[132,342,343],{},"12 August 2026",[114,345,346,351],{},[132,347,348],{},[22,349,350],{},"Spain",[132,352,353],{},"2022, ahead of the pack",[114,355,356,361],{},[132,357,358],{},[22,359,360],{},"France",[132,362,363],{},"10 July 2026, and broader: all EPR streams, not just packaging",[19,365,366,367,370],{},"And the penalty is not a fine. Without registration you have ",[22,368,369],{},"no right"," to place your packaging on that market. It is a ban, not a penalty you pay and forget.",[83,372,374],{"id":373},"and-if-i-do-nothing-what-happens","And if I do nothing, what happens?",[19,376,377],{},"Let us be honest: in the short term, on your own store, probably nothing. No alert, no block, no letter. That is exactly why most cross-border sellers never registered.",[19,379,380],{},"The problem is that nothing goes away. Here is what happens the day it catches up with you.",[19,382,383,386],{},[22,384,385],{},"The arrears, and this is the heaviest part."," The eco-contribution is owed on the packaging you put on the market, whether you declared it or not. Not declaring does not cancel the debt, it defers it. When you regularise, you will be asked to declare past years. For a shop shipping a few tonnes of cardboard a year into a country for three or four years, that is no longer a symbolic amount.",[19,388,389,392],{},[22,390,391],{},"A cease-and-desist from a competitor."," In Germany above all, where the register is public and the matter falls under competition law. You pay their legal costs and sign an undertaking to stop.",[19,394,395,398],{},[22,396,397],{},"Losing a channel."," The day you open a marketplace account or move to a fulfilment provider, they will ask for the number. You do not have it, so you do not sell, and it takes up to twelve weeks to get. That is the worst possible moment to discover the subject.",[19,400,401,404],{},[22,402,403],{},"A fine."," These already exist in countries that had their own regime beforehand, such as Germany or Spain. At EU level nothing is set yet: Member States have until 12 February 2027 to fix their penalties, and the regulation only mandates administrative fines for other obligations, not this one.",[19,406,407,410],{},[22,408,409],{},"Spain is a special case."," If you appoint nobody, Spanish law shifts the liability onto the platform hosting you, or onto the first Spanish distributor. You are not penalised directly, someone else pays in your place, and that someone will cut you off.",[19,412,413],{},"In short: this is not the risk of a one-off fine, it is a debt growing quietly that shows up at the worst possible time.",[83,415,417],{"id":416},"who-checks-you-and-who-does-not","Who checks you, and who does not",[19,419,420],{},"Two things need separating, because this is where everyone gets lost.",[19,422,423,426,427,430],{},[22,424,425],{},"The obligation"," does not depend on your sales channel. ",[22,428,429],{},"The checking"," does.",[108,432,433,446],{},[111,434,435],{},[114,436,437,440,443],{},[117,438,439],{},"Your channel",[117,441,442],{},"Bound?",[117,444,445],{},"Checked?",[127,447,448,462,475,488,502],{},[114,449,450,456,459],{},[132,451,452,455],{},[22,453,454],{},"Large marketplace"," (Amazon Seller Central, Etsy, eBay, Zalando, Fnac, Cdiscount)",[132,457,458],{},"Yes",[132,460,461],{},"Yes. No number, no listing.",[114,463,464,470,472],{},[132,465,466,469],{},[22,467,468],{},"3PL or fulfilment provider"," (Fulfilment by Amazon, your own fulfilment partner)",[132,471,458],{},[132,473,474],{},"Yes. They must suspend the service if your number is missing.",[114,476,477,483,485],{},[132,478,479,482],{},[22,480,481],{},"Small marketplace"," (maker site, sector platform, niche marketplace under fifty staff)",[132,484,458],{},[132,486,487],{},"No. Micro and small enterprises are exempt from this duty.",[114,489,490,496,499],{},[132,491,492,495],{},[22,493,494],{},"Carrier"," (Royal Mail, La Poste, CTT, DPD, GLS, DHL, UPS)",[132,497,498],{},"Not applicable",[132,500,501],{},"No. They are excluded from the text, by name.",[114,503,504,510,515],{},[132,505,506,509],{},[22,507,508],{},"Your own store"," (Shopify, WooCommerce, PrestaShop, Squarespace, Wix)",[132,511,512],{},[22,513,514],{},"Yes, just as much",[132,516,517],{},"No. Nobody stops you.",[19,519,520,523],{},[22,521,522],{},"Marketplace or shop software?"," This is the most frequent confusion. On a marketplace you sell under your own name on someone else's site, alongside other sellers. Shopify, WooCommerce and Squarespace are not marketplaces: they are software you rent to run your own shop. You are the only seller, there is no intermediary, so nobody has a duty to check you.",[19,525,526,529],{},[22,527,528],{},"If you use FBA, Amazon wears both hats at once",", marketplace and fulfilment provider. You then fall under both checks: your listings blocked and your fulfilment suspended.",[19,531,532],{},"The regulation does not rely on inspectors to police hundreds of thousands of sellers. It pushes the checking onto the large intermediaries. That is effective, and very uneven.",[19,534,535,538],{},[22,536,537],{},"The most dangerous case is your own store."," Not the safest. You are as bound as an Amazon seller, but nothing will tell you so. You can rack up years of non-compliance without knowing.",[19,540,541,542,545],{},"And you are not invisible either: national registers are ",[22,543,544],{},"public and searchable",", which the regulation requires. In Germany, where the register has been online since 2019, it is your competitors who do the policing, with cease-and-desist notices you have to pay for. It is currently the only country where a seller on their own store genuinely gets caught.",[83,547,549],{"id":548},"what-could-still-change","What could still change",[19,551,552,553,556],{},"The European Commission has proposed ",[22,554,555],{},"suspending this obligation"," as part of its simplification package. The European Parliament vote is expected in autumn 2026. It is not adopted.",[19,558,559],{},"But an EU suspension would not erase national law. Spain and France require a representative under their own texts, independently of Brussels.",[19,561,562],{},[563,564,565],"em",{},"Legal position as at 25 August 2026.",[83,567,569],{"id":568},"what-to-do-now","What to do now",[26,571,572,578,584,590,596],{},[29,573,574,577],{},[22,575,576],{},"List your real destination countries, by volume."," Not where you could sell: where you actually shipped consumer parcels over the last twelve months. Often three countries are the whole story.",[29,579,580,583],{},[22,581,582],{},"Check whether you are already in breach."," Look yourself up in each public register. In Germany it takes a minute.",[29,585,586,589],{},[22,587,588],{},"Start with Spain and France"," if you ship there. Those are the two where the obligation is clearest today.",[29,591,592,595],{},[22,593,594],{},"Allow for the lead time."," Twelve weeks is not something you sort out the night before a campaign.",[29,597,598,601,602,72],{},[22,599,600],{},"Do not confuse this with box sizes."," That is a separate subject on a separate timeline, covered in our article on ",[603,604,606],"a",{"href":605},"\u002Fen\u002Fblog\u002Fppwr-empty-space-ecommerce-parcels","empty space in ecommerce parcels",[83,608,610],{"id":609},"where-parcelrush-fits-and-where-it-does-not","Where ParcelRush fits, and where it does not",[19,612,613],{},"ParcelRush is not a representative, does not appoint one for you and does not produce your compliance. That is settled with a specialist provider in each country.",[19,615,616,617,620],{},"What the platform does is answer the first item on that list: ",[22,618,619],{},"which countries do you actually ship to, and in what volumes?"," Your shipments are centralised there across every carrier, giving you the split by destination without cross-referencing three interfaces.",[19,622,623,624,628,629,72],{},"If your question is more about choosing a carrier for those countries, we compared the options in our guide to ",[603,625,627],{"href":626},"\u002Fen\u002Fblog\u002Fcompare-european-carriers-ecommerce","European carriers",". And obligations that arise in the country of arrival sit alongside those in our guide to ",[603,630,632],{"href":631},"\u002Fen\u002Fblog\u002Feu-customs-compliance-ecommerce-shipments","EU customs compliance",[19,634,635,636],{},"👉 ",[603,637,639],{"href":638},"\u002Fen\u002Fintegrations","See the carriers available",[83,641,643],{"id":642},"sources","Sources",[19,645,646],{},"Everything cited here comes from an official text, not from second-hand coverage.",[26,648,649,659,667,675,683,692,701],{},[29,650,651,652,658],{},"European Union, ",[603,653,657],{"href":654,"rel":655},"https:\u002F\u002Feur-lex.europa.eu\u002Feli\u002Freg\u002F2025\u002F40\u002Foj",[656],"noopener","Regulation (EU) 2025\u002F40 on packaging and packaging waste",". Articles 3, 44, 45 and 71: producer definition, national register, representative obligation, application date.",[29,660,651,661,666],{},[603,662,665],{"href":663,"rel":664},"https:\u002F\u002Feur-lex.europa.eu\u002Feli\u002Fdir\u002F2008\u002F98\u002Foj",[656],"Directive 2008\u002F98\u002FEC on waste",", Article 8a(5): the old wording, where the representative was an option.",[29,668,651,669,674],{},[603,670,673],{"href":671,"rel":672},"https:\u002F\u002Feur-lex.europa.eu\u002Feli\u002Freg\u002F2019\u002F1020\u002Foj",[656],"Regulation (EU) 2019\u002F1020",", Article 3, point 11: the carrier exclusion.",[29,676,651,677,682],{},[603,678,681],{"href":679,"rel":680},"https:\u002F\u002Feur-lex.europa.eu\u002Feli\u002Freg\u002F2022\u002F2065\u002Foj",[656],"Regulation (EU) 2022\u002F2065 on digital services",", Article 29: the small marketplace exemption.",[29,684,685,686,691],{},"Spain, ",[603,687,690],{"href":688,"rel":689},"https:\u002F\u002Fwww.boe.es\u002Fbuscar\u002Fact.php?id=BOE-A-2022-22690",[656],"Real Decreto 1055\u002F2022",", Article 17(2).",[29,693,694,695,700],{},"France, ",[603,696,699],{"href":697,"rel":698},"https:\u002F\u002Fwww.legifrance.gouv.fr\u002Fcodes\u002Farticle_lc\u002FLEGIARTI000054403121",[656],"Article L. 541-10-9-1 of the Environmental Code",", created by Law 2026-602 of 8 July 2026.",[29,702,703,72],{},[603,704,707],{"href":705,"rel":706},"https:\u002F\u002Foeffentliche-register.verpackungsregister.org\u002F",[656],"German public register of packaging producers",[19,709,710],{},"One point is given with caution, for lack of an official document available at publication: the exact content of the EU suspension proposal.",[83,712,714],{"id":713},"frequently-asked-questions","Frequently asked questions",[716,717,719],"h3",{"id":718},"what-is-an-epr-authorised-representative","What is an EPR authorised representative?",[19,721,722],{},"A company established in the country you ship to, appointed by written contract, which takes on your packaging obligations: registering in the national register, reporting your tonnages, paying the eco-contribution. Same principle as a fiscal representative for VAT.",[716,724,726],{"id":725},"i-only-sell-on-my-own-store-with-no-marketplace-am-i-concerned","I only sell on my own store, with no marketplace. Am I concerned?",[19,728,729],{},"Yes, exactly as much as an Amazon seller. The sales channel changes nothing about the obligation. It only changes who checks you: a marketplace must verify your registration number before letting you sell, whereas on your own store nobody has that duty. You are equally bound, but with nothing to flag that you are in breach.",[716,731,733],{"id":732},"what-happens-if-i-sell-without-being-registered","What happens if I sell without being registered?",[19,735,736],{},"In the short term, on your own store, probably nothing: no intermediary has a duty to check you. But the eco-contribution is still owed on packaging already shipped, and you will have to declare past years when you regularise. On top of that, depending on the country: a national fine, a paid cease-and-desist from a competitor in Germany, and your account blocked the day you open a marketplace. This is not the risk of a one-off fine, it is a debt that accumulates.",[716,738,740],{"id":739},"how-many-representatives-do-i-need","How many representatives do I need?",[19,742,743],{},"One per country you ship consumer parcels to, other than the one where you are established. Shipping to Germany, Spain and Italy means three separate contracts.",[716,745,747],{"id":746},"can-my-carrier-refuse-my-parcel-if-i-am-not-registered","Can my carrier refuse my parcel if I am not registered?",[19,749,750],{},"No. Carriers are expressly excluded by the EU market surveillance regulation, which puts postal services, parcel delivery services and any other freight transport services out of scope. The duty to check sits with marketplaces and with providers who warehouse and prepare your orders, not with the company that moves them.",[716,752,754],{"id":753},"is-there-a-threshold-below-which-i-am-exempt","Is there a threshold below which I am exempt?",[19,756,757],{},"No. There is a lighter reporting regime for small volumes, below 10 tonnes of packaging per year per country, but that is relief on what you report, not a pass on registering. Registration is due from the first parcel.",{"title":759,"searchDepth":760,"depth":760,"links":761},"",3,[762,764,765,766,767,768,769,770,771,772,773,774],{"id":85,"depth":763,"text":86},2,{"id":102,"depth":763,"text":103},{"id":214,"depth":763,"text":215},{"id":264,"depth":763,"text":265},{"id":305,"depth":763,"text":306},{"id":373,"depth":763,"text":374},{"id":416,"depth":763,"text":417},{"id":548,"depth":763,"text":549},{"id":568,"depth":763,"text":569},{"id":609,"depth":763,"text":610},{"id":642,"depth":763,"text":643},{"id":713,"depth":763,"text":714,"children":775},[776,777,778,779,780,781],{"id":718,"depth":760,"text":719},{"id":725,"depth":760,"text":726},{"id":732,"depth":760,"text":733},{"id":739,"depth":760,"text":740},{"id":746,"depth":760,"text":747},{"id":753,"depth":760,"text":754},null,"Person with a clipboard checking labelled shipping boxes in a small order preparation room","2026-08-25","Selling direct into another EU country makes you a packaging producer there. Who must appoint a representative, since when, and who actually checks.",false,"md",[789,790,791,792,793,794],{"q":719,"a":722},{"q":726,"a":729},{"q":733,"a":736},{"q":740,"a":743},{"q":747,"a":750},{"q":754,"a":757},{},true,"\u002Fen\u002Fblog\u002Fepr-authorised-representative-packaging",{"title":5,"description":785},"EPR authorised representative for packaging: who needs one",[801,802,804,806,808,810,812],{"name":657,"url":654},{"name":803,"url":663},"Directive 2008\u002F98\u002FEC on waste, Article 8a",{"name":805,"url":671},"Regulation (EU) 2019\u002F1020 on market surveillance",{"name":807,"url":679},"Regulation (EU) 2022\u002F2065 on digital services (DSA)",{"name":809,"url":688},"Spain, Real Decreto 1055\u002F2022",{"name":811,"url":697},"France, Article L. 541-10-9-1 of the Environmental Code",{"name":813,"url":705},"German public register of packaging producers (LUCID)",[92,815,816,817,818,819,820,821],"authorised representative","PPWR","packaging","EU regulation","distance selling","ecommerce","marketplace","epr-authorised-representative","PYsFRbYUgPAoDx9U0CpYegxDsrw-5g0YUflKF_1R4m4",[825,827,830],{"code":826,"path":797},"en",{"code":828,"path":829},"fr","\u002Ffr\u002Fblog\u002Fmandataire-rep-emballages-ecommerce",{"code":831,"path":832},"pt","\u002Fpt\u002Fblog\u002Fmandatario-rep-embalagens-ecommerce",[834,839,843],{"stem":835,"title":836,"cover":837,"date":838,"category":6,"author":11},"en\u002Fblog\u002Fecommerce-shipping-strategy-2026","Simple and effective e-commerce shipping in 2026","\u002Fassets\u002Fblog\u002Flarge_expedition_ecommerce_simple_2026_22d4b5a464.jpg","2026-04-13",{"stem":840,"title":841,"cover":842,"date":838,"category":6,"author":11},"en\u002Fblog\u002Fbrands-loyalty-delivery-experience","The Secret Weapon of Brands That Build Loyalty: The Delivery Experience","\u002Fassets\u002Fblog\u002Flarge_improve_customer_unboxing_experience_fde9155827.jpg",{"stem":844,"title":845,"cover":846,"date":838,"category":6,"author":11},"en\u002Fblog\u002Fecommerce-shipping-trends","E-commerce Shipping Trends: The Key Logistics Levers","\u002Fassets\u002Fblog\u002Flarge_ecommerce_shipping_trends_2025_essential_insights_f293e447f0.jpg",1787681285391]