What does an EPR authorised representative cost per country?

There is no statutory price. The appointment is a contract with a service provider, and you negotiate the fee with them. It depends on the destination country, the product stream, the tasks taken over and the liability. Statutory fees for registration or confirmation are only added where the competent body charges them. Ask for the service fee and any official fees separately, and have the scope of obligations transferred confirmed in writing.

Do I need a separate representative in every EU country?

Yes, in principle for each country and product stream concerned. From 12 August 2026, the PPWR requires an EPR authorised representative for packaging in every Member State where you supply end users directly without an establishment. In electrical equipment law, representation also applies per country of destination. One and the same provider can hold several mandates, provided it meets the eligibility requirements in each country; but each appointment needs its own written mandate.

Does an establishment or warehouse in the destination country replace the representative?

A genuine establishment in the destination country removes the reason for representation in that country: under Section 8(1) ElektroG, only a producer without an establishment in Germany needs an authorised representative. A warehouse or logistics address alone is not an establishment in the legal sense and does not replace the mandate. Whether the establishment makes you a producer there yourself depends on your delivery and contractual setup and needs to be checked separately.

EPR authorised representative: cost drivers per EU country

Key takeaways

The cost of an EPR authorised representative is a negotiated price for the tasks and liability taken over, not a statutory levy.
Whether, and in what form, a representative is required depends on the destination country, the obligation area and the sales model; packaging, electrical equipment and batteries each have their own legal basis and may require separate mandates.
Which obligations the representative takes over depends on the area of law and the destination country. They can include registration, reporting and other producer obligations.
In Germany, the appointment under Section 8 ElektroG must be in writing, in German and effective for at least three months.
The European Commission has proposed suspending the authorised representative obligation for packaging and batteries; until a decision is adopted, the obligation applies unchanged.

Representation depends on destination country, obligation area and sales model

Whether, and in what form, you need an EPR authorised representative depends on the destination country, the obligation area and the sales model. Packaging, electrical equipment and batteries follow different legal bases and may require separate mandates. The fee depends on the destination country, the product stream, the scope of the mandate and the liability transferred; there is no fee schedule that sets the price per EU country. If you supply several countries and streams, you negotiate each fee separately. Many providers assign and invoice the mandates separately; that is a possible contractual and pricing practice, not a legal rule. Package offers are only comparable if they state the country, the stream and the scope of obligations.

Three obligation areas, different mandates

Packaging, electrical equipment and batteries are separate obligation areas. Each has its own legal basis, its own register and its own procedure. Whether an area needs its own mandate depends on the destination country and the sales channel. Many providers assign and invoice the mandates separately; this too is contractual practice, not a legal requirement. The packaging of an electrical appliance also triggers its own packaging obligations; it is not automatically covered by the equipment mandate.

Packaging: mandate under the Packaging and Packaging Waste Regulation (PPWR), applicable from 12 August 2026^[1]^[2].
Electrical equipment: mandate under the WEEE Directive 2012/19/EU and the national implementing laws, in Germany the ElektroG^[3].
Batteries: if you sell batteries at a distance directly to end users in another Member State, you must appoint an EPR authorised representative for that destination country. Our article on EPR obligations abroad in the EU covers the details and the current EU suspension proposal.

How it differs from other representatives

An EPR authorised representative is not the same as a customs representative or a representative for product requirements such as CE marking. Those roles have different tasks and their own costs. An offer that merely promises representation in the EU is not comparable unless it states the country and the product stream.

The fee depends on four factors: the legal trigger in the destination country, the product stream, the scope of the tasks transferred and the liability. If you misjudge the trigger, you either order an unnecessary mandate or miss a required one; both cost money before the first service fee is charged.

Legal trigger per product stream

The obligation to appoint a representative does not arise across the board. It arises when destination country, product stream and sales channel come together. One question matters most: do you supply end users in the destination country directly without being established there?

Product stream	Legal basis	Trigger	Consequence
Packaging	PPWR (Regulation (EU) 2025/40), Art. 45(3), applicable from 12 August 2026^[2]	Making packaging or packaged products available directly to end users in a Member State without being established there	Written appointment of an EPR authorised representative in the destination country; Member States may also require this for producers from third countries
Electrical equipment (EU-wide)	WEEE Directive 2012/19/EU, Art. 3(1)(f)(iv), Art. 16 and 17^[3]	Distance selling of electrical equipment directly to end users in the destination country	Treated as the producer in the destination country; the representative must be established there
Electrical equipment (sales into Germany)	ElektroG Section 8^[4]	Selling without an establishment in Germany	Exactly one authorised representative; appointment in writing, in German, effective for at least three months; notified to stiftung ear with a copy of the mandate for confirmation
Electrical equipment (German sellers in other EU countries)	ElektroG Section 8(5)^[4]	Supplying end users directly in another Member State	Appointment of a person established there as the responsible party before making equipment available

The sales channel also matters. If you deliver through an intermediary established in the destination country, you do not make the products available directly to end users yourself. Whether the obligations then lie with the intermediary or with you depends on the product stream and the specific supply chain.

For German companies shipping within the EU, Section 8(5) ElektroG applies: before first making an electrical appliance available in another Member State, you authorise a person established there^[5]. The German registrations (stiftung ear for electrical equipment, LUCID for packaging) only cover Germany; each destination country requires its own proof. Our article on EPR obligations abroad in the EU shows how obligations differ by sales setup. Packaging shipments to Austria come with their own obligations, such as appointing an authorised representative established there; our article on selling to Austria covers the details.

Fees and transferred responsibility

The price of an authorised representative does not reflect the act of appointment. It reflects ongoing work and risk: reports, register maintenance, correspondence with authorities and schemes, and the responsibility the mandate transfers.

Set-up or mandate fee: a one-off charge for taking on the mandate, checking the requirements and agreeing the list of obligations.
Ongoing service fee: a recurring charge for the agreed tasks during the term of the mandate.
Registration or authority fees: statutory fees paid to registers or competent bodies in the destination country, separate from the representative's fee.
Ongoing reporting effort: costs for quantity reports, register maintenance and correspondence with authorities and schemes.
Additional effort for extensions: further brands, product categories, range changes or new destination countries increase the agreed effort and therefore the fee.

What determines the price

Destination country and procedure: in Germany, stiftung ear confirms the appointment under Section 8(3) ElektroG^[4]. This contact with the authority is effort that the fee reflects. Depending on the regime and country, a notification without official confirmation may suffice, which makes the procedure simpler.
Product stream and quantities: each stream has its own reports. Growing quantities and changing ranges increase the checking effort.
List of obligations: the mandate must set out in writing which tasks the representative takes over and which remain with the company.
Liability and continuity: obligations from the period of appointment continue after the mandate ends. This continuing liability is a risk the representative factors into the fee.

The representative must be established in the destination country, reliable and able to act. These eligibility requirements limit the supply in each country. The availability of suitable providers in a given destination country can also affect the price level. Check whether a provider actually meets the requirements in the destination country before you appoint them.

Compare mandates on four points: a written appointment with a clear list of obligations, eligibility in the destination country, official confirmation or notification for each procedure, and continuity when the mandate ends. Under Section 8(4) ElektroG, the producer reports the end of the appointment without delay, and the appointment only ends once the authority confirms it^[4]. Obligations from the period of appointment may continue. This continuing responsibility can be taken into account when the mandate is priced.

Ask for the fee in parts: the representative's service fee for the agreed tasks, separate from any statutory fees to registers or authorities. Record the list of obligations transferred in writing. The appointment itself is backed by law: anyone who fails to appoint an authorised representative contrary to Section 8(3), first sentence, or Section 8(5) ElektroG commits an administrative offence^[6]. Our article on calculating packaging costs covers how packaging costs add up across several countries.

Outlook: what is still open

In COM(2025) 982 final of 10 December 2025, the European Commission proposed suspending the authorised representative obligations for packaging and batteries for producers established in the Union until January 2035^[7]. Until the law is amended, the current legal position applies unchanged.

On fees and transferred responsibility: clarify your role, destination country and product stream first. A general overview cannot give a final assessment of your setup, for example with own brands, imports or complex supply chains. Our EPR needs analysis checks each combination of product, role, sales channel and destination country individually. To clarify your position today, request a ClearoSystems consultation. Our experts support the implementation while the rules continue to evolve.

Frequently asked questions

What does an EPR authorised representative cost per country?: There is no statutory price. The appointment is a contract with a service provider, and you negotiate the fee with them. It depends on the destination country, the product stream, the tasks taken over and the liability. Statutory fees for registration or confirmation are only added where the competent body charges them. Ask for the service fee and any official fees separately, and have the scope of obligations transferred confirmed in writing.
Do I need a separate representative in every EU country?: Yes, in principle for each country and product stream concerned. From 12 August 2026, the PPWR requires an EPR authorised representative for packaging in every Member State where you supply end users directly without an establishment. In electrical equipment law, representation also applies per country of destination. One and the same provider can hold several mandates, provided it meets the eligibility requirements in each country; but each appointment needs its own written mandate.
Does an establishment or warehouse in the destination country replace the representative?: A genuine establishment in the destination country removes the reason for representation in that country: under Section 8(1) ElektroG, only a producer without an establishment in Germany needs an authorised representative. A warehouse or logistics address alone is not an establishment in the legal sense and does not replace the mandate. Whether the establishment makes you a producer there yourself depends on your delivery and contractual setup and needs to be checked separately.