EPR registration for sellers outside the EU: packaging, electrical equipment and batteries
Extended producer responsibility (EPR) makes the business that first makes a product available in a Member State pay for collecting and treating it as waste. A seller outside the EU that sells directly to end users in a Member State is the producer there. Three EU laws set this up for packaging, electrical and electronic equipment, and batteries; each Member State runs its own register.
Checked against the sources on 10 October 2026
Checklist by product type
| You sell directly to end users in an EU country | Register as a producer there | Authorised representative there | Law |
|---|---|---|---|
| Products in packaging | Yes, before you sell (Article 44(4)) | Yes, by written mandate (Article 45(3)) | Regulation (EU) 2025/40 (PPWR), applies from 12 August 2026 |
| Batteries, or products with a battery built in or included | Yes, before you sell (Article 55) | Yes, by written mandate (Article 56(3)) | Regulation (EU) 2023/1542, these rules since 18 August 2025 |
| Electrical and electronic equipment | Yes: you are the producer in that country (Article 3(1)(f)(iv)) and must be in its register (Article 16) | For sellers outside the EU, set by national law: check that country's register. Sellers based in another EU country must appoint one (Article 17(2)) | Directive 2012/19/EU (WEEE) |
The PPWR registers come later: each Member State has 18 months from the first implementing act to set one up (Article 44(1)). Many countries already run packaging registers under national law, so check each country you sell to. Online marketplaces must collect the registration number and a self-certification before letting a producer sell packaged products to EU consumers (Article 45(4)).
If an EU importer or distributor first makes your goods available in a Member State, it is the producer there instead (PPWR Article 3; WEEE Article 3(1)(f)).