EPR · WEEE
The WEEE authorised representative: who needs one, and what they actually do
If you sell electrical or electronic equipment into an EU country where your company has no establishment, you usually cannot register yourself. The register will not accept a foreign applicant, and the law expects you to appoint an **authorised representative** established in that country to hold the registration and carry the producer obligations on your behalf. In Germany this is not a convenience: § 8(2) ElektroG makes it mandatory for a distance seller. This guide covers who needs one, what the mandate must say, what the representative does and does not take off your hands, and why it is a different appointment from the GPSR Responsible Person you may already have.
Assuro connects to Shopify. The guidance below applies whatever platform you sell on.
Responsible Person
GPSR, product safety
- Point of contact for authorities
- Often one can cover the whole EU
- Shown on your product page
Authorised Representative
EPR, packaging and WEEE
- Handles registration and fees
- Usually one per country that requires it
- Packaging rules apply since 12 Aug 2026
Why the appointment exists at all
WEEE obligations attach to the producer, and EU law defines that role by market conduct rather than by manufacturing. Anyone who sells electrical equipment directly to consumers in a country where they are not established is a producer in that country. That creates a practical problem the registers had to solve: the obligated party is outside the jurisdiction, has no local legal presence, and cannot be pursued by the authority or held to a take-back duty.
The authorised representative is the answer. It is a company established in the country that accepts the producer's obligations in its own name, is registered in the national WEEE register, and is the party the authority deals with. It gives the register someone locally accountable, and it gives the foreign seller a lawful route to compliance that would otherwise be closed.
It is not a formality you can start after selling
In Germany the appointment has to be in place before the registration, and the registration has to be in place before the first unit is placed on the market. § 6(2) ElektroG also bars distributors from offering, online marketplaces from listing, and fulfilment providers from storing, packing or shipping the equipment of an unregistered producer. The chain around you is required to stop, which is why the practical failure is usually a delisting rather than a fine.
Do I need one?
| Your situation | Can you register yourself? | Representative required? |
|---|---|---|
| Established in the country, selling there | Yes | No |
| No establishment in the country, shipping to consumers there | No | Yes |
| Established elsewhere in the EU, shipping cross-border to consumers | No | Yes, in the destination country |
| Selling only to businesses, no establishment | No | Yes, the duty follows the equipment, not the buyer type |
| Selling through a marketplace that is the importer of record | Depends on who places it on the market | Check the contract before assuming |
The last two rows are where sellers most often get it wrong. Germany's ElektroG contains no threshold by units, weight or turnover, and it draws no line between household and commercial equipment for the purposes of registration: § 2(1) covers both, with separate equipment types for each. And a marketplace arrangement only removes your producer status if the marketplace genuinely places the goods on the market itself, which is a question about the contract and the flow of title, not about whose website took the order.
What the mandate has to contain
Germany is the most prescriptive, and its rules are a fair guide to what the others expect. § 8 ElektroG requires that:
- A producer may appoint only one authorised representative. You cannot split the role between two providers, and you cannot keep a second one in reserve.
- The mandate must be in writing and in German. An English contract, however clear, does not satisfy this.
- It must be valid for at least three months. A shorter engagement is not a valid appointment.
- The producer must notify the authority of the appointment and supply a copy of the mandate.
- The appointment takes effect only once stiftung ear confirms it through the ear-Portal, not on the day you sign.
That confirmation step is the one that catches out sellers working to a launch date. Signing a contract does not let you sell. The sequence is: appoint, notify, wait for confirmation, then register per brand and equipment type, then wait for the registration order, and only then place equipment on the market.
What the representative does, and what stays yours
The representative performs the producer duties in its own name, on your behalf. In practice that means holding the registration, filing the quantity reports, dealing with the authority, and arranging the take-back and financing obligations the law attaches to the equipment. What it does not mean is that you stop being responsible for the accuracy of what it files.
| Task | Usually the representative | Stays with you |
|---|---|---|
| Holding the registration and the WEEE number | Yes | — |
| Filing quantity reports to the authority | Yes | Supplying the quantities and their accuracy |
| Take-back scheme contract and financing guarantee | Arranged by them | Paid by you |
| Classifying products into equipment types | Advises | Yours: you know the catalogue |
| Showing the WEEE number in your offers and invoices | — | Yours, § 6(3) ElektroG |
| Batteries, packaging and GPSR obligations | Only if separately engaged | Yours by default |
The quantities are the part sellers underestimate
A representative can file only what you give it. Germany's household-equipment quantity report under § 27 is monthly, due by the 15th of the following month, and it needs weights by equipment type. Nobody can produce that from an order export alone, which is why the classification work stays with the seller no matter who files.
How it differs from a GPSR Responsible Person
These two appointments are constantly confused, and they are not interchangeable. The GPSR Responsible Person exists under product-safety law: it is an EU-established economic operator whose name and contact details must appear on or with the product, and whose job is safety documentation and cooperation with market-surveillance authorities. One Responsible Person can cover the whole EU, and their details are shopper-facing.
The WEEE authorised representative exists under waste law: it is appointed per country, it is registered with that country's WEEE register, and its job is producer registration and reporting for end-of-life equipment. Its details are not shown to shoppers. A seller shipping electricals into three EU countries typically needs one Responsible Person and three authorised representatives. Our comparison of the Responsible Person and the authorised representative goes through the distinction in more detail.
Choosing one, and what it costs
The role is a commercial service and the law fixes no price, so quotes vary widely and are hard to compare until you know what is bundled. The authority's own fees are small and public: in Germany, 9.50 EUR to grant a registration per producer, brand and equipment type, plus 32.80 EUR per registration number per started calendar quarter under the fee ordinance (ElektroGBattDGGebV). Everything above that — the representative's fee, the take-back scheme, the financing guarantee for household equipment, and the actual recycling costs — is commercial.
- Confirm you are the producer in each destination country, not just the seller
- Appoint one representative per country, in writing and in the required language
- Notify the authority and wait for its confirmation before registering
- Agree in writing who classifies products into equipment types, because that work is yours by default
- Agree how you will supply monthly and annual quantities, and in what format
- Keep the WEEE number in your product offers and invoices yourself
- Check separately whether batteries, packaging and GPSR are covered; they usually are not
How Assuro helps
Assuro connects to your Shopify store and shows, per product and per destination country, which obligations are triggered and which registrations you have on record against them, including the WEEE registration numbers your representative holds for each brand and equipment type. It keeps the reporting deadlines visible, so the quantities your representative needs are not the thing that goes missing. Assuro organises and flags. It does not act as your authorised representative, register you with any authority, or file on your behalf.
Frequently asked questions
Is a WEEE authorised representative mandatory?
For a distance seller with no establishment in the country, yes. Germany's § 8(2) ElektroG requires a producer under § 3 no. 9(d) to appoint one, and stiftung ear will not accept a registration from a foreign company without a German establishment. Other EU countries follow the same pattern with their own registers.
Can one authorised representative cover the whole EU?
No. The appointment is per country, because each WEEE register is national. A seller shipping electricals into three countries needs a representative in each. That is the opposite of the GPSR Responsible Person, where one appointment can cover the EU.
Can I appoint more than one representative in the same country?
In Germany, no. § 8 ElektroG allows a producer only one authorised representative, so you cannot split the role between providers or hold a second in reserve.
What is the difference between a WEEE authorised representative and a GPSR Responsible Person?
Different laws, different jobs. The Responsible Person is a product-safety role, EU-wide, whose contact details appear on or with the product. The authorised representative is a waste-law role, appointed per country, registered with that country's WEEE register, and not shown to shoppers. Many sellers need both.
Does the representative take over my reporting completely?
It files, but it can only file what you supply. Classifying products into equipment types and producing the quantities, including Germany's monthly household-equipment report under § 27, stays with the seller unless you have separately agreed otherwise in writing.
How long does the appointment take to become effective?
Signing the mandate is not the effective date. In Germany the producer must notify the authority with a copy of the mandate, and the appointment takes effect only when stiftung ear confirms it through the ear-Portal. Registration per brand and equipment type follows after that.
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