Which countries need an authorised representative?
The list sellers keep asking for — with the answer nobody is hoping for.
Written 13 August 2026. Prices read from the providers' own pages. Not legal advice.
The answer
All 27, except the one country you are established in. There is no list of exempt countries because there are none. Article 45(3) requires a producer not established in a member state to appoint an authorised representative there, and Article 44 attaches no minimum size, turnover or parcel count.
People keep hunting for a shortcut that does not exist. A German seller, July 2026:
I'm going to cut back and only ship to the countries where it's still possible. Is there a list? Translated from German, Onlinehändler-News comments, 15 July 2026
There is a list. It is all of them. The useful question is which countries earn back what they cost — the calculator works that out from your volumes.
What each country costs
Two providers publish prices openly. Most do not.
- Eldris — a full 27-country rate card dated 1 June 2026, in sterling, covering registration and filing.
- Lizenzero (Interzero) — €299 per country, flat, stated on their home page as covering 31 countries with representatives appointed where required.
For comparison, EcoComply publishes €1,000 a country and EPRio €149 a month (€1,788 a year). The same job spans roughly €280 to €1,788 — know the spread before you accept a quote.
| Country | Representative needed? | Eldris, packaging | Public register you can search |
|---|---|---|---|
| Austria | Yes | £535 | Partial |
| Belgium | Yes | £385 | Not verified |
| Bulgaria | Yes | £250 | Not verified |
| Croatia | Yes | £250 | Not verified |
| Cyprus | Yes | £250 | Not verified |
| Czechia | Yes | £250 | Not verified |
| Denmark | Yes | £600 | Not verified |
| Estonia | Yes | £250 | Not verified |
| Finland | Yes | £535 | Not verified |
| France | Yes | £385 | Yes — SYDEREP open data |
| Germany | Yes | £240 (£185 yr 2) | Yes — LUCID, fully searchable |
| Greece | Yes | £520 | Not verified |
| Hungary | Yes | £740 | Not verified |
| Ireland | Yes | £390 | Not verified |
| Italy | Yes | £535 | No public lookup |
| Latvia | Yes | £250 | Not verified |
| Lithuania | Yes | £250 | Not verified |
| Luxembourg | Yes | £250 | Not verified |
| Malta | Yes | £250 | Not verified |
| Netherlands | Yes | £255 | No public lookup |
| Poland | Yes | £605 | Yes — BDO register |
| Portugal | Yes | £790 | Not verified |
| Romania | Yes | £585 | Not verified |
| Slovakia | Yes | £495 | Not verified |
| Slovenia | Yes | £990 | Not verified |
| Spain | Yes | £520 | No public lookup |
| Sweden | Yes | £535 | Not verified |
Those prices buy registration and filing, not the whole bill. Each country's scheme also charges on the tonnage you ship, and nobody publishes the two halves together. For a true figure, send the scheme your tonnage and ask — better a visible gap than a made-up number.
Can I check whether I'm already registered?
In three countries, yes, free and without an account:
- Germany — the LUCID public register is searchable by name, registration number, postcode, city or brand, and is updated daily. Comfortably the best in the EU.
- France — the producer list with unique identifiers is published as open data. A dataset dump rather than a friendly lookup, but it is genuinely public.
- Poland — the BDO entity register is publicly searchable.
Everywhere else, ask the scheme directly. Article 45(5) requires member states to publish producer lists; as at August 2026 several have not.
Prices move. Check before you pay
Everything above was read from providers' own pages on the dates given, and the market has repriced more than once this year. Get quotes in writing, and check whether scheme fees are included.
Or don't register anywhere
Every option on this page leaves you the registered producer, paying per country. The other shape: someone in the EU buys each order from you and resells it, and carries the registrations. That is Frontdoor.
See how it worksSources, with what each one says
- Regulation (EU) 2025/40 — Article 45(3) requires a producer not established in a member state to appoint an authorised representative there. Article 44 attaches no threshold. Article 45(5) requires member states to publish producer lists.
- Eldris pricing, card dated 1 June 2026, read 12 August 2026 — the sterling figures in the table. Their page adds that “government, scheme and recycling fees are passed through at cost — never marked up — and itemised on your invoice”, which is the scheme-fee point above.
- Lizenzero (Interzero), read 12 August 2026 — their home page states “299 EUR service fee per country” and “0 EUR hidden costs” across “31 countries”.
- EcoComply — publishes €1,000 per country per year. EPRio — €149 a month for one country, €349 for three. Both read 12 August 2026.
- AuthoriseMe pricing — worth reading closely if you have been pointed at them. Their card covers five countries, and the German line is “Single Use Plastic (SUP)” at €99, not packaging. Several third-party pages describe them as covering all 27; their own page does not.
- LUCID public register (Germany) · SYDEREP producer list (France, open data) · BDO register (Poland). All three checked 12 August 2026 and searchable without an account.
- A 2026 study of registration across ten member states found 64 distinct registration fields, 55% of them demanded by only one country, and that national registers have no APIs and no way to verify a registration number automatically.
- The seller quoted above is from the comment thread under Onlinehändler-News, 15 July 2026.
Countries marked “not verified” are ones where we have not confirmed a public register ourselves. That is a gap in our checking, not a claim that none exists.