Which countries need an authorised representative?
Sellers have been asking for this list by name for months, and nobody has published it. Here it is — along with the answer, which is not the one people are hoping for.
Written 13 August 2026 · Prices read from 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 no exempt countries. Article 45(3) of Regulation (EU) 2025/40 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.
This is worth stating flatly, because a lot of effort is being spent looking for a shortcut that does not exist. From a German seller in July 2026, asking a trade publication:
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. So the useful question changes shape: not which countries can I skip legally, but which countries earn back what they cost. That one has a real answer, and it is different for every seller — the calculator works it out from your own 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 per country, and EPRio charges €149 a month for a single country, which is €1,788 a year. The same nominal job spans roughly €280 to €1,788. Nobody had put those side by side, so it is worth knowing the spread before you accept the first quote you are given.
| 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 |
Scheme fees are extra and depend on what you actually ship. Every provider quotes its own fee and then passes national scheme fees through separately, priced by weight and material. No public source joins the two, so if you want a genuine all-in figure for one country you have to ask that country's scheme for a quote on your own tonnage. Any page that gives you a confident total without asking what you ship has guessed.
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 you are asking the scheme directly. Article 45(5) requires member states to publish producer lists in an open format; as at August 2026 several have not done so. Spain has said it is still developing one.
Prices move. Check before you pay
Everything above was read from the providers' own public pages on the dates given. The market has repriced more than once this year, and one widely-cited rate card turned out on close reading to cover a different waste stream than people assumed. Get any quote in writing, and make sure it says whether scheme fees are included.
Or don't register anywhere
Every option on this page leaves you as the registered producer, paying per country. There is another shape: someone established in the EU buys the order from you and resells it, so they carry the registrations and you carry none.
See how it worksSources
- Regulation (EU) 2025/40, Articles 44, 45(3) and 45(5).
- Eldris published rate card, dated 1 June 2026, read 12 August 2026.
- Lizenzero (Interzero) home page, €299 per country, read 12 August 2026.
- EcoComply and EPRio published pricing, read 12 August 2026.
- LUCID public register, SYDEREP open data, BDO register — checked 12 August 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 statement that none exists.