EPR obligations in Spain for all foreign companies

The Extended Producer Responsibility (EPR) regulations in Spain have been introduced by several legal acts: Act 7/2022 of 8 April 2022 and Royal Decrees 106/2008, 110/2015 and 1055/2022. According to these regulations, all companies that sell packaged products, electrical and electronic equipment, and batteries to Spain must fulfil a number of legal obligations.

The most important obligations of EPR in Spain include:

• obtaining a tax identification number NIF (es. Número de Identificación Fiscal or NIF),
• registration in the Register of Producers – Registro de Productores de Producto (Spanish equivalent of BDO) and obtaining an individual EPR number,
• ensuring the management of waste from packaging, WEEE equipment and batteries placed on the Spanish market,
• submitting annual reports on the types and quantities of products covered by the EPR regulations that the product producer has placed on the Spanish market,
• licensing of packaging and WEEE equipment and batteries introduced.

Foreign companies cannot carry out any of these tasks themselves – EPR regulations oblige them to establish an authorised representative in Spain to take over all extended producer responsibility obligations.

Who is obliged to appoint an authorised representative in Spain?

The obligation to appoint an authorised representative for EPR rests with companies not established in Spain that introduce the following products onto the Spanish market:

• electrical and electronic equipment (e.g. household appliances, audio and video equipment, consumer electronics, electronic toys),
• batteries and accumulators (as well as devices containing batteries or accumulators),
• products in packaging:
  • domestic (unit packs in which the product is delivered to consumers),
  • commercial (used for storage and packaging in retail and service outlets),
  • industrial (collective packaging for industry).

The EPR regulations do not only apply to companies that sell the aforementioned products through traditional distribution channels (brick-and-mortar shops, wholesalers). They also apply to companies that offer their products through their own online shops or sales platforms, e.g. Amazon, Zalando or eBay.

Importantly, Spanish EPR regulations do not provide for quantitative exemptions, which means that even companies that sell only a few such packages or products to Spain must appoint an authorised representative. Signing a contract with an entity that will take over EPR obligations in Spain is therefore a necessary condition that must be met by all companies who introduce any packaged products, batteries and accumulators, and electrical and electronic equipment to the Spanish market.

Do you already have an authorised representative in Spain? Discover what Interzero has to offer!

At Interzero, we comprehensively support companies in fulfilling their obligations arising from extended producer responsibility (EPR). We offer the authorised representative service in Spain to all companies that place packaged products, electrical and electronic equipment, and batteries on the Spanish market.

As your authorised representative in Spain, we will take care of:

• registration of your company in the Spanish Register of Producers,
• joining the extended producer responsibility system (EPRS, SCRAP),
• reporting on packaging, equipment and batteries introduced in each calendar year,
• licensing packaging and equipment and simplifiying the payments of licence fees for your company bookkeeping
• representing your company in terms of EPR obligations for the communications with the Spanish environmental authorities and offices.
• organizing the recycling and waste management of packaging, equipment and batteries that you place on the Spanish market with our service providers

Learn about our services and choose Interzero as your authorised representative in Spain!

How do I make Interzero my company’s authorised representative in Spain?

When you choose Interzero, you can complete all the formalities quickly, conveniently and 100% online.

1. Create a free account for your company on the Interzero España website (it only takes 1 minute!).
2. Enter the number and type of packaging you will be sending and calculate the cost of the service.
3. Confirm your details and proceed to finalise the order.
4. Follow the further instructions that we will send you by email.

Once the formalities are completed, we will take care of registering your company and fulfilling the other obligations arising from the EPR in Spain.

FAQ

Find answers to the most frequently asked questions about authorised representatives and EPR regulations in Spain.

EPR Obligations – Interzero Authorized representative in Spain

Who is the authorised representative of a manufacturer in Spain?

An authorised representative in Spain is a representative of a company who takes over the responsibilities of a manufacturer according to Spanish EPR regulations. If your company is not based in Spain, you can only fulfil your EPR obligations through an authorised representative!

Who is the manufacturer according to the Spanish EPR regulations?

According to the Spanish EPR regulations, a producer is any company who manufactures, sells, packages, imports or makes intra-Community deliveries of packaged products, electrical and electronic equipment or batteries to the Spanish market, including all products sold through e-commerce.

This applies to both companies based in Spain and foreign companies (based in the EU or outside the EU).

According to the Spanish regulations on extended producer responsibility, the following are also considered packaging producers:

• retailers, courier companies and online retailers that use shipping packaging to deliver the products they sell,
• companies not established in Spain that use packaging to place products on the Spanish market,
• e-commerce platforms that place products on the Spanish market in packaging from outside Spain,
• companies that package products directly at the point of sale (e.g. takeaway food),
• companies that repackage products for the Spanish market.

How do I know if I need an authorised representative in Spain?

If you place packaged products, electrical and electronic equipment or batteries on the Spanish market and are not based in Spain, you probably need to appoint an authorised representative for your company in Spain. The definition of a producer given above may help you to identify your obligations.

NOTE: Spanish EPR regulations do not provide for quantitative exemptions. EPR obligations must therefore be fulfilled by all Producers, regardless of the quantity of packaged products, equipment and batteries placed on the market.

Do you need more information about EPR obligations in Spain and other European countries?

Register without any obligations and check your EPR obligations in Spain!

All EU countries:  Create a free Licenzero account and find out about your company’s obligations!

Since when is it mandatory to appoint an authorised representative in Spain?

The obligation to appoint an authorised representative in Spain came into force on 1 January 2023. From now on, all foreign companies placing packaged products, electrical and electronic equipment or batteries on the Spanish market must fulfil their obligations as an importer through an authorised representative.

Who can be an authorised representative for EPR in Spain?

An authorised representative for your company in Spain can be a natural or legal person or organisation that fulfils all of the following conditions:

• has an address (registered office) in Spain, takes over and helps you to comply with your obligations of register one of the extended producer responsibility systems in Spain (SCRAP),
• takes over and helps you to comply with your obligations of register register of producers (Registro de Productores de Producto).

Remember that your authorised representative will fulfil your obligations and represent you before the Spanish authorities and offices! Therefore, choose only experienced, reliable authorised representatives who can guarantee the highest quality of service!

When do I have to appoint an authorised representative in Spain?

You should appoint an authorised representative for your company before starting to sell packaged products, electrical equipment or batteries on the Spanish market. If you are currently selling these products to customers in Spain and are considered a manufacturer according to the Spanish EPR regulations, you must appoint an authorised representative as soon as possible!

What are the tasks of an authorised representative in Spain?

The authorised representative of your company in Spain takes over the responsibility for fulfilling the obligations arising from the Spanish regulations on extended producer responsibility. His tasks therefore include, among others:

• registration of the company in the Register of Producers,
• ongoing monitoring of the company’s compliance with the EPR regulations in Spain,
• annual reporting of the types and quantities of packaging, equipment and batteries placed on the Spanish market,
• organisation and coordination of activities related to the management of waste from the introduced packaging, equipment and batteries (usually limited to joining a collective extended producer responsibility system – EPR),
• contact with local authorities and offices,
• licensing of the imported packaging and equipment, including the transfer of the licence fee (calculated once the limits are exceeded) to the relevant authorities.

What about foreign companies that do not appoint an authorised representative in Spain?

Any company that fails to fulfil the obligation to appoint an authorised representative in Spain may be subject to:

• financial penalties, the amount of which depends, among other things, on the number of containers, equipment and batteries introduced,
• bans on the introduction of individual products onto the Spanish market.

Does Interzero also offer the authorised representative service in other countries?

Yes, we currently provide authorised representative services in all 27 EU member states, as well as in the UK, Norway and Switzerland. This allows companies that place packaging and products subject to EPR regulations on the market in several countries to establish an authorised representative quickly, conveniently and comprehensively in the various European markets.

Discover our authorisation services for small and large companies!

Every entrepreneur who places electrical and electronic equipment on the market must perform a number of obligations provided for in the WEEE Act. Polish companies can do it on their own or through a recovery organization. Foreign companies may be required to appoint an authorized representative in Poland to perform the duties of an introducer on their behalf.

Are you obliged to appoint an authorized representative in Poland?

If your business meets the following conditions:

• is a manufacturer of electrical and electronic equipment, imports or makes intra-Community acquisition of equipment, orders equipment under its own brand,
• has its registered office outside Poland,
• sells electrical and electronic equipment to customers in Poland remotely (online store, sales platforms, telesales)…

… then you are obliged to appoint an authorized representative in Poland.

Companies that fail to comply with this obligation may be fined from PLN 10,000 to PLN 100,000.

Who can be an authorized representative of your company?

The role of an authorized representative in Poland can be performed by natural persons, legal persons and organizational units without legal personality. The only statutory condition is the need to have a registered office in Polish.

To establish an authorized representative of your company in Poland, it is necessary to conclude a written agreement with the selected entity. Once the contract is signed, the representative you have chosen will carry out your company’s duties through a recovery organization.

An authorized representative of the company in Poland can also be an organization for the recovery of electrical and electronic equipment, such as Interzero.

Interzero – an authorized representative of your company in Poland

We offer the service of an authorized representative in Poland to all entrepreneurs introducing equipment to the Polish market. As an organization for the recovery of electrical and electronic equipment, we will perform all the obligations of your company without any intermediaries. Our experts will get acquainted with the specifics of your business and determine the type and status of the introducer’s duties, and then offer you the best offer.

By concluding a contract directly with Interzero, you can be sure that your company’s statutory obligations will be fulfilled reliably, on time and comprehensively.

If you are an intra-community supplier of equipment or sell it directly to customers outside of Poland by means of distance communication, you can use our assistance in establishing an authorized representative (sometimes called an authorized representative) in other EU countries where the Interzero Group operates: Austria, Germany, Italy, Slovenia and Croatia.

Why is it worth appointing an authorized representative in Poland?

Establishing an authorized representative in Poland is not only an obligation, but also a number of benefits for your company. What? Check!

Thanks to the cooperation with Interzero:

• you will meet your company’s statutory obligation to appoint an authorized representative in Poland,
• you will be sure that all activities performed on behalf of your company are in accordance with the currently applicable regulations,
• you will avoid severe consequences resulting from improper performance or failure to comply with your company’s statutory obligations (e.g. in the form of financial penalties),
• you will provide foreign distributors of your equipment with an additional benefit in the form of exempting them from the performance of the obligations of the equipment importer.

What responsibilities do we take over as an authorized representative of your company?

As an authorized representative of your company in Poland, Interzero will take over all obligations under the Act on Waste Electrical and Electronic Equipment. These include the following duties:

• organization and financing of WEEE collection and processing,
• achieve minimum annual WEEE collection rates (from 2021 amounting to 65% of the average annual weight of equipment placed),
• achieving minimum recovery rates and preparing WEEE for reuse and recycling,
• concluding an agreement with a recycler on the terms and conditions specified in the Act,
• conducting public educational campaigns,
• annual settlement of the obligation to conduct public educational campaigns.

Remember that  the obligations of the introducer rest on all entities selling electrical and electronic equipment by means of distance communication directly to users in Poland,  regardless of the type and quantity of equipment introduced to the Polish market! Sign a contract with Interzero today – thanks to us you will free yourself from burdensome duties and gain time for what is most important for the development of your business.

Why should you choose Interzero as your company’s authorized representative in Poland?

• We are an Electrical and Electronic Equipment Recovery Organization and for many years we have been fulfilling the statutory obligations of the introducer for our customers.
• We offer competitive prices and the opportunity to take advantage of a wide range of our other environmental services in one place.
• Our experts have extensive knowledge and many years of experience, which guarantees the smooth and trouble-free fulfillment of your company’s obligations.
• We operate in many EU countries, so we can act as an intermediary in the establishment of an authorised representative in other Member States as well.

Not sure if your company should establish an authorized representative in Poland? Do you have questions about the Authorized Representative service? Or do you want to establish an authorised representative in other EU countries? Write to us! Our experts will be happy to help you and dispel all your doubts.

Go to the contact form

Authorized Representative in Poland – Frequently Asked Questions (FAQ)

Although the obligation to appoint an authorized representative in Poland has existed for a long time, many entrepreneurs still do not know about its existence. Find out the answers to the most common questions of entrepreneurs and check if this obligation also applies to your company!

What is an authorized representative?

An authorised representative is an entity with its registered office or place of residence in Polish, which is responsible for the performance of statutory obligations of manufacturers placing electrical and electronic equipment on the market in Poland. It can be a natural person, an organizational unit without legal personality or a legal person, including an organization for the recovery of electrical and electronic equipment. All statutory duties are performed by the authorised representative through the Electrical and Electronic Equipment Recovery Organisation.

The authorized representative assumes responsibilities only with respect to equipment from the manufacturer with which he has concluded a written agreement. Upon signing the contract, the authorized representative assumes responsibility for the performance of statutory duties, from which even cooperation with the recovery organization does not release him.

Who is obliged to appoint an authorized representative in Poland?

The obligation to appoint an authorized representative in Poland applies to companies that do not have their registered office in the country, but sell electrical and electronic equipment directly to Polish customers using means of distance communication (e.g. via sales platforms, their own online store, telesales). Companies that sell electrical and electronic equipment in a traditional way (brick-and-mortar stores, showrooms) may or may not establish a representative in Poland.

Since when is it mandatory to appoint an authorized representative in Poland?

The obligation to appoint an authorised representative in Poland was introduced by the Act of 11 September 2015 on waste electrical and electronic equipment, which came into force on 1 January 2016. From now on , each of the companies that has its registered office in the territory of a Member State other than the Republic of Poland and sells equipment to Polish customers by means of distance communication is obliged to appoint an authorized representative in Poland.

Who can act as an authorized representative of my company in Poland?

In accordance with the provisions of the WEEE Act, an authorized representative of a manufacturer in Poland may be a natural person, an organizational unit without legal personality or a legal person with its registered office in Polish, including an organization for the recovery of electrical and electronic equipment. It is worth remembering that each manufacturer can choose any entity that meets the above criteria as its representative, guided by, for example, the most favorable price, the scope of additional services or the fact of previous fruitful cooperation with a given company in other areas.

Who is a manufacturer within the meaning of the Act introducing the obligation to appoint an authorized representative in Poland?

According to the provisions of the Act of 11 September 2015 on waste electrical and electronic equipment, the manufacturer is not only the actual manufacturer of the equipment, but also companies that import, make intra-Community acquisitions of equipment or order equipment under their own brand.

It follows from Article 4(11) of the Act that a producer is a natural person, an organizational unit without legal personality or a legal person that has its registered office in an EU country other than Poland and:

• manufactures equipment under its own name or trade mark or places on the market under its own name or trade mark in the territory of that Member State equipment designed or manufactured for it,
• resells equipment manufactured by other entities under its own name or trademark in the territory of that Member State (except where the name or trademark of another manufacturer or marketer appears on the equipment),
• as part of its commercial activity, for a fee or free of charge, supplies equipment from another country for distribution, consumption or use for the first time on the market of the EU country in which it is established (Other than Poland),
• sells equipment within the territory of the country by means of distance communication directly to households or users other than households.

Within the meaning of Article 4(11)(d) of the Act, a manufacturer is also a natural person, an organizational unit without legal personality or a legal person who has its registered office in a country that is not a member of the EU and sells equipment in the territory of the country by means of distance communication directly to households or users other than households.

I sell equipment to Polish via an online platform. Am I obliged to appoint an authorized representative in Poland?

If your company:

• is a foreign entity,
• sells equipment directly to users by means of distance communication (including online platforms Ebay, Aliexpress, Amazon, Temu, etc.),

then you are obliged to appoint an authorized representative in Poland.

I am not obliged to appoint an authorized representative in Poland. Can I still conclude an agreement with an entity that will take over my duties?

Some foreign entities are entitled to establish an authorized representative in Poland.

If your company is based outside of Poland and:

• manufactures equipment in EU countries under its own brand,
• introduces equipment manufactured on its behalf under its own brand,
• resells equipment under its own brand,
• imports or makes an intra-Community acquisition of equipment in the territory of an EU country other than Poland…

… and this equipment goes to Polish, you have the right to appoint your authorized representative in Poland.

Such action can bring many benefits to the entrepreneur. First of all, it will make it easier for its business partners to meet the introductory obligations provided for in the Polish law. Distributors, importers and other sellers of equipment from this manufacturer will be able to avoid the need to perform numerous statutory obligations on their own – it is enough to report the quantities of equipment introduced to an authorized representative so that he or she can report, settle and ensure the collection, recovery and recycling of WEEE.

Another benefit is the improvement of the manufacturer’s image in the eyes of consumers and potential business partners. The appointment of an authorised representative in Poland can be seen as an action to increase the transparency of the manufacturer and to reduce the negative impact of its operations on the environment.

Understanding EPR regulations in Germany

The Extended Producer Responsibility (EPR) system in Germany was introduced in accordance with EU directives: 2006/66/EC on batteries and accumulators (now Regulation 2023/1542) and 2012/19/EU on waste electrical and electronic equipment (WEEE).

The German EPR regulations cover among others:

• under the ElektroG law – waste electrical and electronic equipment (WEEE),
• under the BattG law – batteries and accumulators.

Companies that place WEEE or batteries on the German market must fulfill numerous obligations to ensure proper waste management. These obligations include:

• registration with relevant authorities (German Clearing House – EAR) in order to obtain an EPR number,
• regular reporting of quantities of WEEE and batteries placed on the German market,
• organization of take-back and waste management (via an extended producer responsibility organization)
• information obligation (appropriate labeling, user guidance),
• appointment of an authorised representative, if the company is not based in Germany.

What is an authorized representative for EPR in Germany?

An authorized representative for EPR is a natural or legal person established in Germany who takes over the manufacturer’s obligations under EPR regulations (ElektroG for EEE, BattG for batteries). The scope of these obligations depends mainly on the type of products sold.

Only a company based in Germany, registered with the relevant authority ( EAR) and holding a written agreement with the manufacturer to transfer the obligations arising from the EPR regulations can act as an authorized representative of the manufacturer.

Who is required appoint an authorized representative for EPR in Germany?

The appointment of an authorized representative for EPR in Germany is mandatory for all companies that, not being based in Germany, introduce to the German market:

• batteries and rechargeable batteries,
• products containing batteries or rechargeable batteries,
• electrical and electronic equipment (EEE).

Foreign entities that sell products directly to individual customers in Germany via distance sales channels (their own online shops or sales platforms such as Amazon, eBay, Zalando, etc.) must therefore have an authorized representative.

Authorised representive – Soon also required for packaging compliance

The obligation to appoint an authorized representative does currently not apply to companies selling packaging and packaged products on the Germany market. This obligation will come into force due to the Packaging and Packaging Waste Regulation (PPWR) in August 2026. The PPWR replaces the 94/62/EC directive which currently regulates the EPR packaging obligations. However, companies can already voluntarily appoint an authorized EPR representative to ensure full compliance with the PPWR, avoid penalties, and streamline regulatory processes. While companies must register with the LUCID Packaging Register themselfs, the authorised representative fulfils all other packaging obligations.

Authorized EPR representative in Germany – choose the best offer

Are you required to appoint an authorized EPR representative in Germany? Do you want to hand over your tasks to a trustworthy company that will carry them out with the utmost care? Sign a contract with Interzero! As an environmental consulting company with over 30 years of experience, we will provide you with professional end-to-end support and relieve you of tedious duties.

Choosing Interzero as your authorized EPR representative in Germany, you will:

• transfer all your responsibilities arising from EPR regulations in Germany,
• quickly and easily obtain all the data and documents required by the largest sales platforms,
• save time for you and your employees,
• sell your products to German customers safely and legally,
• ensure the waste from your products is processed in an environmentally responsible manner.

Complete a short survey and get a quote for your company >>

Sign a contract with Interzero in a few simple steps

To simplify EPR compliance for businesses, we offer our clients the option to conclude the contract quickly, conveniently, and entirely remotely – 100% online.

To entrust us with the role of an authorized representative of your company in Germany:

Sign a contract with Interzero in a few simple steps

To simplify EPR compliance for businesses, we offer our clients the option to conclude the contract quickly, conveniently, and entirely remotely – 100% online.

To entrust us with the role of an authorized representative of your company in Germany:

1. Choose product categories you sell to customers in Germany and proceed to the form.
2. Complete the online form with quantities and weights.
3. Enter your company details and confirm that their accuracy.
4. Confirm your order and follow the instructions we send to your e-mail address.

Unsure whether EPR applies to your company? Schedule a free consultation with our experts! Book an appointment through our online calendar.

What responsibilities do we fulfil as an authorized representative in Germany?

Interzero has been providing professional environmental services to customers in every industry for over 30 years. We are present in 10 countries, including Germany, where we take over the responsibilities arising from extended producer responsibility from entrepreneurs.

As your authorized representative in Germany, we will take care of:

• registering your company in the relevant registers* (EAR) and advisory support during registration in LUCID, which, in accordance with applicable regulations, you must do yourself,
• recycling and handling waste from packaging, equipment and batteries that you place on the German market,
• participation in the extended producer responsibility system,
• reporting on packaging, equipment and batteries placed on the market in each calendar year (according to the regulations, you must submit reports on introduced packaging yourself),
• licensing of packaging and payment of license fees on behalf of your company (if necessary),
• representation of your company in dealings with German authorities and offices.

*Please note: The registration with the LUCID Packaging Register must be complete by obligated companies themselves. Other obligations can and will be handled by our authorized representative on your behalf.

Our experts will familiarize themselves with the specifics of your business to determine your exact responsibilities as a manufacturer in the German EPR system. This will allow us to carry out all tasks efficiently, comprehensively and with benefits for the environment.

FAQ

Find answers to the most frequently asked questions about the Authorized Representative for EPR in Germany service.

What is EPR?

EPR (Extended Producer Responsibility) is a concept that assumes that the manufacturer should be responsible for the entire life cycle of the products they manufacture – from design and production to the management of the waste generated. Under EU directives, all EU member states are required to incorporate extended producer responsibility into their national legislation for the following:

• packaging and packaged products,
• electrical and electronic equipment (EEE),
• batteries

What is the reason for the obligation to appoint an EPR authorized representative in Germany?

The obligation to appoint an EPR authorized representative is stipulated in two German laws: the law on electrical and electronic equipment (ElektroG) and the law on batteries (BattG). For packaging the obligation is stipulated in EU law (PPWR) and will come into force across all EU member states by August 2026.

Although the extended producer responsibility systems in individual EU member states were designed based on the same EU directives, their shape and method of operation differ significantly. Not only does each member state organize collection in a different way, but local legislation is not always translated into other languages, making it difficult for foreign entrepreneurs to follow and understand the EPR system in force in a given country.

To ensure that foreign companies strictly adhere to EPR regulations, each member state can oblige them to appoint an authorized representative – a local entity that guarantees the fulfillment of all producer obligations.

In the German EPR system, this obligation only exists for batteries and electrical and electronic equipment today but will become mandatory for packaging in 2026 as well.

Who can be an authorized representative for EPR (packaging, batteries, WEEE) in Germany?

An authorized representative for EPR can be a natural or legal person who meets all of the following conditions:

• has a residence or registered office in Germany,
• has been entered in the relevant register (LUCID for packaging, EAR for electrical and electronic equipment and for batteries),
• has concluded a (written) agreement with the foreign manufacturer to transfer the EPR obligations.

When should an authorized representative for EPR be appointed in Germany?

Manufacturers who plan to sell batteries, electrical and electronic equipment to German customers should appoint an authorized representative for EPR before starting their business. The role of the authorized representative is to take the necessary steps to ensure that the products can be legally placed on the market, including obtaining the necessary registrations on behalf of the manufacturer, providing guarantees and joining the extended producer responsibility (EPR) system.

Entrepreneurs who place packaging and packaged products on the German market can currently appoint an authorized representative at any time, both before and during the course of their business, but latest by August 2026 once the PPWR mandatorily requires it.

Does Interzero also offer the authorized representative service in other countries?

Yes, we currently provide authorized representative services in 30 markets – in all 27 EU member states as well as the UK, Norway and Switzerland. This allows companies that bring packaging and products subject to EPR regulations into multiple countries to quickly, conveniently and comprehensively establish an authorized representative in various European markets.

Get an offer for EPR compliance for WEEE and batteries in multiple countries

Get an offer for EPR compliance for packaging in multiple countries

Foreign companies, without a legal entity or registered office in Italy, placing electrical and electronic equipment (EEE) and/ or batteries on the Italian market are legally required to comply with national Extended Producer Responsibility (EPR) regulations. To fulfill these obligations, non-Italian companies must appoint an Authorized Representative based in Italy.

EPR Compliance for WEEE and Batteries in Italy

This requirement is based on Italy’s implementation of two key EU directives:

• Directive 2012/19/EU on Waste Electrical and Electronic Equipment (WEEE),
• Directive 2006/66/EC and EU Regulation 2023/1542 on Batteries and Accumulators and Waste Batteries and Accumulators.

The Authorized Representative acts on behalf of the foreign producer to ensure full compliance with Italian and EU regulations. This includes:

• Registering with the appropriate national registers,
• Submitting regular reports on quantities and types of products placed on the market,
• Ensuring proper labeling, collection, and recycling obligations are met,
• Coordinating with EPR Collective Schemes where applicable.

❗ Important: without an Authorized Representative, foreign companies cannot legally place EEE or batteries on the Italian market.

Who Needs to Appoint an Authorized Representative in Italy?

Any company without a legal entity or registered office in Italy that sells:

• Electrical or electronic devices (e.g. household appliances, IT equipment, entertainment electronics,…),
• Batteries or accumulators (either as standalone products or integrated in devices),

must appoint an Authorized Representative in Italy to ensure compliance with EPR regulations.

This includes:

• Direct sales via e-commerce (e.g. Amazon, eBay),
• Cross-border B2B shipments,
• Sales through third-party platforms or distributors.

Even minimal quantities of EEE or batteries require full compliance—there are no de minimis thresholds in Italy’s EPR legislation.

Why Choose Interzero as Your Authorized Representative in Italy?

At Interzero, we offer full-service support for companies needing to comply with Italian WEEE and battery regulations. As your Authorized Representative in Italy, we will:

• Register with the relevant national registers, such as Registro AEE (for EEE) and Registro Pile (for batteries),
• Provide the registration number for the EEE and/or batteries,
• Join an EPR Collective Scheme, acting as your contact point for all regulatory matters,
• Provide the reporting to the EPR Collective Scheme,
• Submit the annually reporting to the National Register Entity.

How to Appoint Interzero as Your Authorized Representative in Italy?

Getting started is quick and entirely online:

1. Create a free company account via our Italian portal – it takes just one minute.
2. Enter product types and estimated volumes for the Italian market.
3. Get a cost estimate and finalize your order.
4. Follow the confirmation steps sent to your email.

Once completed, we will take care of the entire compliance process for you.

Frequently Asked Questions

What is an Authorized Representative in Italy?
An Authorized Representative is a legal entity based in Italy that assumes responsibility for fulfilling the EPR obligations on behalf of a foreign producer.

What is considered a “producer” under Italian EPR law?
A producer is any company that manufactures, imports, or sells EEE or batteries on the Italian market, whether directly, via distributors, or through e-commerce—regardless of volume.

Who is required to appoint an authorized representative?

Foreign companies without a legal entity or registered office in Italy are required to appoint an Authorized Representative if they place Electrical and Electronic Equipment (EEE), batteries, or accumulators on the Italian market. This obligation applies whether the products are sold directly to end users (e.g., via online platforms) or through local distributors.

This requirement is based on Italy’s implementation of two key EU directives:

• Directive 2012/19/EU on Waste Electrical and Electronic Equipment (WEEE),
• Directive 2006/66/EC and EU Regulation 2023/1542 on Batteries and Accumulators and Waste Batteries and Accumulators.

These legislation mandates that producers not established in an EU Member State must appoint an Authorized Representative in each country where their products are marketed. In Italy, this is enforced through national legislation and overseen by the Registro Nazionale AEE (for EEE) and Registro Pile (for batteries and accumulators).

What are the responsibilities of an authorised representative under EPR?

The Authorized Representative acts on behalf of the foreign producer to ensure full compliance with Italian and EU regulations. This includes:

• Registering with the appropriate national registers,
• Submitting regular reports on quantities and types of products placed on the market,
• Ensuring proper labeling, collection, and recycling obligations are met,
• Coordinating with Collective Schemes where applicable.

Failure to comply can result in penalties and restrictions on market access.

What are the risks of non-compliance?
There are penalties if you do not comply with the obligation of designating an Authorised Representative or fail with it on purpose when required as you place your products in the Italian market. These penalties cover not only a range of monetary fines, according to the quantity and type of products placed on the market or suspension or prohibition of product sales in Italy, but also it can lead to legal and financial consequences.

What is an EPR Collective Scheme?

An Extended Producer Responsibility Collective Scheme is a non-profit organization established by product manufacturers to collectively manage their responsibility for the waste generated by the products they introduce to the market. Its primary function is to fulfill Extended Producer Responsibility (EPR) obligations by organizing, funding, and coordinating the collection, recycling, and proper disposal of waste from its members’ products.

Need help navigating EPR obligations in Italy?
Contact us today or create a free account to get started with Interzero’s Authorized Representative services for WEEE and batteries.

Planning to sell your products to customers in Slovenia but your company is not based there? Under EPR regulations, you are required to appoint an authorized representative to manage your environmental obligations. Now you can do it quickly, conveniently, and 100% online! Explore our EPR service offer in Slovenia and choose Interzero as your authorized representative.

Are you required to appoint an authorized representative for EPR in Slovenia?

Under Slovenia’s Extended Producer Responsibility (EPR) regulations, companies that market packaging and certain product categories on the Slovenian market must comply with specific environmental obligations. However, foreign entities cannot fulfill these duties directly – they must appoint a local authorized representative to act on their behalf and ensure full compliance with local regulations.

You are required to appoint an authorized EPR representative in Slovenia if all of the following apply:

• your place packaging, packaged products or electrical and electronic equipment on the Slovenian market,
• your company does not have a registered office in Slovenia,
• you sell directly to end users (individual consumers) in Slovenia through distance selling channels (e.g., online store, sales platform, etc.).

NOTE: The scale of your business doesn’t matter – whether you sell 1 or 1,000 units of packaging/packaged products or electrical equipment to Slovenia, you must establish an authorized EPR representative

Authorized representative for EPR – guarantor of EPR compliance in Slovenia

An authorized representative in Slovenia is a local legal entity that acts on behalf of your company and represents it before Slovenian authorities in all matters related to Extended Producer Responsibility (EPR). The representative takes over full responsibility for fulfilling your obligations regarding packaging and electrical and electronic equipment placed on the Slovenian market, ensuring your company’s full compliance with local EPR legislation.

Meeting EPR obligations in a timely and reliable manner positively influences how consumers perceive your brand. It strengthens your brand as an environmentally responsible business, builds trust and can encourage customers to choose your products. That’s why it’s crucial to partner with an experienced and reliable authorized representative who guarantees a high standard of service and ensures that all regulatory tasks are handled with care and diligence.

Why choose Interzero as an authorized representative for EPR in Slovenia?

To support companies operating internationally, we have launched a dedicated service as an authorized representative for EPR in Slovenia. By partnering with us, you can be certain that all your obligations will be fulfilled timely, properly and with the highest level of care.

We have been present on the Slovenian market since 2004. With over 20 years of experience, we’ve built deep local expertise and a comprehensive set of best practices to support companies across industries in waste management and environmental compliance. Our business model is unique in Slovenia — we are the only waste management company regularly audited by independent bodies and actively engaged in research and development. This allows us to provide innovative and sustainable solutions that help our clients stay compliant, reduce costs, and protect the environment.

What obligations do we assume as your authorized representative for EPR in Slovenia?

As your company’s authorized representative in Slovenia, we will handle all obligations arising from the PPWR and WEEE directives, including:

• registering your company with Slovenian authorities — ARSO (Environmental Agency), FURS (Tax Administration), and the Ministry of the Environment, Climate and Energy (MOPE),
• enrolling you in Interzero’s Extended Producer Responsibility system, which ensures compliance with collection, recycling, and reuse targets for packaging and equipment waste,
• ensuring your company’s ongoing compliance with Slovenian EPR regulations,
• submitting periodic reports on the quantities of packaging and equipment placed on the Slovenian market,
• representing your company before Slovenian government agencies and institutions,
• monitoring legal changes in EPR that may affect your company’s responsibilities or activities in Slovenia.

How to establish Interzero as an authorized representative of my company in Slovenia?

We make it quick and easy for international businesses to appoint Interzero as their authorized representative in Slovenia. The entire process is fully digital — there’s no need to travel to Slovenia, visit government offices, or even print documents. Simply sign the agreement electronically and upload it through our dedicated customer portal.

To establish Interzero as an authorized representative, follow these simple steps via the Interzero Authorization Portal:

1. Create a free company account – provide your business details and confirm your registration.
2. Estimate your contract cost – enter information about the volume of packaging and products introduced to the Slovenian market to calculate your service fee.
3. Verify the entered data – review and confirm all information.
4. Generate your contract – create and review your agreement online.
5. Sign and submit the contract – follow the provided instructions to electronically sign and send the contract to us.

Need an authorized representative in other European countries? We offer authorized representative services across all EU member states, as well as in the UK, Norway, and Switzerland. Discover our full EPR service portfolio across Europe!

Producer’s authorized representative in Slovenia – FAQ

Learn the answers to the most common questions about an authorized EPR representative in Slovenia.

Who is considered as a producer within the Slovenian EPR regulations?

According to Slovenian EPR regulations, a manufacturer is considered not only the actual producer (manufacturer) of the goods, but also any entrepreneur who first places products or packaging covered by EPR regulations on the Slovenian market. Thus, a producer is an entity that manufactures, sells (including online), packages, imports or makes an intra-Community supply of products and packaging covered by the EPR regulations.

What products are covered by Slovenia’s EPR regulations?

Slovenia’s extended producer responsibility regulations cover:

• packaging (unit, bulk, transport),
• electrical and electronic equipment (EEE),
• batteries and rechargeable batteries,
• candles,
• Single-use plastics (SUP) products and fishing gear.

Other regulated waste streams in Slovenia also cover:

• municipal waste,
• construction and demolition waste,
• hazardous waste.
• end-of-life vehicles (ELVs),
• waste oils.
• textile waste,
• agricultural waste,
• waste from mining and quarrying

Entities placing this extended producer responsibility regulated goods on the Slovenian market must fulfill their obligations under the EPR regulations.

Note: The obligation to appoint an authorized representative applies only to foreign producers placing packaging and EEE on the Slovenian market. Other categories are subject to EPR, but without the representative requirement.

What is a producer’s authorized representative?

An authorized representative is a legal entity established in Slovenia that assumes the obligations of the foreign entity(ies) under Slovenia’s Extended Producer Responsibility legislation.

Why is appointing an authorized representative in Slovenia mandatory?

This requirement stems from both EU directives and Slovenian national legislation. Key EU acts include:

• Directive 94/62 on packaging and packaging waste,
• Directive 2008/98 on waste,
• Directive 2012/19/EU on waste electrical and electronic equipment (WEEE).

Slovenian legislation includes:

• Environmental Protection Act ZVO-2,
• Decree on packaging and packaging waste (UL RS št. 54/21, 208/21, 44/22 ZVO 2, 120/22),
• Decree on Waste (UL RS št. 77/22, 113/23, 13/25),
• Decree on Waste Electrical and Electronic Equipment (UL RS št. 55/15, 47/16, 72/18, 84/18 ZIURKOE 108/20, 44/22 ZVO-2).

Having an authorized representative for EPR in Slovenia is intended to ensure that foreign entities operating in the Slovenian market properly fulfill all obligations under the Extended Producer Responsibility legislation.

When must I appoint an authorized representative for EPR in Slovenia?

You should appoint an authorized representative before placing packaging, packaged goods, or EEE on the Slovenian market. If you are already active in Slovenia but haven’t appointed one yet, you must do so immediately. Non-compliance may result in a fine of up to €4,000.

The good news? The process is 100% online – no need to send hard copies or notarized power of attorney. Visit Interzero’s Slovenian EPR portal and appoint your representative today.

What obligations will my authorized representative in Slovenia perform?

The tasks of the authorized manufacturer’s representative for EPR in Slovenia mainly include:

• registration of your business with ARSO, FURS, and the Ministry of Environment,
• regular reporting to the Ministry of Environment,
• fee calculation and payments to FURS under EPR rules,
• organization and financing of waste collection and treatment for your packaging waste and WEEE,
• compliance with minimum annual collection targets,
• fulfillment of reuse and recycling preparation targets,
• contracting with approved recyclers,
• representation before local authorities,
• ongoing EPR compliance monitoring.

My company has a subsidiary in Slovenia. Do I still need to establish an authorized representative for EPR?

Yes. Even if your company has a subsidiary in Slovenia, you must appoint an authorized representative unless that subsidiary has a registered business address and a Slovenian VAT number. Most subsidiaries don’t meet these requirements.

Who can be an authorized representative for EPR in Slovenia?

An authorized representative in Slovenia must be a legal entity established in Slovenia, holding a valid Slovenian VAT number, and must enter into a formal agreement with a foreign producer. Under this agreement, the representative assumes full responsibility for fulfilling all of the producer’s obligations under Slovenian Extended Producer Responsibility (EPR) regulations.

Given the critical nature of this role, we strongly recommend entrusting your EPR responsibilities to a proven, trusted, and experienced partner — such as Interzero. By choosing a reliable company like Interzero as your authorized representative, you gain not only compliance but also peace of mind, knowing that all your extended producer responsibility obligations in Slovenia will be fulfilled thoroughly, accurately, and on time.

Are companies introducing small amounts of packaging and equipment exempt from meeting EPR obligations in Slovenia?

No. Currently, there are no quantity-based exemptions in Slovenia. This means that manufacturers placing even small amounts of packaging, packaged products, or electrical and electronic equipment on the Slovenian market are subject to all obligations under the local Extended Producer Responsibility (EPR) legislation.

Until 2021, producers introducing less than 15 tons of packaging annually into Slovenia were exempt from many of these obligations, including the packaging fee. However, in April 2021, the regulations were amended — the quantity exemptions were abolished, and all producers were required to comply fully with EPR obligations.

If your business is not yet in compliance with these regulations, we strongly encourage you to contact Interzero’s experts as soon as possible. We will assist you in completing all necessary formalities and preparing any outstanding reports.

I sell only to other businesses (B2B). Do I still need to have an authorized EPR representative in Slovenia?

No. The obligation to have an authorized representative for EPR in Slovenia applies only to companies selling packaging, packaged products and electrical and electronic equipment directly to end-users (individual consumers) in Slovenia.

If your company operates exclusively in the B2B sector and does not sell to individual consumers in Slovenia, then the requirement to appoint an authorized representative does not apply to your operations.

What are the risks for foreign producers who fail to establish an authorized representative in Slovenia?

Foreign producers who fail to comply with the requirement to establish an authorized representative — or who implement their EPR obligations incorrectly — may face financial penalties of up to €4,000.
In addition, the Slovenian authorities may impose further enforcement measures, such as a sales ban of the producer’s goods within Slovenian territory.

To avoid these risks, make sure you’re fully compliant with EPR rules. Interzero is here to help every step of the way.

Are you seeking a reliable, trustworthy company to manage your EPR obligations in Croatia? Choose Interzero! As your authorized representative in Croatia, we will assume full responsibility for your EPR obligations, enabling you to focus on your core business activities. Explore our services and complete your registration online.

Do you have to appoint an authorized representative for EPR in Croatia?

Companies that place packaging, electrical and electronic equipment, and batteries on the Croatian market are required to comply with a range of legal obligations under the Extended Producer Responsibility (EPR) regulations in Croatia. Foreign entities cannot fulfil these obligations on their own – they must appoint an authorized EPR representative in Croatia.

If you sell the above-mentioned products and packaging to individual customers from Croatia using:

• your own online store,
• sales platforms (e.g. Zalando, eBay, Etsy),
• other distance selling channels…

…you are required to meet your EPR obligations by appointing an authorised representative.

Interzero provides professional authorized representative services to all entities that place packaging and packaged products on the Croatian market. Entrust us with your obligations and become one of our many satisfied clients.

What responsibilities will Interzero assume as your authorized representative in Croatia?

As your authorized EPR representative in Croatia, Interzero will manage all responsibilities assigned to producers under local regulations. Once you sign a contract with us, we will:

• register your company in the Croatian register of extended producer responsibility (EPRR),
• submit monthly reports on the quantities of packaging and products your company placed in the Croatian market,
• calculate and remit waste management fees on your behalf to the Croatian Fund for Environmental Protection and Energy Efficiency (FZOEU),
• represent your company before Croatian authorities in all matters concerning EPR obligations.

This ensures that your products can be sold in Croatia legally, safely, and in full compliance with all applicable regulations.

Why choose Interzero? Our expertise in EPR in Croatia and EU

Complying with EPR regulations in individual EU member states can be a significant challenge for businesses. At Interzero, we want to support every company in fulfilling these obligations, which is why we offer professional, expert and comprehensive services in the field of EPR in Croatia and 29 other countries, and act as an authorized representative, representing our clients in 30 European markets.

In Croatia, we act as a legal entity and represent:

• producers,
• importers and
• entrepreneurs conducting intra-community deliveries of packaging and products.

We make sure that your company meets all the requirements of local EPR regulations. With us, you can do business legally, safely and without legal or financial risk.

How do I appoint an authorized representative for EPR in Croatia?

To simplify compliance with Croatian EPR regulations, we have developed an online portal that enables you to quickly calculate the cost of our service and easily sign a contract. Choosing Interzero, you can take care of all the formalities in just a few minutes without leaving your home or office!

To appoint Interzero as your authorised representative:

1. Create a free company account at EPR Interzero.
2. Enter the types and quantities of packaging and products you intend to place on the market to calculate your contract cost
3. Confirm your data and generate a contract.
4. Sign the contract and upload it to your customer account at EPR Interzero.

That’s all it takes. Now you can focus on growing your business without any worries, while we take care of all your obligations in an efficient, reliable and environmentally friendly manner.

Authorized representative for EPR in Croatia – frequently asked questions (FAQ)

Find answers to the most frequently asked questions about EPR regulations in Croatia and the authorized representative for EPR in Croatia.

Who is the authorized representative?

The authorized representative for EPR in Croatia is a natural or legal person who is registered in the Croatian register of extended producer responsibility and takes over full responsibility from a foreign company for the fulfillment of EPR obligations in Croatia regarding individual product categories (packaging, products in packaging, electrical and electronic equipment, batteries).

The authorized representative is appointed by contract. Go to the website of EPR Interzero and sign a contract with us in a few simple steps!

From the moment the contract becomes valid, the authorized representative begins to perform all EPR obligations in Croatia on behalf of the foreign company. The scope of their responsibilities and the remuneration for their services depend on the type and quantity of products and packaging being brought onto the Croatian market. Create a free account for your company and calculate the cost of your contract >>

Which companies must have an authorized representative for EPR in Croatia

All companies that:

• are not based in Croatia,
• place packaging, packaged products, electrical and electronic equipment or batteries and accumulators on the Croatian market as part of their business activities,
• sell the aforementioned products to private customers (natural persons) in Croatia through distance-selling channels (phone, online shop, mail order, TV).

Operating contrary to EPR regulations can result in severe penalties!

What is the reason for the obligation to appoint an authorized representative for EPR in Croatia?

The obligation to appoint an authorized representative in Croatia is based on several national legal acts:

• packaging and packaged products – Ordinance on packaging and waste packaging, single-use plastic products and fishing gear containing plastic (OG 137/23),
• batteries and accumulators, electrical and electronic equipment – Ordinance on the management of special categories of waste in the Fund system (OG 124/23),
• general provisions – Waste management act (OG 84/21, 142/23).

The EPR regulations in Croatia and other member states have been implemented in accordance with Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008, on waste and repealing certain Directives.

Who is a producer according to the Croatian EPR regulations?

According to the definition in the Croatian EPR regulations, a producer is a legal or natural person – a craftsman, or a natural person who develops, produces, transforms, processes, sells, coveys across state lines, or imports, that is, places the products, and/or devices, and/or equipment on the Croatian market.

For example – an online platform (marketplace) that provides services for the sale and purchase of packaged products and deliver to Croatian market is also considered a producer for all producers who sell through this platform and have not fulfilled their legal obligations and did not registered in the Extended Producer Responsibility Register (hr. Registar proizvođača s proširenom odgovornošću, RPPO) by themselves.

Importantly, only those who sell products to individuals (consumers, Croatian citizens) are considered producers. If you only sell your products to Croatian companies, you are not subject to EPR obligations and do not need to appoint an authorized representative for your company in Croatia.

I sell products via a sales portal. Do I need to appoint an authorized representative in Croatia?

Yes. All producers who sell online to Croatian citizens through different online platforms should fulfil EPR obligations, incl. appointment of an authorised representative, on their own. Most of popular online platforms require from distributors submitting a confirmation of appointing an authorised representative in Croatia or providing with some EPR information (concerning ex. registration, fees) before entering partnership.

If the distributor (producer) won’t appoint an authorised representative in Croatia, then the online platform is obliged to tave over all its EPR responsibilities in Croatia.

Does Interzero also offer the EPR authorized representative service in other countries?

Yes. We currently provide authorized representative services in all 27 EU member states, as well as in the UK, Norway and Switzerland. We fulfill the obligations on behalf of EU and non-EU companies.

Thanks to our comprehensive EPR services, companies placing packaging on the market can quickly and conveniently appoint an authorized representative in various European countries in one place.

Check your responsibilities in other countries >>