Does a Spanish authorised representative also cover my sales to other EU countries?

Q: Does a Spanish authorised representative also cover my sales to other EU countries?

No. Under Article 3(1)(19) PPWR, the authorised representative for EPR is a person established in the Member State where you make the packaging available, appointed for that country's obligations. Selling to consumers in Germany or France needs a representative there too.

No. An authorised representative for EPR is established in, and acts for, one Member State. Each country you sell to needs its own.

By Razvan Toma · Founder · Last checked 4 October 2026 · Sources linked below

Quick answer

No. Article 3(1)(19) PPWR defines the authorised representative for extended producer responsibility as a person established in the Member State where the producer makes packaging available, designated to fulfil the producer's obligations in that Member State. A Spanish representative registers you in the Spanish RPP and nowhere else. If you also sell to consumers in Germany or France, each needs its own: see eprgermanyrep.com and eprfrancerep.com.

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Selling into Spain without a Spanish company?

Since 12 August 2026, PPWR Article 45(3) requires an authorised representative established in Spain. We are that representative, for €199 a year.

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