Authorized Representative for Batteries and EEE in Germany: Simplify your EPR obligations!

Foreign companies placing WEEE or batteries on the German market must comply with a series of legal obligations under the German Extended Producer Responsibility (EPR) legislation. One of the key requirements is the appointment of an Authorized Representative (AR) , who takes responsibility for fulfilling obligations relating to electrical and electronic equipment and batteries.

Request a personalized quote now to manage your EPR obligations. >>

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Understanding EPR Regulation 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 ),
2012/19/EU on waste electrical and electronic equipment (WEEE).

The German EPR regulations include, among others:

in accordance with the ElektroG law – waste electrical and electronic equipment (WEEE),
according to the BattG – batteries and accumulators.

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

registration with the competent authorities ( German Clearing House – EAR ) in order to obtain an EPR number,
periodic reporting of the quantities of WEEE and batteries placed on the German market,
organization of waste collection and management (through an EPR organization),
information requirements (adequate labelling, user instructions),
appointment of an authorized representative, if the company is not based in Germany.

What is an Authorized Representative for EPR in Germany?

An EPR Authorized Representative is a natural or legal person based in Germany who assumes the manufacturer’s obligations under the EPR regulations (ElektroG for EEE, BattG for batteries). The scope of these obligations depends primarily on the type of products sold.

Only a company based in Germany, registered with the competent authority (EAR) and in possession of a written agreement with the manufacturer for the transfer of obligations arising from the EPR regulation, can act as the manufacturer’s authorized representative.

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

The appointment of an authorised representative for the EPR in Germany is mandatory for all companies not based in Germany that place on the German market:

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

Foreign entities that sell products directly to end customers in Germany via distance selling channels (such as their own online shops or e-commerce platforms like Amazon, eBay, Zalando, etc.) must therefore necessarily have an authorized representative.

Soon also for packaging compliance

Currently, the obligation to appoint an authorized representative does not apply to companies selling packaging or packaged products on the German market. This obligation will come into force with the Packaging and Packaging Waste Regulation (PPWR) in August 2026. The PPWR will replace Directive 94/62/EC , which currently regulates EPR obligations relating to packaging.

However, companies can already voluntarily appoint an EPR Authorized Representative to ensure full compliance with the PPWR, avoid penalties, and streamline regulatory processes. Although companies must register independently with the LUCID Packaging Registry , the Authorized Representative is responsible for fulfilling all other packaging-related obligations.

Authorized EPR Representative in Germany – Get the best deal!

Are you required to appoint an authorized EPR representative in Germany? Do you want to entrust your tasks to a reliable company that will handle them with the utmost care? Sign a contract with Interzero!
As an environmental consulting firm with over 30 years of experience, we offer comprehensive professional support and free you from time-consuming and complicated tasks.

By choosing Interzero as your authorized EPR representative in Germany, you will be able to:

transfer all your responsibilities under EPR regulations to Germany,
quickly and easily obtain all the data and documents required by the main sales platforms,
save precious time for you and your collaborators,
sell your products to German customers safely and legally,
ensure that your product waste is treated in an environmentally friendly manner.

Complete a short questionnaire and receive a personalized quote for your company. >>

Sign a contract with Interzero in a few simple steps

To simplify EPR compliance for companies, we offer our customers the ability to conclude contracts quickly, conveniently, and entirely remotely, 100% online .

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

Select the product categories you sell to customers in Germany and access the form.
Fill out the online form indicating quantities and weights.
Enter your company details and confirm them.
Confirm your order and follow the instructions you will receive via email.

Not sure if EPR applies to your business? Book a free consultation with our experts via our online calendar.>>

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

For over 30 years, Interzero has provided professional environmental services to clients across all sectors. We operate in 10 countries, including Germany, where we take on the obligations arising from Extended Producer Responsibility (EPR) on behalf of entrepreneurs.

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

register your company in the relevant registers ( EAR ) and provide you with consultancy support during the LUCID registration, which according to the legislation must be carried out directly by the company,
recycling and management of waste from packaging, equipment and batteries placed on the German market,
participation in the EPR system ,
reporting on packaging, equipment and batteries placed on the market in each calendar year (note: by law, packaging reporting must be sent directly by the company),
packaging license and payment of related fees on behalf of your company (if required),
Representation of your company in relations with German authorities and offices.

Please note: Registration in the LUCID Packaging Register must be completed directly by the required companies. All other requirements can be handled by our authorized representative on your behalf.

Our experts will analyze the specifics of your business to precisely define your obligations as a manufacturer under the German EPR system. This way, we can manage all activities efficiently, comprehensively, and sustainably .

FAQ

Find answers to frequently asked questions about the Authorized Representative (EPR) service in Germany.

What does EPR mean?

EPR (Extended Producer Responsibility) is a concept whereby manufacturers are responsible for the entire life cycle of the products they place on the market, from design and production to waste management. Under EU directives, all Member States must integrate extended producer responsibility into their national legislation regarding:

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

Why is it necessary to appoint an EPR authorized representative in Germany?

The obligation to appoint an authorized EPR representative is stipulated in two German laws: the Electrical and Electronic Equipment Act ( ElektroG ) and the Battery Act ( BattG ). For packaging, the obligation is enshrined in EU law ( PPWR ) and will enter into force in all Member States by August 2026. Although the extended producer responsibility systems in the various EU Member States were developed based on the same European directives, their structure and operation differ significantly. Not only does each country organize collection differently, but local regulations are often not translated into other languages, making it difficult for foreign businesses to understand and comply with the EPR system in force in a given country. To ensure that foreign companies strictly comply with EPR regulations, each Member State can require them to appoint an authorized representative—a local entity who ensures that all producer obligations are fulfilled. In the German EPR system, this obligation currently only exists for batteries and electrical and electronic equipment, but will also become mandatory for packaging from 2026.

Who can be an Authorized Representative for EPR (packaging, batteries, WEEE) in Germany?

An EPR Authorized Representative may be a natural or legal person who meets all of the following conditions:

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

When must an authorized EPR representative be appointed in Germany?

Manufacturers intending to sell batteries or electrical and electronic equipment to German customers must appoint an authorized EPR representative before starting their business. The authorized representative’s task is to take all necessary measures to ensure the products can be legally placed on the market, including the required registrations on behalf of the manufacturer, the provision of guarantees, and participation in the extended producer responsibility system. Businesses placing packaging and packaged products on the German market can currently appoint an authorized representative at any time, both before and during their business, but no later than August 2026, when this will become mandatory under the PPWR.

Does Interzero offer authorized representative services in other countries?

Yes, we currently offer authorized representation services in 30 markets: in all 27 EU member states, as well as the United Kingdom, Norway, and Switzerland. This allows companies placing packaging and products subject to EPR regulations in multiple countries to quickly, conveniently, and comprehensively appoint an authorized representative in various European markets.