AUTHORISEME
FAQ

Questions producers ask before they book

EPR is implemented nationally, so few answers are the same in every country. These are the questions our customers ask most often — with the general orientation we can give.

Do I need this?

When an Authorised Representative is required, and what quantity has to do with it.

Do I need an Authorised Representative in every country where I sell?

In general, an Authorised Representative may be required if your company places products or packaging on the market in an EU country where it does not have an establishment. This is particularly relevant for cross-border distance sales, for example through your own online shop or marketplaces.

As a simplified general orientation, B2C sales to end users in a country where the producer has no establishment generally fall within the scenarios in which an Authorised Representative is required. The same can apply to sales to commercial end users, although individual EU countries may implement this differently. For transport packaging or B2B sales to resellers, an Authorised Representative is generally not required, but national deviations can apply.

The decisive factors are therefore not only where your company is established, but also who receives the products, how they are distributed and who places the relevant packaging on the destination market.

An Authorised Representative is also only one part of EPR compliance. It does not automatically replace registration, participation in a Producer Responsibility Organisation (PRO), licensing or reporting requirements.

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Do I need an Authorised Representative if I only sell very small quantities?

Very small sales volumes do not automatically mean that an Authorised Representative is unnecessary. The relevant setup depends primarily on the sales model, the country in which the products are placed on the market and whether the producer has an establishment there.

As a simplified general orientation, direct sales to end users in a country where the producer has no establishment generally fall within the scenarios in which an Authorised Representative is required. National implementation can differ, so low quantities should not be used on their own to determine whether the requirement applies.

AuthoriseMe therefore treats quantity as only one part of the overall setup.

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Does appointing an Authorised Representative replace my other EPR obligations?

No. The appointment of an Authorised Representative is one part of the overall EPR setup and does not automatically replace the producer's other obligations.

Depending on the country and EPR stream, you may still need an EPR registration, participation in a Producer Responsibility Organisation (PRO), licensing of the relevant quantities and periodic reporting. The Authorised Representative fulfils the role assigned to it under the applicable national framework, but the surrounding EPR obligations remain relevant.

AuthoriseMe supports with the AR appointment, relevant registrations, communication with authorities and authority reporting within the scope of the agreed service. Where possible and required, we also arrange the initial PRO setup. Ongoing reporting directly to the PRO is currently not included in the standard service and remains the customer's responsibility.

The exact combination of requirements remains country-specific.

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What is the difference between EPR registration, a Producer Responsibility Organisation (PRO) and an Authorised Representative?

EPR registration, participation in a Producer Responsibility Organisation (PRO) and the appointment of an Authorised Representative are three separate elements of EPR compliance and should not be confused with one another.

The EPR registration records the producer in the relevant national register and usually results in a registration or EPR number. A Producer Responsibility Organisation (PRO) organises the producer-responsibility system in the respective country and normally charges licensing fees based on the type and quantity of products or packaging placed on the market.

An Authorised Representative acts locally on behalf of a foreign producer where national rules require one. The AR assumes the role defined by the applicable national EPR framework, but the appointment does not automatically replace the underlying registration, PRO participation, licensing or reporting obligations.

Depending on the country, all three elements may therefore be required at the same time. AuthoriseMe supports with the relevant registrations, the AR appointment and, where possible and required, the setup with the relevant PRO.

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Are there exemptions for small businesses or very low quantities?

Very small sales or packaging volumes do not automatically mean that EPR requirements do not apply. As a general regulatory orientation from 12 August 2026, low quantities should not be treated as a general exemption from EPR registration. Depending on the country, EPR stream and specific setup, registration and other EPR steps may therefore still be relevant even for businesses with only a few shipments or very low packaging weights.

Small quantities can still affect the applicable service or fee category and may influence PRO licensing fees, reporting frequency or the amount of data that needs to be submitted. The exact setup remains country-specific.

There is currently no additional special microbusiness tariff below the smallest AuthoriseMe category.

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Service and price

What our fees cover — and which external costs come on top.

What is included in the AuthoriseMe service?

The AuthoriseMe service consists of two main components: the annual Service Fee and the annual Authorised Representative Fee.

The Service Fee covers the ongoing administrative work related to the EPR setup and management. This can include customer support, coordination, registrations, communication with competent authorities, reporting to the relevant authorities and, where possible and required, arranging the setup with the relevant Producer Responsibility Organisation (PRO).

The separate Authorised Representative Fee covers our role, responsibility and associated liability as your local Authorised Representative in the relevant country.

Please note that some activities are not included in the standard service. In particular, ongoing reporting directly to the PRO is currently the customer's responsibility. External costs such as PRO licensing fees, authority fees, notarisation or apostille costs and, where required, verification or audit costs are also charged separately.

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How much does the AuthoriseMe service cost and which additional costs may apply?

AuthoriseMe charges an annual Service Fee and an annual Authorised Representative Fee. The Service Fee covers the administrative work related to the EPR setup and ongoing management, while the Authorised Representative Fee covers our role and responsibility as your local representative.

In addition, external costs may apply depending on the country and EPR setup. These can include PRO licensing fees, authority or registration fees, notarisation or apostille costs and, where required, auditor or verification costs. These external costs are not included in the AuthoriseMe fees.

The level of PRO licensing fees depends on the respective country, PRO, material and quantities placed on the market. Individual calculations or estimates of PRO licensing fees based on customer quantities are not part of our standard service. Where available, the relevant PROs publish their tariffs and price lists online.

See our current prices

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What is the difference between the Service Fee and the Authorised Representative Fee?

The two fees cover different parts of the AuthoriseMe service and are both annual fees.

The Service Fee covers the administrative work connected with the EPR setup and ongoing management. This can include customer support, coordination, registrations, communication with competent authorities, reporting to the relevant authorities and, where possible and required, arranging the setup with the relevant Producer Responsibility Organisation (PRO).

The Authorised Representative Fee is separate and covers our legal role, responsibility and associated liability as your local Authorised Representative in the relevant country. Depending on the country and service, the applicable category may depend on the relevant size or risk classification.

External costs such as PRO licensing fees, authority fees, notarisation or apostille costs and required verification costs are not included in either fee unless explicitly stated otherwise.

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Are PRO licensing fees included in the AuthoriseMe price?

No. PRO licensing fees are external costs and are generally separate from the AuthoriseMe Service Fee and Authorised Representative Fee.

The level of these fees depends on the country, the relevant Producer Responsibility Organisation (PRO), the materials or product category and the quantities placed on the market. In some countries, minimum fees or other country-specific charges may also apply.

Individual calculations or estimates of PRO licensing fees based on customer quantities are not part of our standard service. Where available, the respective PROs publish their current tariffs and price lists online. During onboarding, we inform you which PRO setup is relevant for the service you have booked.

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Do you calculate or estimate my PRO licensing fees?

No. Individual calculations or estimates of PRO licensing fees based on customer quantities are not part of our standard service. Calculating these fees across several countries can be complex because the applicable tariff depends on the relevant PRO, material categories, quantities and country-specific rules.

The AuthoriseMe fees shown on our pricing page therefore do not represent all possible external EPR costs. PRO licensing fees, authority fees and other third-party costs may apply in addition to our Service Fee and Authorised Representative Fee.

Where the relevant PRO publishes its tariff or price list online, customers can use this information to determine the applicable licensing costs. During onboarding, we will inform you which PRO setup is relevant for the countries you have booked, but we do not provide individual fee calculations as part of the standard service.

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Getting started

What happens after booking, which documents we need and how long it takes.

What happens after I book the service?

After booking, the relevant AuthoriseMe fees must be paid and the required documents must be provided. A Power of Attorney (PoA) is required when AuthoriseMe is appointed as the Authorised Representative. The formal requirements depend on the respective country. In some countries, additional formalities such as notarisation and/or an apostille may be required; the applicable requirements are shown during the application process in the AuthoriseMe portal.

Once payment and the required documentation are available, we review the relevant country setup and contact you with the next steps. Where a registration or PRO setup is required and can already be carried out, we coordinate the process accordingly.

If a national Authorised Representative procedure is still being implemented, your booking remains recorded and you are included in our ongoing process. As soon as the relevant register, PRO procedure or national framework becomes available, we contact you and request any additional information or documents needed.

You therefore do not need to restart the booking process later simply because a country is still finalising its implementation.

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How long does the registration process take?

A registration typically takes around one to three months, but the actual timing depends on several factors. These include the country, the responsible authority, the completeness of the documentation, the required PRO setup and whether the relevant national register or Authorised Representative process is already fully operational.

Some registrations can therefore be completed more quickly, while others may take longer. In countries where the new AR procedure is still being implemented, a fixed completion date may not yet be possible.

Once we have the required documents and can start the process, we will guide you through the next steps. If the process depends on a national register or authority that is not yet operational, we will keep the booking in our process and inform you when implementation moves forward.

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When will I receive my EPR registration number?

The registration number is issued by the competent authority or national register once the relevant registration process has been completed. AuthoriseMe cannot issue the number itself.

As a general indication, registrations often take around one to three months, but the actual timeline depends on the country, authority, completeness of the documents and whether any additional PRO or Authorised Representative steps are required. In countries where new AR procedures are still being implemented, the process can take longer.

Once the competent authority or register has issued the registration number, we communicate it to you as part of the onboarding process. A pending application should not be treated as equivalent to an already issued registration number.

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Which documents do you need from me?

The exact documentation depends on the country and EPR stream, but we generally need the information required to identify your company and understand the existing EPR setup. This can include company details, existing EPR registration numbers, information on existing PRO agreements and relevant product or packaging information.

A Power of Attorney (PoA) is always required when AuthoriseMe is appointed as your Authorised Representative. Depending on the country, the PoA may need to be notarised and, where required, provided with an apostille.

If you already have registrations or PRO contracts in place, please provide the corresponding evidence during onboarding. We take existing setups into account and do not automatically replace them.

We will let you know during the onboarding process if additional country-specific documentation is required.

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What information do I need to provide about my products or packaging?

The information required depends on the country, EPR stream and specific registration or reporting process. We therefore do not ask every customer for the same set of quantity or material data at the beginning.

For packaging, relevant information can include the types of packaging used, the applicable materials and, where required for a specific process, the quantities placed on the market. For other EPR streams such as WEEE or batteries, additional product-specific information may be required.

During onboarding, we request the information that is actually needed for the relevant country and service. Existing registrations, PRO agreements and available product or packaging documentation should also be provided where applicable. This helps avoid unnecessary duplicate work and ensures that the process is based on the customer's existing setup.

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Registration and existing setup

Who registers, and what happens to registrations and PRO contracts you already have.

Do I need to register myself in the national EPR register?

No. Not every country follows the same process as Germany's LUCID register. In many countries, AuthoriseMe can carry out or coordinate the required registration on your behalf as Authorised Representative once the applicable national process is available.

Germany and Denmark are key examples where certain producer registrations must be completed directly by the producer itself. In other countries, the registration can often be handled through the Authorised Representative or as part of the local EPR setup.

This means you should not automatically create accounts or registrations in every national register before onboarding. We will inform you if a specific action has to be completed directly by your company.

Where a country's registration or AR process is still being implemented, we will contact you as soon as the relevant procedure becomes available.

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Do I need to register myself, or does AuthoriseMe register me?

The registration process is not the same in every country. Many customers are familiar with Germany's LUCID register and assume that they must personally create and complete a separate registration in every country. That is generally not the case.

Where the national framework allows it, AuthoriseMe can carry out or coordinate the required registration as part of our role as Authorised Representative. We will let you know which steps, if any, must still be completed directly by your company.

Germany and Denmark are important examples where certain registration steps must be carried out by the producer itself. For other countries, the process depends on the national register and current implementation. You should therefore not create registrations in multiple national systems on your own unless this is specifically required for your setup.

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I already have an EPR registration or PRO contract. Do I need to start again?

Usually not. Existing EPR registrations and PRO agreements are taken into account and generally do not need to be replaced solely because an Authorised Representative is appointed, provided the existing setup can continue to be used under the applicable national rules.

For example, if you already have a valid PRO agreement, the licensing arrangement can often remain in place while AuthoriseMe handles the Authorised Representative and registration-related elements. We will usually ask you to provide evidence of the existing registration or PRO participation so that duplicate registrations or licensing can be avoided where possible.

However, several countries are still implementing the Authorised Representative requirements or adapting their national legislation and administrative procedures. The required setup may therefore change. In some countries, it may become necessary to establish a new PRO agreement in which AuthoriseMe is reflected as the Authorised Representative or otherwise integrated into the compliance setup.

If such a change is required for your country, we will inform you and explain the necessary next steps. The same applies to existing registration numbers: depending on the country, they may remain valid, need to be updated or, in some cases, need to be replaced as part of the Authorised Representative setup.

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Can I keep my existing PRO or system participation agreement after appointing AuthoriseMe?

In many cases, an existing Producer Responsibility Organisation (PRO) or system participation agreement can remain in place after AuthoriseMe is appointed as your Authorised Representative. Appointing an Authorised Representative does not automatically mean that an existing licensing agreement must be cancelled or replaced.

Where the existing setup can continue to be used under the applicable national rules, we work with that setup rather than creating a duplicate arrangement. This is important to avoid duplicate licensing or unnecessary additional fees.

However, several countries are still implementing the Authorised Representative requirements or adapting their national legislation, registers and PRO procedures. In some countries, the final setup may therefore require a new or amended PRO agreement in which AuthoriseMe is reflected as the Authorised Representative.

If this becomes necessary for your country, we will inform you and explain the required next steps. Please do not cancel an existing PRO agreement before the country-specific setup has been confirmed.

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I already have an EPR registration number. Will I need a new one when I appoint an Authorised Representative?

Not necessarily. Whether an existing EPR registration number can remain in place after an Authorised Representative is appointed depends on the country and the way the national register links the producer and the representative.

In some countries, the existing registration can continue and only the representative information needs to be added or updated. In other countries, appointing or changing an Authorised Representative can affect the registration and may result in a new registration number.

Because several countries are still implementing the new Authorised Representative requirements, these procedures can also evolve as national legislation, registers and PRO processes are finalised. If your existing registration needs to be amended or replaced, we will inform you and explain the required next steps.

For this reason, please do not cancel an existing registration or create a new one before the country-specific process has been confirmed.

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Reporting

Which reports we file and which stay with you.

Who submits the EPR reports?

Reporting responsibilities depend on whether the report is submitted to an authority or directly to a Producer Responsibility Organisation (PRO).

Reporting to the relevant authorities on behalf of the producer is included in our standard service. Before the applicable reporting deadline, we contact you and request the data needed for the submission. Reporting frequency can vary by country and may be monthly, quarterly or annual.

Ongoing reporting directly to the PRO is currently not included in our standard service. The customer is responsible for submitting the required data directly to the relevant PRO.

As part of our standard service, we also do not review or validate Excel, CSV or other reporting files prepared by the customer. Separate support for preparing or reviewing reporting data can be offered as an additional service.

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Does AuthoriseMe handle reporting to the Producer Responsibility Organisation (PRO)?

AuthoriseMe handles reporting to the relevant authorities where this is part of the agreed service. Before the relevant authority reporting deadlines, we contact customers and request the data needed for the submission.

Reporting directly to the respective Producer Responsibility Organisation (PRO) is currently not included in our standard service. The customer remains responsible for submitting the required quantity data directly to the PRO in accordance with the applicable reporting frequency.

We are working on solutions that will make the submission of reporting data through the AuthoriseMe platform easier in the future. If you require additional support with the preparation or review of reporting data, this may be available as a separate service subject to additional fees.

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Countries and implementation status

Where the national procedure is ready, where it is still being built, and what applies in individual markets.

What happens if the Authorised Representative process is not yet implemented in a country?

If the national Authorised Representative process is still being implemented, this does not necessarily mean that your booking has to be cancelled or restarted later. Where the service is already offered, your booking can remain recorded and you are included in our ongoing implementation process.

The outstanding point can vary by country. For example, the technical function in the national register may not yet be available, the relevant PROs may still be defining their process, or the national legislation may not yet have been finalised.

As soon as the relevant national procedure becomes available, we contact customers who have already booked and explain the next steps. We may then request additional information or documents required for the registration or appointment.

We do not provide a legal clearance on whether a customer may start or continue selling while a national procedure is still pending; this depends on the customer's individual situation and the applicable national rules.

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Can I book the service if the Authorised Representative process is not yet fully implemented in a country?

Yes, where the service is already available for booking, you can book it even if the practical national procedure has not yet been fully implemented. This is currently relevant in several countries where registers, PROs or national authorities are still finalising the technical or legal process for appointing an Authorised Representative.

Your booking is recorded by AuthoriseMe and you are included in our ongoing implementation process. As soon as the relevant national procedure becomes available, we contact you with the next steps and request any additional information or documents that may be required.

This means you do not need to restart the booking process later. However, the booking itself should not be understood as confirmation that a formal appointment or registration has already been completed where the national procedure is not yet available.

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Can AuthoriseMe support several EU countries under one account?

Yes. AuthoriseMe is designed to support companies that have EPR obligations in multiple European markets. You can use the platform to book and manage services for several countries rather than setting up a completely separate relationship for each market.

The actual EPR setup remains country-specific. Registration requirements, Authorised Representative rules, PRO arrangements, reporting frequencies and external costs can differ from one country to another. We therefore coordinate the relevant process for each booked country based on the applicable national framework.

Some countries already have fully operational AR procedures, while others are still implementing the required registers, PRO processes or national legislation. Where a booked country is still in implementation, your booking remains recorded and we contact you as soon as the relevant process can be started.

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What is the current status of the Authorised Representative requirement for packaging in Italy?

The practical implementation of the packaging Authorised Representative function in Italy is not yet fully operational. At the same time, producers selling packaged products directly to end users in Italy may already have a registration obligation, and CONAI currently requires an Italian service address for the registration process. This service address is not yet part of our current AuthoriseMe setup. We are clarifying the requirements and will inform customers who have already booked the Italy service as soon as the process can move forward. We cannot provide a legal clearance on whether or when a specific customer may start selling in Italy.

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Can AuthoriseMe support me in all EU countries?

AuthoriseMe supports EPR and Authorised Representative services across multiple EU markets. However, EPR and AR requirements are implemented nationally, so the practical process is not identical in every country.

In some countries, the Authorised Representative process and national register are already operational. In others, technical register functions, PRO procedures or the national legal framework are still being implemented. Service availability can therefore differ depending on the country and EPR stream.

Where a service is available for booking but the national procedure is not yet fully operational, your booking can remain recorded and we will inform you once the relevant process can start.

For this reason, we do not treat the EU as one single registration. Each country and EPR stream has to be handled according to its own national setup.

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What do I need for packaging EPR in Austria?

For Austria, you generally need an Authorised Representative, participation in an Austrian Producer Responsibility Organisation (PRO) and the required Power of Attorney. If you use Reclay Systems Austria, a flat-rate PRO contract for packaging quantities up to and including 1,500 kg costs EUR 150 per year and is separate from AuthoriseMe fees. For onboarding, we require proof of the PRO contract, the paid AuthoriseMe invoice and the notarised Power of Attorney.

Conclude the PRO contract at Circular Pro

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Do I need a Spanish NIF for packaging EPR?

Yes. A Spanish NIF is required before the Spanish EPR registration process can be completed. AuthoriseMe does not currently provide the NIF application directly. Once the NIF is available, the Spanish EPR and Authorised Representative process can continue with AuthoriseMe.

Apply for the NIF through Circular Pro

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Which packaging PROs apply in Belgium and the Netherlands?

For Belgium, Fost Plus is the relevant PRO for household packaging and Valipac for commercial packaging. In the Netherlands, Verpact is the relevant PRO. The organisations publish their tariffs and price lists online. PRO and licensing costs are separate from AuthoriseMe fees.

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These answers give general orientation on EPR and Authorised Representative requirements. They are not a binding legal assessment of an individual business model. National implementation and individual supply chains differ; the setup that applies to you is confirmed during onboarding.

Still unsure how your setup is judged?

Tell us where you sell and what you ship. We will tell you which countries and streams are relevant for you.