WEEE registration across the EU, country by country

Why there is no EU-wide WEEE number

The architecture is in Article 16 of Directive 2012/19/EU: member states "shall draw up a register of producers, including producers supplying EEE by means of distance communication", and producers or their authorised representatives file into it electronically. The registers are national by design. The directive asks them to be interoperable — national registers should link to each other to make cross-border registration easier — but interoperability is not mutual recognition, and after fourteen years there is still no single portal, no single number and no passporting of one country's registration into another's market.

That matters because the trigger is placing equipment on the market of a given member state, not selling into the EU in general. Ship a lamp to a French consumer and you are a producer in France; ship the same lamp to Italy and you are a producer in Italy, under a different statute, with a different register, a different number format and a different report due on a different date. Nothing you did in France counts. The commonest expensive mistake in this whole area is treating the first registration you obtained — usually the German one, because Germany enforces hardest — as an EU-wide licence.

The second structural point is that "producer" in WEEE law is not the factory. Under Article 3(1)(f) it is whoever first places the equipment on that national market under their own name or brand, resells under their own brand, imports into that member state, or — point (iv) — sells by distance communication directly to users in a member state while being established in another member state or in a third country. That last limb is why marketplace and webshop sellers are producers in every destination country even though they manufacture nothing. If you import into your own country and then wholesale onwards, your customer is not the producer in their market for those goods; you are, in the country of import.

One consequence that catches lean operations: the duty attaches per country from the first unit, not above a turnover or tonnage threshold. There is no de minimis in the directive. A handful of member states operate simplified or reduced-fee regimes for very small producers, and the compliance scheme fee obviously scales with volume, but the registration duty itself does not wait until you are big.

The authorised representative, and where it is not optional

Article 17 has two paragraphs that get conflated. Paragraph 1 is permissive: each member state "shall ensure that a producer as defined in Article 3(1)(f)(i) to (iii) established in another Member State is allowed... to appoint a legal or natural person established on its territory as the authorised representative". Paragraph 2 is mandatory and points the other way: each member state must ensure that a distance seller established on its territory that sells into a member state where it is not established "appoints an authorised representative in that Member State". Paragraph 3 is one line and is the one people forget: "Appointment of an authorised representative shall be by written mandate." An email confirmation and an invoice are not a mandate.

For a producer established outside the EU altogether, the directive says less than sellers expect, and national law fills the gap — which is why the answer is per country. Denmark is the cleanest illustration of how hard the gate can be: a business without a Danish CVR number selling directly to end users can only establish a registration in the Danish producer register if it simultaneously requests a Danish authorised representative, who then confirms and assumes the responsibility, and the registration is held under the representative's CVR number. Finland works the same way in substance — a foreign producer selling directly to Finnish users can discharge producer responsibility only through a representative domiciled in Finland. Austria writes it into the EAG-Verordnung: § 21a requires foreign distance sellers to appoint a Bevollmächtigter who is established in Austria and has a domestic delivery address.

What you are buying is liability transfer, not paperwork. The representative is the person answerable to that state's authority for your obligations, which is why representatives underwrite the mandate, ask for volume data they can defend, and charge accordingly. It also means one representative per country: a mandate for Poland does nothing in Portugal. Two useful exceptions to the cost picture — in Belgium the national scheme Recupel offers to act as the authorised representative for foreign distance sellers at no charge for its members, and in several countries the compliance scheme you must join anyway will take the representative role as part of its service. Ask before you contract a separate provider.

What it actually costs: state fees versus the fees that matter

Two different bills arrive and they are frequently confused. The first is the state or register fee, which is small and sometimes zero: €46 in Italy for 2026 (€30 secretarial fee plus €16 stamp duty), about €200 a year in the Netherlands, SEK 1,000 a year in Sweden as the supervision fee, 200 zł for a micro-enterprise or 800 zł otherwise in Poland (payable again annually, by the end of February, in the years after registration), a turnover-tiered €100 to €600 plus VAT in Ireland, nothing at all in Spain, where the RII-AEE is expressly free. Germany is the outlier in structure rather than size: €9.50 net per brand and equipment type, plus a €32.80 net quarterly register fee.

The second bill is the one that scales: the compliance-scheme or eco-contribution charge, invoiced per unit or per kilogram of equipment placed on that national market, plus — in Germany, for consumer equipment — an annual insolvency-proof guarantee. These are set by the scheme, not the state, and they differ by product category by an order of magnitude: a lamp, a laptop and a fridge are not the same money. Anyone quoting you a flat annual figure for "EU WEEE compliance" is quoting the administrative layer only.

The third cost is the representative, roughly €300 to €800 a year per country at market rates for a non-EU seller, less when your scheme includes it, zero in the Belgian case above. Budget honestly per country rather than in aggregate: for a small seller entering one mid-sized market the realistic first-year number is a few hundred euros of fees plus the representative, before any per-kilogram charge on real volumes. The German first-year total, all in and before recycling costs, ran to roughly €800 to €1,500 for a non-EU seller when we last checked it in 2026-07 — a useful upper anchor, because Germany is the most demanding of the large markets.

How marketplaces enforce it: per country, not once

Marketplace enforcement is the reason this stopped being a theoretical duty. Amazon collects an EPR registration number per country and per waste stream and blocks or restricts listings without one; in France and Spain the alternative to uploading a valid number is being enrolled into a chargeable "pay on behalf" service where the platform declares for you and bills you. There is no field for a single European number, because there is no single European number — the WEEE identifier you paste for Germany is rejected as invalid for Italy.

The platforms are not being officious. France's AGEC framework requires marketplaces to verify that third-party sellers hold the unique identifier (IDU) for each relevant scheme and makes the platform itself the producer for quantities sold on behalf of sellers unless it holds proof that those sellers have complied. Belgium went the same way with effect from 29 March 2025: online marketplace operators must check that sellers meet their EPR obligations or assume those obligations themselves, including paying the Recupel contributions on the appliances sold through the platform. When the platform's own liability turns on your number, the number becomes a condition of listing.

Plan for the check to land before you have the number. Registrations are not instant — the German process runs weeks, and any country where a representative mandate has to be signed and confirmed adds its own lead time — while a marketplace compliance sweep lands overnight. Register before you switch a country on, not after the suspension email.

You already have a German WEEE-Reg.-Nr. — what it buys you

It buys you Germany, and a template. It does not make you compliant in Italy, France or Spain, it is not accepted in any other national register, and it will be rejected by marketplace compliance forms for those countries. The German number's format, its brand-and-category structure and its guarantee requirement are specific to the ElektroG; other member states register different things — Italy registers the producer at the Chamber of Commerce, France issues a per-scheme unique identifier through ADEME, Spain records you in an industrial register run by the ministry.

What does transfer is the underlying work product, and that is worth more than it sounds. The equipment-category mapping across the six WEEE categories, the brand list, the per-SKU weights and the placed-on-market data set you built for stiftung EAR are the same inputs every other register wants. The second registration takes a fraction of the time of the first for exactly that reason. If Germany is where you are starting and the German mechanics — stiftung EAR itself, the authorised representative confirmation, the insolvency-proof guarantee for consumer equipment — are what you actually need, that is a separate guide and it is linked below; this page deliberately does not repeat it.

Batteries and packaging: the same map, twice more

WEEE is one of three per-country registers most electricals sellers owe, and the other two are moving right now. Batteries: Regulation (EU) 2023/1542 replaced the old directive and its extended-producer-responsibility regime applies from 18 August 2025, with producers required to register in each member state where they first make a battery available and to appoint a representative where they are not established. A device with a battery inside it — which is most consumer electronics — is a battery producer as well as an EEE producer, in every one of those countries.

Packaging: the PPWR, Regulation (EU) 2025/40, applies from 12 August 2026. Article 44 requires a producer to be registered in every member state where it first makes packaging or packaged goods available, and forbids making that packaging available where neither the producer nor its representative is registered; Article 45 requires non-EU producers to have an authorised representative in each member state concerned. In practice this replicates the country-by-country pattern you are already dealing with for WEEE, on a much larger population of sellers, from the same date.

The practical consequence is procurement, not law: pick a compliance arrangement per country that can hold all three mandates, or you will be signing three separate representative agreements in each of eight countries and reconciling three reporting calendars against the same shipment data.

A sensible order of registration

Order by revenue at risk, not by alphabet. Take your last twelve months of shipments by destination country, rank them, and register in that order — the cost of being unregistered scales with what a suspension in that market would cost you, and the fees scale with volume anyway. For most EU electricals sellers that means Germany, France and Italy first, then Spain and the Netherlands, then whichever of Poland, Belgium, Austria and the Nordics your actual data shows.

Then apply two corrections. First, pull forward any country where a marketplace is already asking: an imminent listing block outranks a larger market you are not being challenged on. Second, pull forward the countries whose process has the longest lead time rather than the largest fee — the ones where a written mandate must be signed, confirmed in a register by a local entity and only then activated (Denmark and Finland structurally, Germany in practice) take weeks that a country with a same-week online registration does not.

Finally, register the entity that is actually placing goods on that market. If you sell through a subsidiary in one country and direct from a third country in another, those are different producers under Article 3(1)(f), and a registration in the wrong company's name is not a defence. Where you wholesale to an established local importer, that importer is the producer for those goods — get it in writing, with their number, rather than assuming it.

Sources (checked 2026-08)

Legal spine: Directive 2012/19/EU (WEEE recast), Article 3(1)(f) definition of producer including point (iv) distance sellers, Article 16 (national register of producers, including distance sellers; registration and reporting by producers or their authorised representatives; interoperability between national registers) and Article 17 paragraphs 1 to 3 (permissive appointment for producers established in another member state; mandatory appointment for outbound distance sellers; appointment by written mandate) — consolidated text as published on legislation.gov.uk, since eur-lex.europa.eu returns no content to this network. Regulation (EU) 2023/1542 on batteries (EPR obligations applying from 18 August 2025; registration per member state). Regulation (EU) 2025/40 (PPWR), Articles 44 and 45, applying from 12 August 2026.

Country sources, each giving the register, the representative rule and the figures in its row: Italy — registroaee.it and the Camera di Commercio Milano Monza Brianza Lodi pages (Art. 29 D.Lgs. 49/2014; €46 for 2026 as €30 plus €16 stamp; 2025 data due 3 July 2026). France — filieres-rep.ademe.fr on the identifiant unique (mandatory since 1 January 2022, Art. L. 541-10-13 Code de l'environnement; representative route for non-established producers; marketplace verification duty; penalties to €30,000 with daily penalties, Art. L. 541-9-5). Spain — industria.gob.es RII-AEE and RD 110/2015 (free register, representante autorizado, quarterly quantities). Belgium — recupel.be legal obligations (entry agreement, quarterly or monthly declarations plus annual confirmation, Recupel as free authorised representative, marketplace duty from 29 March 2025). Netherlands — Nationaal (W)EEE Register (about €200 a year). Austria — EAG-VO § 21 and § 21a (EDM registration; Bevollmächtigter established in Austria).

Continued: Poland — biznes.gov.pl BDO guidance (200 zł micro or 800 zł others, same amount annually by end of February, financial security by 30 June, autoryzowany przedstawiciel). Ireland — producerregister.ie and weeeireland.ie (2026 fees €100 to €600 plus VAT by turnover; monthly Blackbox reporting). Sweden — Naturvårdsverket (SEK 1,000 annual supervision fee; producentombud by written mandate). Denmark — producentansvar.dk (no Danish CVR number means registration only through a Danish representative, under their CVR). Finland — ely-keskus.fi (representative domiciled in Finland; register moved from the Pirkanmaa ELY Centre to the new national supervisory agency on 1 January 2026). Czechia — Act No. 542/2020 Coll. and the Ministry of the Environment register (producer or pověřený zástupce, usually filed by the collective system). Portugal — apambiente.pt and SILiAmb under DL 152-D/2017 (representative with a Portuguese NIF). Greece — EOAN and the EMPA register (registration before first sale; no fee). German figures are carried from our stiftung EAR guide (checked 2026-07), not re-derived. Marketplace behaviour is as documented by Amazon's EPR seller pages and reported by compliance providers in mid-2026 — treat the pattern as durable and the specific enforcement date as checkable.

Check your specific case

• WEEE producer EU registration helper
• EU authorized representative finder
• Packaging EPR fees per EU country
• Guide: WEEE registration in Germany with stiftung EAR

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