Free tool · EU law, three streams
Who is the producer?
Three EU texts answer it, one stream each.
The producer is the business that carries the EPR obligation in a country: it registers, joins a scheme and declares what it sold there. It is not always the brand, and under the EU texts it is not the marketplace that hosts your sale. Describe how you sell into one EU country, and see who the producer is there for packaging, WEEE and batteries, with the article that says so.
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Describe how you sell into one EU countryIndicative · 3 questions at most
You are the producer, in the country where you are established
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PackagingYou
You are established there and you are the first to make the product available there. Having it made under your own name or brand makes you its manufacturer.
Regulation (EU) 2025/40, Article 3(1), points (13)(a) and (15)(b)
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WEEEYou
You make the equipment, have it made, or resell it under your own name or brand, where you are established.
Directive 2012/19/EU, Article 3(1)(f)(i) and (ii)
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BatteriesYou
You make the battery or have it made, or resell it under your own name or brand, where you are established. A battery built into your product counts.
Regulation (EU) 2023/1542, Article 3, point (47)(a) and (b)
You are the producer: you are the first to supply it in that country
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PackagingYou
You buy the product elsewhere and are the first to make it available where you are established.
Regulation (EU) 2025/40, Article 3(1), point (15)(b)
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WEEEYou
You place equipment from another country on the market where you are established, as a business.
Directive 2012/19/EU, Article 3(1)(f)(iii)
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BatteriesYou
You are the first to supply batteries from another country where you are established, including the ones inside products.
Regulation (EU) 2023/1542, Article 3, point (47)(c)
Someone before you in the chain is the producer
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PackagingSomeone before you
The producer is whoever first made the packaged product available in that country, not the business that resells it after them.
Regulation (EU) 2025/40, Article 3(1), point (15)(b)
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WEEESomeone before you
The producer is the business whose name or brand the equipment carries, or the one that brought it into the country.
Directive 2012/19/EU, Article 3(1)(f)(i) to (iii)
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BatteriesSomeone before you
The producer is the business whose name or brand the battery carries, or the one that first supplied it in the country.
Regulation (EU) 2023/1542, Article 3, point (47)(a) to (c)
You are the producer there, even without a company in the country
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PackagingYou
You make the product available directly to end users in a country where you are not established. Where the parcels leave from does not change this.
Regulation (EU) 2025/40, Article 3(1), point (15)(c) and (d)
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WEEEYou
You sell equipment at a distance, directly to households or business users there, from another EU country or from outside the EU.
Directive 2012/19/EU, Article 3(1)(f)(iv)
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BatteriesYou
You sell batteries at a distance, directly to end users there. Batteries inside the products you sell count.
Regulation (EU) 2023/1542, Article 3, point (47)(d)
Your buyer is the producer there, not you
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PackagingYour buyer
Your buyer is established in that country and is the first to make the product available there.
Regulation (EU) 2025/40, Article 3(1), point (15)(b)
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WEEEYour buyer
Your buyer places equipment from another country on the market there, as a business.
Directive 2012/19/EU, Article 3(1)(f)(iii)
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BatteriesYour buyer
Your buyer is the first to supply batteries from another country there, including the ones inside products.
Regulation (EU) 2023/1542, Article 3, point (47)(c)
You need a representative in that country for some streams
For packaging and batteries, the EU texts require an authorised representative in each country where you sell directly to end users without being established there. For WEEE, the law of your own country has you appoint one there.
See the table, country by countryRegulation (EU) 2025/40, Article 45(3); Regulation (EU) 2023/1542, Article 56(3); Directive 2012/19/EU, Article 17(2)
You need a representative in that country for some streams
For packaging and batteries, the EU texts require an authorised representative in each country where you sell directly to end users. For WEEE, each country decides for sellers established outside the EU: some require one, some only allow one.
See the table, country by countryRegulation (EU) 2025/40, Article 45(3); Regulation (EU) 2023/1542, Article 56(3)
You may still appoint a representative for WEEE
Every EU country must allow a producer established in another member state to appoint a representative on its territory to carry its WEEE obligations there.
Directive 2012/19/EU, Article 17(1)
The marketplace checks your number. It does not take your place
Before it lets you sell to consumers, the marketplace has to collect your registration number and a self-certification from you, for packaging and for batteries. Under a written mandate, it may pay your packaging contributions for you. The WEEE directive sets no such check; some national laws add one.
Regulation (EU) 2025/40, Article 45(4) to (6); Regulation (EU) 2023/1542, Article 62(6)
The fulfilment service provider checks too
When you sign with a fulfilment service provider, you give it your packaging registration number and self-certification. It checks them, asks you to correct what is wrong, and suspends its service until you do.
Regulation (EU) 2025/40, Article 45(7) and (8)
Indicative: these are the EU definitions, read on 11 November 2026. Each country applies them through its own register, and a person reads your case before any quote.
- PackagingRegulation (EU) 2025/40Article 3(1), point (15)
- WEEEDirective 2012/19/EUArticle 3(1)(f)
- BatteriesRegulation (EU) 2023/1542Article 3, point (47)
- Read at the source11 November 2026On the published texts, not on summaries
The definitions, side by side
Five situations, three definitions. Where you are established decides most of it.
Each text defines the producer in its own words, and all three land on the same situations. Read your row across: each cell names who the producer is for that stream, and the point of the definition that says so.
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You sell it under your own name or brand, in the country where you are established
- Packaging
- YouRegulation (EU) 2025/40, Article 3(1), points (13)(a) and (15)(b)
- WEEE
- YouDirective 2012/19/EU, Article 3(1)(f)(i) and (ii)
- Batteries
- YouRegulation (EU) 2023/1542, Article 3, point (47)(a) and (b)
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You buy it in another country and are the first to sell it where you are established
- Packaging
- YouRegulation (EU) 2025/40, Article 3(1), point (15)(b)
- WEEE
- YouDirective 2012/19/EU, Article 3(1)(f)(iii)
- Batteries
- YouRegulation (EU) 2023/1542, Article 3, point (47)(c)
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You buy it from a business in your own country and resell it as it is
- Packaging
- Someone before youRegulation (EU) 2025/40, Article 3(1), point (15)(b)
- WEEE
- Someone before youDirective 2012/19/EU, Article 3(1)(f)(i) to (iii)
- Batteries
- Someone before youRegulation (EU) 2023/1542, Article 3, point (47)(a) to (c)
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You sell it directly to end users in a country where you are not established
- Packaging
- YouRegulation (EU) 2025/40, Article 3(1), point (15)(c) and (d)
- WEEE
- YouDirective 2012/19/EU, Article 3(1)(f)(iv)
- Batteries
- YouRegulation (EU) 2023/1542, Article 3, point (47)(d)
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You sell it to a business in another country, which resells it there
- Packaging
- Your buyerRegulation (EU) 2025/40, Article 3(1), point (15)(b)
- WEEE
- Your buyerDirective 2012/19/EU, Article 3(1)(f)(iii)
- Batteries
- Your buyerRegulation (EU) 2023/1542, Article 3, point (47)(c)
“End users” covers consumers and businesses that use the product themselves, in all three texts. A battery built into your product counts as a battery you supply. National laws apply these definitions through their own registers, and a person reads your countries before any quote.
Marketplaces and fulfilment
They check your number. They don't carry the obligation.
The packaging and battery texts give online platforms and fulfilment service providers a duty to check your registration before they serve you. That is why a marketplace sets you a deadline. Under the EU texts, the duty does not make it the producer.
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The marketplace checks your number. It does not take your place
Before it lets you sell to consumers, the marketplace has to collect your registration number and a self-certification from you, for packaging and for batteries. Under a written mandate, it may pay your packaging contributions for you. The WEEE directive sets no such check; some national laws add one.
Regulation (EU) 2025/40, Article 45(4) to (6); Regulation (EU) 2023/1542, Article 62(6)
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The fulfilment service provider checks too
When you sign with a fulfilment service provider, you give it your packaging registration number and self-certification. It checks them, asks you to correct what is wrong, and suspends its service until you do.
Regulation (EU) 2025/40, Article 45(7) and (8)
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Marketplace
The platform that hosts the sale. Does not carry the obligation, but controls it: Amazon asks for an EPR number and suspends listings without one.
Not established there
Producer without a company in the country? Then the representative question follows.
Selling directly to end users in a country where you are not established makes you the producer there. For some streams, the law also wants someone established in that country to carry your obligations: an authorised representative.
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In another EU country
For packaging and batteries, the EU texts require an authorised representative in each country where you sell directly to end users without being established there. For WEEE, the law of your own country has you appoint one there.
Regulation (EU) 2025/40, Article 45(3); Regulation (EU) 2023/1542, Article 56(3); Directive 2012/19/EU, Article 17(2)
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Outside the EU
For packaging and batteries, the EU texts require an authorised representative in each country where you sell directly to end users. For WEEE, each country decides for sellers established outside the EU: some require one, some only allow one.
Regulation (EU) 2025/40, Article 45(3); Regulation (EU) 2023/1542, Article 56(3)
Which countries want one for WEEE, and which only allow one, is set country by country. See the table, country by country
You know who the producer is. The scope check maps what it owes, country by country.
Tell us where your company is registered, where you ship and what is in the box. You'll see an indicative map of what you owe on the screen, and a person reads it before anyone quotes you anything.
Free. No card. A person answers.
Source review
Figures on this page come from published guidance. Last source review: 11 November 2026. Rules change. The scope check is reviewed by a person before any quote.
- PackagingRegulation (EU) 2025/40Article 3(1), point (15), and the articles cited above
- WEEEDirective 2012/19/EUArticle 3(1)(f), and the articles cited above
- BatteriesRegulation (EU) 2023/1542Article 3, point (47), and the articles cited above
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