Kan jeg selv håndtere min EPR-registrering, eller har jeg brug for en repræsentant?
For a large part of EPR registration, you can do it yourself. Most national registers, such as Germany's LUCID, are open to companies that register directly, in German or sometimes in English, with their own login and their own responsibility. There is no legal obligation to use an agency for this, as long as your company is established in the European Union.
The exception lies in the place of establishment. A number of countries require companies that are not established in that country or sometimes not even in the EU to appoint a local authorized representative who registers on their behalf and is a point of contact. This is then not a choice between doing it yourself or outsourcing, but a condition for being allowed to supply in that country at all. Which situation applies to you depends on where your company is established and in which country you place packaged products on the market.
What you can arrange yourself
If your company is established in the EU, you can generally log in yourself to the national register, enter your packaging data and provide the annual quantities. This does require that you correctly classify the material categories, know which weight applies per packaging type and understand the correct fee structure of that country. For one country, that is manageable. As soon as you supply in five or six countries, with just as many different registers, classifications and deadlines, it becomes mainly a matter of time and the risk that you overlook something.
The decision wizard on epria.eu provides a first point of reference: you can see in a few questions which role you have per country and per packaging type, and whether registration is relevant for that situation at all. This is a free step that helps you determine whether handling it yourself is realistic, before you start with a register.
When a representative is not optional
Some countries, including Germany via LUCID, set as a condition that a company without an establishment in that country or in the EU appoints a registered representative. This representative registers on your behalf, shares responsibility for the accuracy of the information and is the point of contact for the supervisory authority. This is not a matter of convenience, but a formal requirement that is separate from how well you know the rules yourself or how much time you want to spend on it.
Whether this obligation applies to your situation depends on the precise establishment structure of your business and the country of supply. This is one of the subjects on which the official guidelines differ per country, and on which we deliberately do not give our own legal judgment. If you are unsure whether your company falls under this obligation, we will cite the relevant guidelines and refer you to the competent authority or a lawyer.
Doing it yourself versus getting guided support
The boundary is therefore not at "can I technically fill this in myself", because that is possible in most registers. The boundary lies in three things: whether your country of establishment requires a representative, whether you have the time to maintain multiple country systems, and whether you want to bear the risk that an incorrect classification only comes to light during an inspection. For a small assortment in one country, handling it yourself is often feasible. For multiple countries, varying packaging types or a structure with establishments in different member states, the chance of errors increases, simply because each country uses its own classification and fees.
In the knowledge base you will find per subject how we have researched how the registration obligation, the representative and the annual report fit together per country, so you don't have to browse through six different government websites yourself. If you want to know how epria.eu arranges the guidance per country and what remains under your own responsibility in this process, you can read that on the page explaining how it works.
What epria.eu does and does not do for you
Epria.eu bliver selv aldrig en affaldsbehandlingsorganisation og opkræver ikke bidrag på dine vegne. Hvad vi gør, er at vejlede dig ved registrering i det rette nationale register, udarbejde emballagedossieringen og overensstemmelseserklæringen i henhold til bilag VIII, og minde dig på rette tid om årsopgørelsen. Hvorvidt det er hensigtsmæssigt for din situation, og hvilke omkostninger der er forbundet hermed, kan du se på siden med abonnementtakstifterne.
Vil du først selv se, om registrering i et andet land er relevant for dig, og om en repræsentant er nødvendig, så benyt den gratis rolguide. Det tager et par minutter og giver med det samme en konkret indikation, uden at du behøver at oprette en konto.