GPSR and EPR — Country by Country

Product Safety (GPSR) and Recycling Cost Obligations (EPR) in Europe — Country by Country

As at 22 September 2026

Companies shipping into Europe and the UK tend to get caught out at the same point:
"We have appointed one representative, so we are covered."

In practice, two separate regimes are running, and they require different numbers of things.

It is entirely possible to have appointed a GPSR representative and still have completed zero EPR registrations.

1. GPSR (product safety) — the region decides the treatment

1-2. Language is where it usually goes wrong

Warnings and instructions are understood to be required in the language(s) specified by the member state where the product is sold.
Japanese and English alone are not sufficient in a number of countries.

2. EPR (recycling costs) — first, it splits into three streams

① Packaging          Boxes, void fill, bags, labels — everything wrapping the goods
② Electrical         Anything that runs on electricity, or ships with a plug or cable
③ Batteries          Loose batteries, and batteries built into products

Within the same country, these three are normally registered separately and reported separately.
"Our German registration is done" frequently turns out to mean packaging only.

3. The twelve countries: where you register, and whether a representative is needed

These are the twelve countries we actually handle.

We have not published fee amounts here. How fees are calculated (by weight and material, and so on) is reasonably stable, but the rates themselves move every year.

4. The four countries that are most often got wrong

4-1. Denmark — you must register before you sell

The regime is understood to have applied in full from 1 October 2025.

Registration is understood to be required at least 14 days before the first sale
   — registering after you have started selling is understood to be too late
From 2026, an annual report between 1 January and 31 May is understood to be required
   — a missed deadline can render the registration invalid

The representative requirement is understood to differ depending on whether the producer is established inside or outside the EU.
For a Japanese company (outside the EU), a representative obligation is understood to arise where batteries are sold directly to consumers; an equivalently worded obligation for packaging and electricals is not apparent.

4-2. Sweden — a representative is something you may appoint, not something you must

This is the one country of the twelve where the model differs.

A producer without an establishment in Sweden may appoint a representative, but is understood not to be acting unlawfully by choosing not to.
In that case, the producer itself carries the Swedish obligations directly.

"A representative is required everywhere in Europe" is not accurate for this country.

4-3. United Kingdom — there is no EU-style "authorised representative"

Instead, under a legislative change understood to have taken effect on 12 August 2025, where a non-UK company sells electrical equipment to UK households through an online marketplace, that marketplace is itself treated in law as the producer.

In other words, the question of who carries the obligation is framed differently from the EU.

For packaging, the first invoices are understood to have been issued in October 2025, and from the second year the rate is understood to vary according to how recyclable the material is.

4-4. Germany — the battery legislation has been replaced

From 7 October 2025, the legal basis for batteries is understood to have been replaced by new legislation.
Internal documents, and explanations from service providers, are often still written against the old statute.

5. In every country, the sequence is the same

① Register    Register in that country, in that stream, and obtain a number
② Join        Join the compliance organisation in that country
③ Report      Report the quantities placed on the market, by material and by weight
④ Pay         Pay according to weight and material
⑤ Label       Apply that country's sorting marks and labelling (such as the French mark)

Selling into twelve countries means twelve of these — and each splits again across the three streams.

6. In practice, delisting arrives before the regulator does

The most common trigger for companies contacting us is not a letter from an authority.

It is a marketplace asking for the registration number, the number not being available, and the listing being suspended.

Registering at that point is understood to take time before a number is issued. Sales stay stopped in the meantime.

7. About this page

• Information is as at 22 September 2026. These regimes change
• It is compiled from published information from national authorities and ministries, but it is general information and not advice on any specific matter
• What your company actually needs to do depends on the products, the countries, the annual tonnage, and the sales channel (your own site or a marketplace)

Talk to us

Once we know which countries, which products, and roughly what annual weight, the scale of the work becomes visible.

Answer a short set of questions and we will come back to you with the scope that is likely to apply to your company.
Your answers are saved as you go, so you can stop and continue later.

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If a listing has already been suspended, please say so — we will treat it accordingly.