KontorBund — Explainer Where registration can be delegated — and where it can't
Last checked 8 September 2026
kontorbund.com/explainers/where-registration-can-be-delegated.html

The Library

Where registration can be delegated — and where it can't

Last checked8 September 2026

KeeperOpen — keeper wanted

StatusDraft, eleven countries open

The short version

Article 44 has two delegation routes, not one, and they default opposite ways. Your scheme may register you unless a member state says otherwise (Art. 44(2)); your representative may register you only if a member state says so (Art. 44(3)). Germany is the one state we have found that shut both. Austria went the other way and made the representative the only route you are allowed to use. And eleven of the twenty-seven have published no answer at all.

There are two delegation routes, not one

Almost every guide to this subject asks one question — "does this country let my representative register me?" — and treats the answer as a single national switch. That is the wrong shape. Article 44 contains two separate delegation routes, they run through different people, and their defaults point in opposite directions.

Route one — the PRO route, Art. 44(2): Second sentence: where you have entrusted a producer responsibility organisation with your EPR obligations under Art. 46(1), "the obligations set out in this Article shall be met by that organisation, unless otherwise specified by the Member State". Note the shape: this is on by default, and a state has to actively switch it off.
Route two — the representative route, Art. 44(3): "Member States may provide that the obligations set out in this Article may, on the basis of a written mandate, be met on behalf of producers by an authorised representative for the extended producer responsibility." Off by default, and a state has to actively switch it on.

This is why the folkloric question has no answer. "Which countries let you delegate registration" is asking about one switch when there are two, wired the opposite way round. The answerable question is narrower and duller: for this country, which of the two routes is open — the PRO route, the representative route, both, or neither?

Germany closed both doors — and that is the unusual part

Germany is the country everyone quotes, and it is quoted for the wrong reason. People say "Germany doesn't allow delegation" as though it were a strict version of a rule the others have relaxed. What actually happened is more specific: Germany is the one member state we have found that has shut both routes.

It did not take the Art. 44(3) option, so no representative may register you. And it is the "unless otherwise specified by the Member State" in Art. 44(2) — your dual system may do a great deal for you, but it may not submit your LUCID registration. The ZSVR's own word for it is höchstpersönlich: strictly personal. Your own employees may do the typing. An external service, agency or representative may not.

What this does not mean. Germany still requires an authorised representative from 12 August 2026, for everything else. Registration stays with you, the representative carries the rest, and you need both — which is why the Germany desk is the only one in the set that describes two obligations rather than one. A provider offering to "do your LUCID registration for you" is selling something that is not compliant, and the register is public, so it is visible that they did.

Austria is the mirror image, and it surprises people more

If Germany closed both doors, Austria removed the handle from the inside. A seller with no Austrian seat or branch, shipping to Austrian consumers, is not allowed to register alone. The representative is not a convenience there and not a way of saving yourself an afternoon — it is the only route into the system that exists.

Sellers find this the harder of the two to accept, because it costs money to do something they were willing to do for free. It is worth being precise about what is happening: Austria has not made registration optional, it has made you ineligible to perform it. The obligation is unchanged; the hand that performs it is not yours.

All twenty-seven, as far as we can establish

Read this as "who, in practice, submits the registration" rather than as a ruling on which paragraph a state relied on — several countries have a working route without ever having published which of the two doors they opened. Not published means exactly that: we looked, we did not find it, and we would rather leave a gap than fill it.

Country Who submits your registration What we found

Austria Your representative — and only them A seller with no Austrian seat may not register for consumer sales at all. Notarially certified power of attorney.

Belgium Your scheme Fost Plus registers its members collectively. Your representative must itself be registered with EPRiBEL.

Bulgaria Not published Filing runs on a qualified electronic signature and no foreign-producer route has been published either way.

Croatia Your representative The representative uploads the authorisation into RPPO for the Fund to approve.

Cyprus Not published Cyprus has not published which register entry a foreign producer needs, let alone who may make it.

Czechia Your representative A dedicated application exists, and the representative may file in its own name.

Denmark Your representative The representative files — and DPA invoices it, not you. Seven days to accept before the request expires.

Estonia Your representative In substance yes: the appointment is not complete until the mandate is filed in the packaging register.

Finland Your scheme The producer organisation contracted through Rinki handles the authority registration.

France Your mandataire or scheme The scheme registers you in SYDEREP and ADEME issues the IDU. The exact mirror of Germany.

Germany You, personally Neither route. höchstpersönlich — your own staff may type it, no external party may.

Greece Not published EMPA exists and is in Greek; no appointment procedure for a representative has been published.

Hungary Your representative Under Decree 80/2023, with a Hungarian tax number. Two registrations, authority and MOHU.

Ireland Not published Competent authorities designated in 2025; the operational route was not published when we checked.

Italy Not published The PPWR register is unpublished. The CONAI foreign-company route is an email address.

Latvia Not published No published position on either route for a producer established abroad.

Lithuania Not published GPAIS is built around Lithuanian producer and importer definitions. No complete foreign route.

Luxembourg Not published Valorlux is the practical route; the register question itself is open.

Malta Your representative Malta already publishes a written-mandate form — rarer than it should be.

Netherlands Not published No published position, though below 50,000 kg there may be nothing to file anyway.

Poland Not published — and in practice, you No published position, and BDO access normally needs a person who can authenticate through Poland's national system. A BDO proxy is not an Art. 45(3) representative.

Portugal Your representative The authorised-representative classification in SILiAmb is the entry route for a foreign tax number.

Romania Not published No single public packaging register; AFM enrolment needs a qualified electronic signature.

Slovakia Your representative The § 27 mandate has a statutory minimum one-year term, and the representative acts in its own name.

Slovenia Your representative The representative completes the registration — this is how the well-run ones work.

Spain Your representative The representative registers you in the RPP; your ENV number then goes on your invoices.

Sweden Your PRO The PRO may submit, and you remain accountable for the accuracy and the timing either way.

Country	Who submits your registration	What we found
Austria	Your representative — and only them	A seller with no Austrian seat may not register for consumer sales at all. Notarially certified power of attorney.
Belgium	Your scheme	Fost Plus registers its members collectively. Your representative must itself be registered with EPRiBEL.
Bulgaria	Not published	Filing runs on a qualified electronic signature and no foreign-producer route has been published either way.
Croatia	Your representative	The representative uploads the authorisation into RPPO for the Fund to approve.
Cyprus	Not published	Cyprus has not published which register entry a foreign producer needs, let alone who may make it.
Czechia	Your representative	A dedicated application exists, and the representative may file in its own name.
Denmark	Your representative	The representative files — and DPA invoices it, not you. Seven days to accept before the request expires.
Estonia	Your representative	In substance yes: the appointment is not complete until the mandate is filed in the packaging register.
Finland	Your scheme	The producer organisation contracted through Rinki handles the authority registration.
France	Your mandataire or scheme	The scheme registers you in SYDEREP and ADEME issues the IDU. The exact mirror of Germany.
Germany	You, personally	Neither route. `höchstpersönlich` — your own staff may type it, no external party may.
Greece	Not published	EMPA exists and is in Greek; no appointment procedure for a representative has been published.
Hungary	Your representative	Under Decree 80/2023, with a Hungarian tax number. Two registrations, authority and MOHU.
Ireland	Not published	Competent authorities designated in 2025; the operational route was not published when we checked.
Italy	Not published	The PPWR register is unpublished. The CONAI foreign-company route is an email address.
Latvia	Not published	No published position on either route for a producer established abroad.
Lithuania	Not published	GPAIS is built around Lithuanian producer and importer definitions. No complete foreign route.
Luxembourg	Not published	Valorlux is the practical route; the register question itself is open.
Malta	Your representative	Malta already publishes a written-mandate form — rarer than it should be.
Netherlands	Not published	No published position, though below 50,000 kg there may be nothing to file anyway.
Poland	Not published — and in practice, you	No published position, and BDO access normally needs a person who can authenticate through Poland's national system. A BDO proxy is not an Art. 45(3) representative.
Portugal	Your representative	The authorised-representative classification in SILiAmb is the entry route for a foreign tax number.
Romania	Not published	No single public packaging register; AFM enrolment needs a qualified electronic signature.
Slovakia	Your representative	The § 27 mandate has a statutory minimum one-year term, and the representative acts in its own name.
Slovenia	Your representative	The representative completes the registration — this is how the well-run ones work.
Spain	Your representative	The representative registers you in the RPP; your ENV number then goes on your invoices.
Sweden	Your PRO	The PRO may submit, and you remain accountable for the accuracy and the timing either way.

Eleven of the twenty-seven have no published answer. That is the real headline, and it is not a gap in this page — it is a gap in the national implementations, eight months after the register obligation started to bite. Where the route is unpublished the duty is not suspended; you still may not make packaging available before you are registered (Art. 44(4)), which is an uncomfortable place for a state to leave a seller standing.

Why this is worth getting right

Three practical consequences, in the order they tend to bite.

You may be buying something you cannot use: A provider selling "EU-wide registration handled for you" is selling something that is not deliverable in Germany and not clearly deliverable in the eleven unpublished states. Ask, per country, who signs the application. A provider that answers "we handle it" without naming the route has not answered.
It changes what you can and cannot outsource under time pressure: If you find a deadline three days out, the delegable countries are the ones you can still fix by signing a mandate. Germany is not — you have to be at the keyboard yourself, and you need whatever identity credentials the register wants. Plan the non-delegable ones first.
Registration and representation are different things and get conflated: A country can require a representative and still refuse to let that representative register you. Germany does exactly that. So "I have appointed a representative" is not the same sentence as "I am registered", and only one of them keeps you the right side of Art. 44(4). See what an authorised representative is — and isn't.

Sources

The two-route reading is ours, taken from the text of Art. 44 itself. We have not seen it set out this way in a vendor guide or in the Commission FAQ, which is either because it is obvious once you read the Article or because everyone has been answering the folkloric question instead. Check it against the text before you rely on it — the relevant words are quoted in full above, so you can.

Regulation (EU) 2025/40 (PPWR) — EUR-Lex Source for Art. 44(2) second sentence (the PRO route, on unless a state specifies otherwise), Art. 44(3) (the representative route, off unless a state provides for it), Art. 44(4) (no making available before registration) and Art. 46(1) (entrusting a PRO). Read directly for this page
ZSVR — the German register on the authorised representative Source for German registration being höchstpersönlich and for the representative duty existing alongside it rather than instead of it
European Commission — PPWR Frequently Asked Questions, 2nd edition DG ENV Unit B01, August 2026 (KH-01-26-068-EN-N). Read in full. Does not address the Art. 44(2) / Art. 44(3) distinction — checked, so nobody repeats the search
The twenty-seven country desks Every row in the table above is drawn from that country's desk, where the finding sits next to its national source

Help us finish this page

Eleven countries have no published answer — Bulgaria, Cyprus, Greece, Ireland, Italy, Latvia, Lithuania, Luxembourg, the Netherlands, Poland and Romania. If you have registered in any of them, you know something the published material does not say: who actually signed the application, and whether the authority accepted it from them. That is a two-line contribution that closes a row on this table for everybody.

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