compliance teamGerman EPR compared with Spain, Portugal and Italy
Step 1
Fix the destination and entity
Step 2
Collect current primary sources
Step 3
Compare equivalent controls
Step 4
Publish only source-complete differences
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
Who touches the register
Germany is the outlier. Its packaging register is free, public and searchable, and the producer must complete the entry personally; a registration performed by a third party does not count. In Spain, Portugal and Italy the equivalent step is normally handled by a service provider on the producer's instructions.
That single difference reshapes the product. Elsewhere the question is who files for you; in Germany the question is how well the session you run yourself has been prepared, and whether the result was verified in the public register afterwards.
What the representative actually carries
Germany gives the authorised representative the heaviest role of the four markets: it is deemed to be the producer, acts in its own name, is itself the addressee of the associated fines, and remains bound for duties accrued while the mandate ran. The mandate must be in German and signed by hand or with a qualified electronic signature.
The other three markets separate the roles differently, and some allow a simple electronic signature that Germany does not accept. Comparing them means comparing the actual mandates, not the marketing labels attached to them.
Costs and reporting rhythm
Germany has ten competing dual systems and no published tariff, so the licence for a small seller is a two-figure annual cost and the meaningful expense is representation. Markets with a single scheme publish rate cards instead, which makes their contributions predictable but their choice non-existent.
Reporting rhythms differ too: Germany asks for the same numbers twice, once to the system and once to the register, with a closing annual report by 1 June and an audited completeness declaration only above high thresholds. Compare each control against its own current primary source; nothing here transfers by analogy.
Conclusion
Scope comes before a form. Connect the legal entity, its German establishment, the product, the sales channel and the EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. The packaging register, the central agency, the dual systems and the marketplaces control their own procedures, timing and decisions.