Start a conversation

EU compliance

The four European representatives, and why it is never the same person

A Chinese company selling in Europe usually needs several distinct mandated parties, and almost always buys one. The word representative covers jobs that rest on different legal bases, and a provider who says it does representation generally covers only one of them.

China → France

The confusion is almost never the exporter's fault. A European customer asks for an EU representative, a service provider answers that it does exactly that, a contract is signed, and everyone goes back to work. The contract is real and the provider is honest. It simply covers one of several roles that the same word is used for, and the three others stay unfilled until something makes their absence visible — a customs hold, a delisted product page, a tax demand, a letter from an authority nobody can answer.

What the responsible person for the product actually carries

This is the one most people mean, and the one that commits the most. Product legislation in the Union requires, for whole families of goods, that a party established in the Union be designated to answer for the product itself. Its name and its address go on the product, on the packaging or on the accompanying document. It keeps the declaration of conformity and the technical file available for the authorities, it cooperates when a product looks unsafe, and it is the address to which a surveillance authority writes. It is not a postbox: it is the party that has to produce a document on request and explain what it means.

Why the collection and recycling mandate is somebody else, country by country

Extended producer responsibility works on a different logic entirely. It does not ask who answers for the safety of the product; it asks who finances the end of its life — the packaging, the electrical and electronic equipment, the batteries, the textiles, depending on the stream and the country. A seller established outside the Union generally cannot register directly, so it appoints an authorised representative who registers in its name, declares what was placed on the market and pays the contribution. The decisive point is that these registers are national. There is no single European enrolment: each member state keeps its own register, with its own streams, its own identifiers and its own declaration calendar, and a mandate valid in one country proves nothing in the one next door.

  • The responsible person for the product. Established in the Union, named on the product or its packaging, holds the declaration of conformity and keeps the technical file available. It answers to market surveillance and can be required to act on a product already on the market. One for the Union, designated by a written mandate that says what it may and may not do.
  • The authorised representative for the collection and recycling streams. Registers you in the national register of the stream concerned, declares the quantities placed on that national market and pays the contribution. One per member state, often one per stream, and the obligation attaches country by country rather than once for the Union.
  • The tax representative for VAT. Deals with registration, returns and payment of the tax in the member states where your sales make it due. In several countries this party is jointly liable for the tax it declares on your behalf, which is why it asks for guarantees and refuses files it cannot verify. It says nothing about the product.
  • The representative for personal data. Required when a company not established in the Union processes the personal data of people who are there — customers of an online shop, users of a connected product, people who filled in a form. It is the contact point for the supervisory authorities and for the individuals themselves, and it keeps the record of processing activities available.

Four mandates, four liabilities, and why one provider rarely covers them

Each of these roles is created by a different body of law, and each exposes whoever accepts it to a different risk. The party that answers for the product can be ordered to withdraw goods from the market. The party that registers you in a recycling stream owes a contribution calculated on declared quantities. The tax representative may be pursued for tax it never collected. The data representative is the address the supervisory authority uses. No serious provider accepts all four for the same fee, because the liabilities do not resemble one another — and a provider who says yes to everything without changing the price is a provider who has not read what it is signing.

What to ask a provider before signing anything

The useful question is never « do you do representation ». It is which of these roles the mandate covers, under which legislation, for which product categories and in which member states. Ask to see the clause that names the role. Ask whether the name and address that will appear on the packaging are the provider's, and whether that is contractually permitted for your product family. Ask who holds the technical file and where it physically sits. A provider who can answer those questions in writing is a provider you can keep; one who answers that everything is included has sold you a single role and the belief that you have four.

In which order to put them in place

  1. Settle who answers for the product, before the first shipment. Its name goes on the packaging, so the artwork depends on it, and artwork is the slowest thing to change once printing has started.
  2. Register in the collection and recycling streams of each country you actually sell into, before the goods are placed on that market. The registration identifier is sometimes asked for by marketplaces and by customers before the first order, and obtaining it is not instantaneous.
  3. Deal with VAT when the structure of your sales is decided — who imports, who invoices, whether you sell to businesses or to consumers — because the answer determines where registration is due and whether a representative is required at all.
  4. Appoint the data representative as soon as a European customer can give you their details: a shop that takes orders, a product that sends data back, a newsletter form. This one is forgotten the longest and is the easiest of the four to put right.
  5. Write down, on one page, who holds which mandate, in which country, with which contract reference and which contact name. That page is what a customer, a marketplace or an authority asks for, and reconstructing it under pressure is how companies discover a role was never filled.

Before renewing any representation contract, lay the mandates side by side and read only the clause that names the role. Most companies discover at that moment that they are paying for the same job in duplicate in one country and have nobody at all in another. Start with the product, because that name is printed and because it is the address an authority will write to; then go stream by stream and country by country, since those registers are national and the detail varies by member state. Ask the national register or the authority of the country you actually sell in rather than reasoning from what was true somewhere else.

Where to read it yourself

Official pages, opened and checked on 15 October 2026. Where a rule changes, these are the addresses that change with it — this article does not.

Questions we get on this.

Can the same company be our responsible person, our recycling representative and our tax representative?

Legally it is possible in some combinations, and commercially it is rare, because the three expose the provider to risks of a different nature. Groups exist that offer several of these services under one roof, usually through separate entities and separate contracts with separate fees. What matters is not whether it is one company but whether each role is named in a mandate: a single invoice does not prove that a register was joined or that a tax representation was accepted. Read the clause, not the brochure.

Do we need a recycling representative in every member state, or is one enough for the Union?

Extended producer responsibility is organised nationally. Each member state keeps its own registers, defines its own streams and sets its own declaration obligations, so the registration is done country by country for every country where the product is placed on the market. There is no single European enrolment that covers them all. The practical consequence is that opening a new country is not only a commercial decision: it adds registrations, declarations and contributions. Check with the register of the country concerned, because both the streams and the procedure vary.

Our distributor says it handles everything. Is that enough?

It can be true and it is worth writing down, because a distributor who takes on these roles acquires obligations and leverage at the same time. If its name is printed on your packaging as the party answering for the product, changing distributor later means changing the packaging, and sometimes losing access to the file that proves conformity. Make sure the mandate says which role is covered, that the technical file remains yours, and what happens to the registrations the day the relationship ends. That last clause is the one nobody writes and everybody needs.

Keep reading on this.

EU complianceWho is legally responsible for your product in the European UnionSelling into Europe means someone established in Europe carries obligations for the product. Deciding who, early, avoids discovering it at customs.EU complianceExtended producer responsibility: the European bill nobody quotes youYou pay for the end of your product's life in every country where you sell it. Registration is national, per stream, and marketplaces now enforce it for the regulator.EU complianceWhen the manufacturer is outside Europe, who pays for a defective product?European law answers this with a chain of substitutes, and the first link is your importer. Understanding the order explains why European buyers negotiate indemnities so hard.EU complianceWhat general product safety rules now require on an online product listingThe product page is no longer just marketing. European general product safety law made the listing itself a regulated object, with information that has to be visible before anyone clicks buy.

If this raised a question about your own project, tell us where you are — the first conversation usually clarifies more than a proposal.

Talk about selling into Europe →Read the full guide