--- title: "We ship electronics to consumers in several EU countries" description: "Under the WEEE Directive 2012/19/EU, a business selling electrical and electronic equipment at a distance to households or other users in a Member State where it is not established is the producer in that Member State. It must be registered there. A seller established in another Member State appoints an authorised representative in each country it sells to, by written mandate, to carry out its producer duties." type: "problem" url: "https://www.conphora.com/solutions/problem/weee-several-countries/" markdown: "https://www.conphora.com/solutions/problem/weee-several-countries.md" locale: "en" language: "en" updated: "2026-10-04" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02012L0019-20240408" tags: ["WEEE", "batteries-electronics"] license: "Free to quote with attribution and a link to the page" --- # We ship electronics to consumers in several EU countries Under the WEEE Directive 2012/19/EU, a business selling electrical and electronic equipment at a distance to households or other users in a Member State where it is not established is the producer in that Member State. It must be registered there. A seller established in another Member State appoints an authorised representative in each country it sells to, by written mandate, to carry out its producer duties. ## Why this happens A web shop that sends electronics across a border takes its producer obligations with the parcel. The WEEE Directive 2012/19/EU defines as a producer anyone who, irrespective of the selling technique, sells electrical and electronic equipment by distance communication directly to private households or to other users in a Member State, and is established in another Member State or in a third country (Article 3(1)(f)(iv)). [1] Registration follows the customer. Member States keep a register of producers, including producers supplying by distance communication, and those producers are registered in the Member State they sell to. Where a distance seller is not registered in that Member State itself, it is registered through its authorised representative (Article 16(1)). On registration, the register receives the representative's details and also the contact details of the producer it represents (Annex X, Part A, point 1). [1] The authorised representative is the link. A Member State ensures that a distance-selling producer established on its territory, which sells into another Member State where it is not established, appoints an authorised representative in that other Member State as the person responsible for its obligations there (Article 17(2)). The appointment is made by written mandate (Article 17(3)). Producers established in another Member State that place equipment on a market in the ordinary way may also appoint a representative there instead of acting themselves (Article 17(1)). [1] The national registers do not work in isolation. The authorities cooperate and exchange information, in particular between registers and by electronic means, to make sure producers comply (Article 18), and national registers link to each other's websites to make registration in several countries possible (Article 16(2)(d)). Inspections cover at least the information reported to the register (Article 23(1)(a)). [1] ## How to solve it 1. **List the countries your parcels go to** Pull your sales by delivery country and by product category, for consumers and for business customers. The directive counts distance sales to private households and to other users alike, and each country where you are not established is a separate obligation. 2. **Confirm you are the distance-selling producer there** A business that sells equipment by distance communication directly to private households or other users in a Member State, and is established in another Member State or a third country, is the producer in that Member State. Your registration at home does not cover those sales. 3. **Appoint an authorised representative per country** If you are established in an EU Member State and sell into another one, appoint an authorised representative in that other Member State, by written mandate, as the person responsible for your producer obligations there. The representative registers you and gives the register your contact details as the producer represented. 4. **Feed each register with per-country data** Each national register needs the categories, brands and selling technique you use in that country, and periodic reports of the weight of equipment you placed on that national market. Set up your order data so that you can report per country and per category. 5. **Arrange financing and take-back in each country** Your financing duty for the waste from your products applies in each Member State, individually or through a collective scheme there. As a seller you may also have one-to-one take-back duties when you supply a new product, unless the Member State uses the derogation, so check the national arrangement. ## What you need to show - **Written mandates for your authorised representatives** — You and each representative (WEEE Directive Article 17(2) and (3)) - **Registration in each Member State you sell to** — Your authorised representative, or you where you register directly (WEEE Directive Article 16(1) and Annex X, Part A) - **Reports per Member State on equipment placed on the market** — You or your authorised representative (WEEE Directive Article 16(2)(c) and Annex X, Part B) ## If you do nothing - **Registers exchange information** — Authorities responsible for the directive cooperate and exchange information, in particular between national registers and by electronic means, to make sure producers comply (WEEE Directive Article 18). - **Inspections start with the register** — Member States carry out inspections that cover at least the information reported in the register of producers (WEEE Directive Article 23(1)(a)). - **Penalties in each country** — Each Member State lays down effective, proportionate and dissuasive penalties for infringements of its national WEEE rules (WEEE Directive Article 22). ## Questions ### Does our registration at home cover what we sell abroad? No. Distance sellers are registered in the Member State they sell to, and where they are not registered there themselves, through their authorised representative (WEEE Directive Article 16(1)). ### Do sales to business customers count? Yes. The distance-selling producer definition covers sales directly to private households and to users other than private households (WEEE Directive Article 3(1)(f)(iv)). ### We are outside the EU and ship to EU consumers. Which rules apply? The producer definition includes distance sellers established in a third country (WEEE Directive Article 3(1)(f)(iv)), and they are registered in the Member State they sell to (Article 16(1)). Article 17(2) on appointing a representative addresses sellers established in a Member State, so check the national transposition in each country for how a non-EU seller registers. ### How is the representative appointed? By written mandate (WEEE Directive Article 17(3)). The representative is established in the Member State concerned and is responsible for fulfilling your producer obligations on its territory (Article 17(2)). ### Who pays for collecting the old devices in those countries? For waste from private households, you do, as the producer, for the waste from your own products, either individually or by joining a collective scheme, with a guarantee given when the product is placed on the market (WEEE Directive Article 12(1) and (3)). ## Regulations involved WEEE ## Sources 1. [Directive 2012/19/EU on waste electrical and electronic equipment (WEEE) (consolidated text of 8 April 2024)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02012L0019-20240408) — EUR-Lex, 2026-10-04 2. [Directive 2012/19/EU on waste electrical and electronic equipment (Official Journal L 197, 24.7.2012)](https://eur-lex.europa.eu/eli/dir/2012/19/oj) — EUR-Lex, 2026-10-04