Enregistrement EPR pays par pays : Où une marque de vélos électriques s’enregistre-t-elle en Allemagne, en France, aux Pays-Bas, en Belgique, au Danemark, en Espagne et au Royaume-Uni ?

Part 1 of this series explained why the importer is the legal “producer” and which three obligation streams an electric bike triggers. This part is the map: for each major cycling market, which registers exist, which organisations run collection, and where appointing a local authorised representative is not optional. Rules evolve — treat the official links below as the source of truth and this article as the orientation layer.

Official registers and authorities referenced in this article:

• Germany: Fondation EAR (WEEE & battery registers) · ZSVR — LUCID (packaging)
• France: ADEME filières REP · Ecologic · Citeo
• Netherlands: Stichting OPEN · Stibat · Verpact
• Belgium: Recupel · Bebat · Fost Plus / Valipac
• Denmark: Dansk Producentansvar (DPA)
• Spain: MITECO (RII-AEE and packaging producer registers)
• United Kingdom: GOV.UK WEEE · GOV.UK packaging EPR

How to read this map

Every country below follows the same skeleton — a register entry that gives you a producer number, membership of a collection/recovery scheme that handles the physical waste stream, and an annual (sometimes more frequent) quantity declaration. What differs is how many registers there are, who runs them, whether foreign companies must appoint a local representative, and how aggressively marketplaces and authorities check. The table gives the overview; the sections after it cover what actually trips importers up in each market.

Germany: three systems, zero tolerance for selling first

Germany runs its three streams as three genuinely separate systems, and all three follow the same hard rule: registration before the first unit is offered for sale — offering, not just selling, is enough to trigger the obligation.

For the vehicle, registration with Stiftung EAR under the ElektroG yields a WEEE registration number (WEEE-Reg.-Nr.) that must appear on invoices and that marketplaces verify. Foreign companies without a German establishment appoint an authorised representative to hold the registration. The battery register — also administered via Stiftung EAR under battery law — is a separate registration covering the packs in your bikes and any spares sold alone. Packaging runs through the LUCID register operated by the ZSVR, paired with a contract with a licensed dual system that finances collection; declared volumes in LUCID and volumes licensed with the dual system must match, which is exactly where missing per-SKU packaging weights from a factory turn into declaration errors.

German marketplaces have enforced EPR numbers since 2022, and the enforcement mechanism is commercial before it is legal: listings are simply deactivated. For a brand launching with marketplace or hybrid distribution, the German registrations belong on the critical path of the launch plan, ahead of stock arrival — approval at EAR can take weeks.

France: one identifier per stream, and a mandatory local mandataire

France organises EPR through ADEME, which issues a unique identifier (IDU) per company per stream — so an e-bike brand ends up holding several IDUs: one for electrical equipment, one for batteries, one for packaging. Each IDU is obtained through membership of an approved eco-organisme for that stream: Ecologic is a principal eco-organisme for electrical equipment, Citeo dominates household packaging, and batteries run through the approved battery organisations. Membership is not decorative — without a signed contract with an approved scheme, the products may not legally be sold in France.

Two French specifics matter for bike businesses. First, companies not established in France must appoint a French authorised representative (mandataire) who assumes the obligations locally; this applies to EU companies without a French branch as well as non-EU sellers. Second, France runs a dedicated EPR stream for sport and leisure articles (ASL, managed by Ecologic) which covers conventional, non-motorised cycles — so a brand selling both electric and non-electric bikes registers the electric models under the electrical-equipment stream and the non-electric models under ASL. Mixing these up is one of the most common French declaration errors in the bike trade. France also requires the Triman logo and sorting information on consumer products and packaging — a labelling point to settle with your manufacturer at artwork stage, not after printing.

The Netherlands and Belgium: consolidated schemes, fewer surprises

The Dutch system is comparatively streamlined: Stichting OPEN administers producer responsibility for electrical equipment, Stibat handles batteries, and Verpact (successor to the Afvalfonds) runs packaging, with small-volume thresholds that many bike importers exceed quickly given packaging weight per unit. Belgium mirrors the structure with Recupel for electrical equipment, Bebat for batteries — one of Europe’s oldest battery schemes, with well-developed reporting — and a packaging split between Fost Plus for household packaging and Valipac for commercial/industrial packaging. The household-versus-commercial packaging split matters for B2B bike shipments: pallets and transport packaging to dealers are treated differently from the retail carton that reaches an end customer, and your declaration structure should reflect your actual distribution model.

Denmark: one front door

Denmark is administratively the friendliest of the group: Dansk Producentansvar (DPA) operates the producer registers for electrical equipment and batteries in one place, and packaging EPR — introduced in phases from 2024–2025 in line with EU requirements — is likewise administered through the DPA structure. Foreign producers without a Danish establishment appoint a local representative. For a brand entering the Nordics, Denmark’s consolidated register makes it a sensible first market operationally, whatever the commercial logic of the entry sequence.

Spain: newer packaging rules, formal representative requirement

Spain requires registration in the RII-AEE register for electrical equipment and, since Royal Decree 1055/2022, in a producer register for packaging, alongside battery producer registration. Non-Spanish companies act through an authorised representative. Spain’s packaging rules are newer than Germany’s or France’s and reporting expectations have been tightening year on year, so budget more lead time for the first declarations than the register’s formal deadlines suggest.

United Kingdom: same logic, separate universe

The UK sits outside the EU framework but runs directly comparable obligations, so nothing transfers: EU registrations have no validity in Great Britain. Producers of electrical equipment register through a producer compliance scheme with the environment agencies; battery producers join a battery compliance scheme; and the reformed packaging EPR (pEPR) requires packaging data reporting through the government service, with larger producers additionally paying disposal fees that began landing in 2025. UK thresholds are size-based — smaller producers face reduced obligations — so establish early which side of the thresholds your first-year volumes fall on, and note that “wheelie bin” labelling and data-reporting categories differ in detail from EU practice even where they look familiar.

Sequencing a multi-country launch

Registering in seven countries across three streams is around twenty separate administrative relationships. Importers who manage this well do three things. They sequence market entry, completing registrations for the first one or two markets before stock ships rather than retrofitting compliance after sales begin. They centralise the product data — one master file per SKU holding unit weight, battery data and packaging composition, maintained from manufacturer documentation, so every national declaration draws on the same numbers. And they decide early whether to run registrations in-house or through a pan-European compliance provider; providers cost money but collapse the twenty relationships into one, which is usually worth it beyond two or three markets.

All three habits depend on the same upstream input: complete, per-SKU manufacturer data. Part 3 sets out exactly what to request, and how to pre-empt the reporting problems that otherwise surface at the first annual declaration. For the wider certification picture behind market entry, see the Guide de conformité des vélos cargo de l'UE.

Foire aux questions

Which country should I register in first?

The one where you will first offer products for sale — the obligation attaches to offering on that national market, not to where your warehouse sits. If stock lands in Germany but first sales are in the Netherlands, Dutch registrations come first; if you sell on German marketplaces from day one, German numbers must exist before listings go live.Do I need an authorised representative in every country?

Do I need an authorised representative in every country?

Not in every country, but in several — France requires a mandataire for any company without a French establishment, Germany requires one for WEEE if you have no German branch, and Spain and Denmark have comparable requirements. The pattern: the further you are from having a local entity, the more likely a representative is mandatory.Are the fees significant?

Are the fees significant?

Fees are volume-based — per kilogram or per unit placed on the market — plus fixed register and scheme charges. For bikes the packaging stream is often the largest line because of per-unit packaging weight. The economically dangerous cost is not the fee schedule but late registration, which brings back-payments and potential fines on everything already sold.Does EU assembly change my EPR obligations?

Does EU assembly change my EPR obligations?

No — EPR attaches to placing products on a national market regardless of where they were assembled. Assembly location affects customs and duty treatment, which is a separate consideration in landed-cost planning.

Planning a multi-country launch? United Mobility works with brands entering several European markets in sequence and provides per-model documentation — unit weights, battery data sheets, packaging specifications — structured so the same file supports every national declaration. Discuss your market plan with us.