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Does a warehouse or VAT number in a country make me established there for EPR?

Generally no: stock at Amazon or a 3PL, or a VAT number, is not an establishment; you still need a representative there.

By Razvan Toma · Founder · Last checked 21 October 2026 · Sources below

Generally no. A local VAT registration, or stock in Amazon's or a logistics provider's warehouse, does not make your company established in that country. In Germany, § 5(2) VerpackDG asks whether you have an establishment (Niederlassung) there, and stock in someone else's warehouse is not one; the French and Italian sites reach the same answer under their law. So the obligations follow where you sell, and the representative duty still applies.

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