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EPR Authorized Representative 2026: When You Need One Under the PPWR and National Law
An EPR authorized representative is a person or company established in a member state who fulfils a producer's EPR obligations there. Since 12 August 2026, Art. 45 PPWR requires one for every producer, EU or non-EU, that sells packaged products directly to end users in another member state. Germany, France, Austria, Belgium and other countries add their own rules for packaging, WEEE and batteries.
Last reviewed: · Sources linked below
Authorized representative at a glance
- Legal basis (packaging)
- Art. 45 of the EU Packaging Regulation (PPWR, Regulation (EU) 2025/40), applicable since 12 August 2026.
- Who must appoint one
- Producers selling packaged products directly to end users in another member state (distance sellers), whether established in the EU or outside it.
- Where
- In each member state where they first make packaging available, other than their own.
- Other non-EU producers
- Member states may require an authorized representative; this depends on the country.
- Germany
- § 5 VerpackDG: only producers without a German branch who sell directly to end users in Germany. Only one AR; contract in German.
- France
- "Mandataire" required since 10 July 2026 for all producers not established in France, EU and non-EU, all EPR streams.
- Exemption?
- Proposal – not yet law The omnibus would exempt some EU-established producers. It does not help non-EU sellers.
The authorised representative under PPWR Art. 45
Under Art. 45 PPWR, producers who sell packaged products directly to end users in another member state must appoint an authorised representative for extended producer responsibility in each member state where they first make packaging available, other than their own. This applies whether the producer is established in another EU country or outside the EU.
The PPWR describes these producers as distance sellers (Art. 3(1)(15)(c) and (d)): they supply packaging or packaged products by means of distance contracts directly to end users in a member state where they are not established. The Regulation entered into force on 11 February 2025 and has applied since 12 August 2026.
Common misconception: "Only non-EU producers need an authorized representative in every member state" is wrong. The PPWR duty depends on selling directly to end users in another member state. An EU company shipping to consumers abroad is covered too. For non-EU producers that do not sell directly to end users, member states may require a representative, so it depends on the country.
While an exemption is being negotiated, the European Commission has asked member states to enforce the AR duty "in a constructive and pragmatic" way. That is guidance on enforcement, not an exemption: the duty applies.
Do I need an authorized representative? Typical scenarios
The decisive questions are where you are established and whether you sell directly to end users in the destination country.
| Scenario | Packaging AR in the destination country? |
|---|---|
| Polish online shop shipping to consumers in Germany | Yes: distance seller under Art. 45 PPWR; in Germany § 5 VerpackDG (no German branch, sells directly to end users) |
| US or Chinese brand selling to consumers in France via its own web shop | Yes: Art. 45 PPWR, plus the French "mandataire" duty for all EPR streams |
| German company selling to consumers in Germany | No: the PPWR duty applies only in member states other than your own |
| Non-EU manufacturer supplying an importer, not end users | Depends on the country: member states may require an AR for other third-country producers |
| Seller not established in France selling through a France-established marketplace that handles compliance under L. 541-10-9 | France: mandataire duty deemed met. Other countries: check separately |
Germany: § 5 VerpackDG, ElektroG and BattDG
In Germany, packaging producers need an authorized representative only if they have no German branch and sell directly to end users in Germany (§ 5 VerpackDG, since 12 August 2026). The VerpackDG, together with the PPWR, replaced the VerpackG on that date.
- Only one AR: a producer can appoint only one authorized representative in Germany.
- Contract in German: the appointment contract must be in German.
- LUCID: the producer enters the AR in LUCID; the appointment becomes effective once the AR confirms it.
- Registration stays with the producer: the LUCID registration remains in the producer's name. LUCID registration with the ZSVR is free of charge.
For electrical and electronic equipment, producers without a German establishment need an authorized representative (Bevollmächtigter) for their stiftung ear registration; stiftung ear charges €50.60 net for the AR confirmation. For batteries, producers without a German establishment register with stiftung ear via an authorized representative. Details: LUCID registration, WEEE registration, battery registration.
France: the "mandataire" under Loi n° 2026-602
Since 10 July 2026, every producer subject to EPR in France that is not established in France must appoint a France-established "mandataire" by written mandate. According to law-firm analyses and a French producer responsibility organisation, this follows from Loi n° 2026-602 of 8 July 2026 (published in the JORF on 9 July 2026), which inserted Art. L. 541-10-9-1 into the Code de l'environnement.
- Who: EU and non-EU producers without an establishment in France.
- Which streams: all EPR streams, not only packaging. France has around 20 EPR streams (filières REP).
- Marketplace exemption: the duty is deemed met where a France-established marketplace handles compliance under L. 541-10-9.
- UIN: independently of the mandataire, each stream needs its own UIN from ADEME (SYDEREP).
More on France: EPR in France 2026.
Is a local representative required? Country overview
Representative rules differ by country and by stream; for packaging, Art. 45 PPWR applies EU-wide to distance sellers on top of national rules. "Check with us" marks details we have not yet verified against an official source.
| Country | Packaging | WEEE | Batteries |
|---|---|---|---|
| Germany | Yes, if no German branch and selling directly to end users (§ 5 VerpackDG) | Yes, without German establishment | Yes, without German establishment |
| France | Yes, mandataire for all producers not established in France (since 10 Jul 2026) | Yes, mandataire (all EPR streams) | Yes, mandataire (all EPR streams) |
| Italy | Yes: Italy-based representative (Italian VAT number and PEC) for sellers without Italian establishment; B2C distance sellers need an AR under the PPWR | Check with us | Check with us |
| Spain | Yes: representante autorizado for producers established in another EU state or a third country | Check with us | Check with us |
| Poland | Art. 45 PPWR for distance sellers; national details: check with us | Check with us | Check with us |
| Netherlands | Art. 45 PPWR for distance sellers; national details: check with us | Check with us | Check with us |
| Belgium | Yes: foreign producers need an AR established in Belgium and registered with EPRiBEL (since 12 Aug 2026) | Check with us | Check with us |
| Austria | Yes: Bevollmächtigter for foreign distance sellers to private consumers (§§ 16a–16e VVO) | Yes: Bevollmächtigter for foreign distance sellers (§ 12a AWG, §§ 21a–c EAG-VO) | Yes: Bevollmächtigter for foreign distance sellers (§ 12a AWG) |
| Sweden | Yes for EU-established producers ("auktoriserat ombud", since 12 Aug 2026); non-EU distance sellers: check with us | EU distance sellers: Sweden-established representative; non-EU sellers may register directly | EU distance sellers: Sweden-established representative; non-EU sellers may register directly |
| Czech Republic | Art. 45 PPWR for distance sellers; authorized representatives report to EKO-KOM | Check with us | Check with us |
| Denmark | According to DPA: EU companies need a Danish AR; non-EU companies may register directly | Check with us | Representative required, also for non-EU companies |
| Portugal | Yes for foreign distance sellers to end users (since 1 Jan 2022) | Yes for foreign distance sellers to end users (since 2018) | Yes for foreign distance sellers to end users (since 1 Jan 2022) |
| Ireland | Check with us | Yes: Irish AR for distance sellers outside Ireland | Yes: Irish AR for distance sellers outside Ireland |
| United Kingdom | Check with us (outside the EU; PPWR does not apply) | Check with us | Check with us |
Registers and numbers per country: EPR numbers by country. Marketplace requirements: Amazon & eBay EPR numbers.
The omnibus exemption: what is proposed Proposal – not yet law
The EU is negotiating an exemption from the AR duty for certain EU-established producers, but it is not law, and none of the versions on the table helps non-EU sellers. Until a final text is adopted and in force, Art. 45 PPWR applies as written.
| Step | Date | Content |
|---|---|---|
| Commission proposal (Environmental Omnibus, COM(2025) 982) | 10 Dec 2025 | Suspend the AR duty for EU-established producers |
| European Parliament position | 20 Oct 2026 | Exemption for EU micro and small enterprises until 2035 (as reported by Packaging Europe) |
| Council negotiating position | 21 Oct 2026 | EU-established producers placing under 1 tonne of packaging per year in another member state would not need an AR there; suspension until 2032 |
| Next step | Pending | Trilogue between Parliament, Council and Commission |
- Does not help non-EU sellers: all versions concern EU-established producers only. A US, UK or Chinese seller shipping to EU consumers still needs an authorized representative.
- Batteries: Proposal – not yet law the omnibus would also suspend the AR duty under the Battery Regulation; Parliament voted on 20 October 2026, the Council position is pending.
- National rules: national duties such as the French mandataire or the Austrian Bevollmächtigter are set in national law and remain in force unless that national law is changed.
Follow the timeline on PPWR 2026 on epr-obligation.eu and the EPR deadline calendar.
What an authorized representative does and what it is liable for
An authorized representative carries out the producer's EPR obligations in the country where it is appointed and is the contact point for the authorities there. The exact scope and liability follow from the national law and from the mandate between producer and representative.
- Appointment: by written mandate or contract (France: written mandate; Germany: contract in German).
- Registration: registers the producer or confirms the appointment in the national register (in Germany the AR confirms in LUCID, while the registration stays with the producer).
- Schemes and fees: organises participation in the required scheme or producer responsibility organisation.
- Reporting: submits or supports quantity reports and declarations on time.
- Authority contact: receives requests from authorities and answers them on the producer's behalf.
Because the representative takes on obligations towards the authorities, it needs reliable data from the producer: product lists, packaging weights by material, sales volumes per country. Penalties for missing registrations are set nationally; in Germany, for example, fines under § 66 VerpackDG reach up to €200,000 depending on the offence, with PPWR-related fines applying from 12 February 2027.
How Certify acts as your authorized representative
Certify GmbH acts as authorized representative in all EU member states. One partner for packaging, WEEE and batteries covers your registrations, your representative duties and your reporting.
- Free first consultation, no obligation. We check in which countries and for which streams you need an authorized representative, based on your products and sales channels.
- Mandate and registration. Certify is appointed as your representative and handles the registrations and confirmations in the national registers.
- Ongoing compliance. Quantity reports, scheme participation and deadlines are managed in one place, and your EPR numbers are ready for Amazon and eBay.
FAQ: EPR authorized representative
What is an EPR authorized representative?
An EPR authorized representative is a person or company established in a member state who carries out a producer's extended producer responsibility obligations there, such as registration, scheme participation and reporting, and acts as the contact for the authorities.
Who needs an authorised representative under the PPWR?
Under Art. 45 PPWR, producers who sell packaged products directly to end users in another member state must appoint an authorised representative in each member state where they first make packaging available, other than their own. This applies to EU and non-EU producers alike.
Do non-EU sellers need an EPR authorized representative?
Yes, if they sell directly to end users in an EU member state. For other non-EU producers, member states may require one. The omnibus exemption under discussion would not change this for non-EU sellers.
Do EU companies need an authorized representative in other EU countries?
Yes, if they sell packaged products directly to end users in another member state. Some countries also have national rules, for example France requires a mandataire for every producer not established in France, and Sweden requires an auktoriserat ombud for EU-established producers.
Is the authorized representative duty being abolished for small businesses?
Not yet. It is a proposal: the Council position of 21 October 2026 would exempt EU-established producers placing under 1 tonne of packaging per year in another member state until 2032, and the European Parliament voted on 20 October 2026 for an exemption for EU micro and small enterprises until 2035. Trilogue negotiations follow. It is not law and does not help non-EU sellers.
Do I need an authorized representative in Germany?
For packaging, only if you have no German branch and sell directly to end users in Germany (§ 5 VerpackDG). You can appoint only one, the contract must be in German, and your LUCID registration stays in your name. For WEEE and batteries, producers without a German establishment need one.
Can one company be my authorized representative in several countries?
Yes. A service provider can act as your representative in several member states, provided it meets each country's requirements. Certify GmbH offers authorized representation in all EU member states.
- Regulation (EU) 2025/40 (PPWR), Art. 3 and Art. 45 – EUR-Lex
- European Commission – EPR for packaging and small businesses
- Council of the EU – Press release of 21 October 2026
- Packaging Europe – Parliament vote of 20 October 2026
- ZSVR – Authorising a representative
- VerpackDG – gesetze-im-internet.de
- stiftung ear – Costs and fees
- Légifrance – Loi n° 2026-602 du 8 juillet 2026
- Gossement Avocats – Analysis of Loi n° 2026-602
- Fost Plus – Mandatory registration in the producer register
- USP Austria – Authorized representatives for packaging
- Naturvårdsverket – New national rules following the PPWR
- APA Portugal – FAQ authorized representative
- EPA Ireland – Guidance for distance sellers of EEE and batteries
This page is general information, not legal advice. Last reviewed 27 October 2026.
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