EPR Authorised Representative
Sometimes yes. But do not start with the representative. Start with one simple question: Who is the producer in that country?
The Producer appoints the representative in writing. The representative is established in the relevant EU country and performs the EPR duties covered by the law and mandate. The Producer does not disappear. The representative performs the local EPR work.
Meet the four actors
Most confusion comes from mixing these roles together. Keep them separate.
The business that carries the packaging EPR responsibility in that Member State.
Main question: “Who is responsible?”The locally established person or company appointed for the applicable EPR duties.
Main question: “Who acts locally?”The authorised organisation or system that performs waste-management functions and collects EPR contributions.
Main question: “Who runs the EPR system?”The public body or statutory system that registers, supervises or receives regulatory information.
Main question: “Who checks compliance?”Very important
They sound similar. They solve completely different problems.
This representative acts for the Manufacturer on specified PPWR conformity tasks.
This representative acts for the Producer on extended producer responsibility duties under PPWR Chapter VIII.
We explain Manufacturer, Importer and Producer separately, then use real business cases: a Polish manufacturer selling to Spain and Turkish outdoor products imported into Germany and Poland.
Rule number one
Simple decision tree
Use these questions in this order.
Producer is a legal EPR role. It does not simply mean factory or Manufacturer.
Do not use only a VAT number to answer this. Look at the actual legal establishment and business structure.
Under the current PPWR Article 45(3) text, Producers in Article 3(15)(c) and (d) appoint an EPR representative by written mandate in each relevant other Member State.
PPWR does not give one automatic answer for all third-country Producers. The destination Member State's current national rule must be checked.
An end user can be a company. If a bakery, factory, hotel, workshop or office buys your product and uses it itself, it can be a professional end user. If the buyer resells the product in the form supplied, that is a different supply-chain situation.
See the difference
Same type of packaging. Different commercial route. Different EPR result.
The foreign company sells directly to the German end user. Under Germany's current rule, a foreign Producer without a German branch must appoint an EPR Authorised Representative.
The customer is a business, but it uses the product itself. A professional business can be an end user. Do not treat every B2B transaction as wholesale resale.
Do not jump straight to the AR question. First determine who first makes the packaging or packaged product available in France under the actual distribution flow.
Germany's current mandatory foreign-seller rule is framed around companies selling directly to German end users without a German branch. Legal establishment therefore matters.
One common mistake
Packaging EPR is operated country by country. Representation follows the relevant Member State.
Real country examples
These four examples show why you must check the destination country.
Who does what?
A representative cannot report correct numbers if the Producer does not provide correct data.
Two flows
Wrong packaging data in means wrong regulatory data out. Representation does not remove the Producer's obligation to provide accurate information.
EPR contributions and authority charges are regulatory costs. They are separate from the representative's commercial service fee.
What an EPR AR does not do
The representative performs duties. The Producer remains the Producer.
EPR representation is connected to the relevant Member State.
Packaging, sales and company information must come from the Producer.
Article 17 Manufacturer representation and Article 45 EPR representation are separate legal functions.
Compare the two roles →The European Commission proposed COM(2025) 982 to suspend Article 45(3) until 1 January 2035. As of our 28 August 2026 review, the document remains a legislative proposal. Proposed wording must not be treated as adopted law.
What should I do?
Who carries EPR responsibility for this exact sale?
In which Member State does the EPR obligation arise?
Does current EU and national law require a local EPR AR?
Use the written appointment required by that country.
Registration, EPR system, reporting, payments and evidence.
Primary sources
EPR Representation FAQ
A person or company established in the relevant Member State and appointed in writing to perform the Producer's applicable packaging EPR duties.
No. First determine whether the seller is the Producer. For third-country Producers, the current destination-country rule must then be checked.
There is no automatic single EU-wide EPR representation. The relevant Member State and its rules must be checked.
No. Article 17 concerns the Manufacturer's Authorised Representative for specified conformity tasks. Article 45 concerns EPR representation for the Producer. These are separate legal roles. See the full Manufacturer AR vs EPR AR comparison with practical cases →
No. A business can be a professional end user. The important question is whether it uses the product itself or makes that product further available in the form supplied.
No. The Producer remains the Producer. The representative performs the EPR obligations covered by the applicable law and written mandate.
No. Under the current German rule, LUCID producer registration remains the Producer's own duty. The representative performs the other applicable EPR obligations.
No. As of 28 August 2026, COM(2025) 982 is a legislative proposal. The current PPWR text and current national rules remain the basis for today's compliance decisions.
First determine whether you are the Manufacturer, Importer or EPR Producer. Then determine whether the destination country requires an EPR Authorised Representative.