BEYOĞLU PROFESSIONAL PPWR-EPR COMPLIANCE SERVICES
Free Workspace Check My EU Scope
PPWR-EPR  ·  Knowledge Hub  ·  EPR Representation  ·  Manufacturer AR vs EPR AR

Two Representatives · Two Different Jobs

Manufacturer AR and EPR AR are not the same thing.

Both contain the words “Authorised Representative”. That causes the confusion. One belongs to the Manufacturer / conformity side. The other belongs to the Producer / packaging EPR side.

Show Me the Difference Poland → Spain Example
20-second answer

Manufacturer AR works with the conformity file. EPR AR works with the country EPR file.

A Manufacturer Authorised Representative is appointed by the Manufacturer under PPWR Article 17 for specified conformity and authority-facing tasks. An EPR Authorised Representative is appointed by the Producer for extended producer responsibility obligations in a particular Member State.

Manufacturer → Article 17 AR → conformity / documents / market surveillance

Producer → Article 45 EPR AR → registration / EPR / reporting / country obligations

Start here

The representatives are different because Manufacturer and Producer are different roles.

Under PPWR, “Manufacturer” answers the conformity question. “Producer” answers the packaging-waste responsibility question. They can be the same business — but they do not have to be.

MANUFACTURER

Manufacturer

“Who is responsible for the packaging being compliant?”

The Manufacturer is the economic operator carrying the core PPWR conformity responsibility for the packaging or packaged product. Commission guidance describes this as one economic operator EU-wide.

Sustainability requirements
Labelling requirements
Conformity assessment
Technical documentation
EU Declaration of Conformity
PRODUCER

Producer

“Who carries packaging EPR responsibility in this Member State?”

Producer is the EPR role. It is determined according to the Member State, packaging flow and route to market. The Producer is responsible for the EPR obligations where that packaging is expected to become waste.

Country-specific role
Producer registration
EPR / PRO participation
Packaging quantity reporting
EPR financial contributions
Important: The same company can be the Manufacturer EU-wide and also become the EPR Producer in Spain, France, Germany, Czechia or another Member State depending on how it sells there.

Now compare the representatives

Same phrase. Different legal function.

PPWR ARTICLE 17

Manufacturer Authorised Representative

Acts for Manufacturer
Main purpose Specified packaging conformity and market-surveillance tasks
Geography Established within the European Union
One per destination country? No
Typical document role Keeps the EU Declaration of Conformity and technical documentation available to authorities as specified in the mandate
Producer register / PRO? Not the purpose of Article 17
Article 17 says a Manufacturer may appoint this representative by written mandate.
PPWR ARTICLE 45 · CHAPTER VIII

EPR Authorised Representative

Acts for Producer
Main purpose Extended producer responsibility for packaging waste
Geography Relevant destination Member State
Country-by-country? Yes
Typical work Registration, EPR system, reporting, contributions and evidence as applicable
Main public systems Producer register, EPR authority and national EPR / PRO infrastructure
Under the current Article 45(3) text, specified EU cross-border Producers selling directly to end users in another Member State shall appoint an EPR Authorised Representative there.

One visual rule

Manufacturer AR is an EU conformity role. EPR AR follows the EPR country.

Manufacturer AR
EU
Established within the Union. It is not automatically duplicated in every Member State where the product is sold.
VS
EPR AR
COUNTRY
The representative belongs to the specific Member State in which the relevant Producer EPR obligation arises.

Case Study 1

A Polish company makes its own glass decoration products and sells them directly to Spain.

The glass decoration is the product. The box, protective paper, insert, film, tape and shipping materials are the packaging. Now follow the two PPWR roles separately.

Company Established in Poland
Product Own-brand glass decoration
Packaging Retail + protective + shipping packaging
Sale Direct web sale to Spanish end user
🇵🇱
Polish Company Makes, packages and sells
→
📦
Packaged Product Travels from Poland to Spain
→
🇪🇸
Spanish End User Uses the product rather than reselling it
TRACK A · CONFORMITY

Manufacturer

Who is responsible for PPWR packaging conformity?
Under the assumptions in this example, the Polish own-brand company is the Manufacturer.
Selling to Spain does not create a new Manufacturer in Spain.
Manufacturer AR in Spain?
NO — not merely because the company sells into Spain.
Article 17 allows the Manufacturer to appoint an EU-established Authorised Representative by written mandate, but this is a separate conformity role.
TRACK B · PACKAGING EPR

Producer

Who carries the packaging EPR responsibility in Spain?
The Polish company makes the packaged product available directly to a Spanish end user.
It therefore becomes the relevant Producer in Spain for this direct cross-border flow.
Spanish EPR AR?
YES — under the current Article 45(3) framework.
The EPR representative belongs to the Spanish EPR relationship — not to the EU-wide Manufacturer conformity role.
One company · two answers

The Polish business is Manufacturer and Spanish Producer at the same time.

Manufacturer side Polish company
↓
EU conformity responsibility
↓
Manufacturer AR not automatically required
Spanish EPR side Polish company
↓
Producer in Spain
↓
Spanish EPR Authorised Representative

Case Study 2 · Importers

Same Turkish supplier. A German importer. A Polish importer. Three EPR outcomes.

Now use a more common SME example. Two European businesses buy the same packaged outdoor products from Turkey. One sells only in Germany. The other sells in Poland and directly to customers in Czechia.

Product

Packaged outdoor products

Camping accessories, trekking equipment, outdoor cooking accessories or similar products.

Assumptions

These facts matter to the result.

Turkish supplier uses its own brand.
Goods arrive in the EU already packaged.
EU buyers do not rebrand the goods.
Czech sales are direct to Czech end users.
🇹🇷
Turkish Outdoor Supplier Supplies its own branded packaged products
↓
🇩🇪
German Company Imports from Turkey and sells on the German domestic market. IMPORTER + GERMAN PRODUCER
🇵🇱
Polish Sole Trader Imports from Turkey into Poland and sells into two markets. IMPORTER
🇵🇱 Poland Domestic sales
🇨🇿 Czechia Direct end-user sales
M

Manufacturer

Who owns the PPWR conformity responsibility?

Under these assumptions, the Turkish supplier remains the Manufacturer of its own branded packaged product.

I

Importer

Who brings the packaged product from Turkey into the EU?

The German company is an Importer in Germany. The Polish business is an Importer in Poland.

P

Producer

Who carries EPR responsibility in each Member State?

This changes by market and sales route. The same Polish business can therefore be Producer in Poland and Czechia.

≠ AR

Importer does not mean Manufacturer Authorised Representative.

German company = Importer.

It has its own importer obligations under PPWR Article 18.
Polish business = Importer.

It also has Article 18 importer duties for the goods entering the EU through Poland.
Neither becomes Article 17 AR automatically.

Manufacturer AR status requires a separate written mandate from the Manufacturer.
Rebranding changes the analysis.

If an EU business places the packaging or packaged product under its own name or trademark, check Manufacturer status again.
🇩🇪
Route A

Turkey → German importer → German market

EPR AR: NO
1 Turkish supplier
2 German company imports
3 First German market supply
RESULT German company = Producer in Germany
Producer: The Germany-established company imports packaged products from a third country and first makes them available on the German market.
German EPR AR: Not required for this domestic German flow because the Producer itself is already established in Germany.
Manufacturer AR: The German importer is not automatically the Turkish Manufacturer's Article 17 representative.
🇵🇱
Route B1

Turkey → Polish importer → Polish market

EPR AR: NO
1 Turkish supplier
2 Polish business imports
3 First Polish market supply
RESULT Polish business = Producer in Poland
Polish EPR AR: Not required for its domestic Polish EPR relationship because the Producer itself is established in Poland.
🇨🇿
Route B2

Polish business → Czech end user

CZECH EPR AR
1 Business established in Poland
2 Direct cross-border offer / sale
3 Czech end user
RESULT Polish business = Producer in Czechia
Producer: The Polish business makes the packaged product directly available to an end user in another Member State. This is the Article 3(15)(d) cross-border producer pattern.
Czech EPR AR: Yes under the current Article 45(3) rule. The Producer established in Poland appoints, by written mandate, an EPR Authorised Representative in Czechia.
Czech Manufacturer AR too? No. Becoming Producer in Czechia does not create a second Manufacturer or a Czech Article 17 Manufacturer AR requirement.
SAME COMPANY · POLAND

Domestic Polish sale

Polish business imports and first makes the packaged products available in Poland.

Producer in Poland
Polish EPR AR: NO
SAME
BUSINESS
SAME COMPANY · CZECHIA

Direct Czech sale

The same Polish business sells directly to a Czech end user.

Producer in Czechia
Czech EPR AR: YES
Main lesson

A company does not have one permanent EPR identity for the whole EU.

German business Importer in Germany
+
Producer in Germany
+
German EPR AR: NO
Polish business · Poland Importer in Poland
+
Producer in Poland
+
Polish EPR AR: NO
Polish business · Czechia Cross-border seller
+
Producer in Czechia
+
Czech EPR AR: YES

Change one fact

What if the Polish business sells to a Czech reseller instead?

ROUTE

Direct-to-end-user becomes wholesale distribution.

The Polish business is now supplying an independent Czech reseller rather than the Czech end user. For the packaged-product flow in this simplified example, the Czech reseller can become the Producer when it first makes the packaged products available on the Czech market.

🇵🇱 Polish supplier → 🇨🇿 Czech reseller → Czech end user

So the Polish company's Czech EPR representative conclusion can change even though the physical product and packaging did not change.

BRAND

Change the brand and the Manufacturer analysis can change too.

Our importer example assumes the Turkish supplier's own brand. If the German or Polish buyer commissions the packaging or packaged product under its own name or trademark, check the PPWR Manufacturer definition again. Do not apply the importer example automatically to a private-label supply chain.

SME detail

Micro-enterprises have a special Manufacturer rule.

MICRO

Small business does not always mean the brand owner is the PPWR Manufacturer.

Article 3(13)(b) contains a specific exception where a micro-enterprise has packaging or a packaged product made under its own name or trademark and the packaging supplier is located in the same Member State. Where the statutory conditions are met, that packaging supplier is treated as the Manufacturer.

This exception changes the Manufacturer analysis. It does not remove the need to determine the EPR Producer separately for every relevant Member State.

Final comparison

Manufacturer AR and EPR AR in one table.

QUESTION MANUFACTURER AR EPR AUTHORISED REPRESENTATIVE
Legal basis PPWR Article 17 PPWR Article 45 / Chapter VIII
Acts for Manufacturer Producer
Main question Is the packaging compliant? Who operates packaging EPR in this country?
Main subject Conformity Packaging waste / EPR
Geography EU conformity role Member-State-specific EPR role
Representative location Established in the Union Established in the relevant Member State
Automatically required for every cross-border sale? No Can be mandatory; current Article 45(3) requires it for specified cross-border Producers
Technical documentation Authority-access role under mandate Not its core purpose
EU Declaration of Conformity Authority-access role under mandate Not its core purpose
Producer register Not Article 17's purpose Relevant to EPR role
PRO / EPR system No Yes, where applicable
Packaging quantities Not an EPR declaration role Used for EPR reporting
EPR contributions No Part of EPR framework
Does Importer automatically equal this AR? No No — Producer status and representation must be determined separately

Remember only this

“Conformity file” versus “country EPR file”.

FILE A

Packaging Conformity File

Manufacturer
↓
Article 17 Manufacturer AR

≠
FILE B

Country EPR File

Producer
↓
Article 45 EPR Authorised Representative

Primary Sources

The two roles come from different parts of PPWR.

BINDING EU LAW Regulation (EU) 2025/40 — PPWR COMMISSION GUIDANCE C/2026/3084 — Manufacturer and Producer interpretation GERMANY ZSVR — Distinguishing Manufacturers and Producers EU27 Official authorities, registers and EPR systems →

Simple FAQ

The questions that cause most of the confusion.

Is Manufacturer Authorised Representative the same as EPR Authorised Representative?

No. Manufacturer AR belongs to the Article 17 conformity role. EPR Authorised Representative belongs to the Producer's Chapter VIII extended producer responsibility role.

Is a Manufacturer AR mandatory just because I sell in another EU country?

No. Article 17 says the Manufacturer may appoint an Authorised Representative by written mandate. Cross-border sales do not themselves create one Manufacturer AR per destination country.

Is an EU importer automatically the foreign Manufacturer's AR?

No. Importer and Manufacturer Authorised Representative are separate PPWR roles. The Importer has its own Article 18 obligations. Manufacturer AR status requires a separate written mandate.

Can an importer also be the EPR Producer?

Yes. A company established in a Member State that imports packaged products from a third country and first makes them available in that Member State can be the Producer there.

Why does the German importer not need a German EPR AR?

In our example the German company itself is the Producer and is already established in Germany. The EPR relationship is therefore operated by the Germany-established Producer rather than by a foreign Producer through a German representative.

Why can the Polish business need an EPR AR in Czechia?

Because it is established in Poland but directly makes packaged products available to end users in Czechia. Under the current Article 45(3) framework, the resulting Czech Producer relationship requires an EPR Authorised Representative in Czechia.

What if the Czech buyer is a reseller?

The EPR result can change. Where the Polish company supplies an independent Czech reseller rather than the end user, the Czech reseller can become the Producer when it first makes the packaged products available on the Czech market.

Can one business be Producer in more than one Member State?

Yes. Producer is a Member-State-specific EPR role. A Polish business can be Producer in Poland for domestic sales and also be Producer in Czechia for direct cross-border sales to Czech end users.

Does private label change the result?

It can change the Manufacturer analysis. If the EU business has packaging or a packaged product designed or manufactured under its own name or trademark, the PPWR Manufacturer definition must be checked again.

Can the Manufacturer AR take over all Manufacturer duties?

No. Article 17 keeps core Manufacturer obligations, including the Article 15(1) obligations and drawing up the Annex VII technical documentation, outside the representative's mandate.

Do not start with “Which representative do I need?”

First identify the Manufacturer. Then the Importer. Then determine the Producer in each destination country. Only after that can the correct representative question be answered.

Check My EPR Representation EPR Representation Guide Open Free Workspace
Error get alias