Free Representation Utility
Check whether your EPR position requires a country-level representative.
Authorised representation depends on who the producer is, where that producer is established, how the product reaches the destination market and whether the Member State has activated a national rule for third-country producers.
Check the representation position
Answer for one destination Member State at a time.
What is your current producer position?
An EPR authorised representative is relevant only if your business is the producer for the destination Member State.
Which Member State are you checking?
Representation is a country-level relationship.
Where is the producer established relative to this country?
This determines whether the PPWR's direct cross-border rule or a third-country national rule must be used.
Who receives the packaged product in the destination country?
Direct-to-end-user sales and sales to an independent importer or reseller can produce different legal results.
Do you have a local legal presence in the destination country?
A branch or separately incorporated subsidiary can change both establishment and producer analysis.
PPWR legal logic
“Foreign seller” is not enough information to answer the question.
Producer status, establishment, destination and recipient must be resolved before the representation rule is applied.
Cross-border EU producer
A producer within Article 3(15)(c) or (d) must appoint an EPR authorised representative in each Member State where it makes packaging or packaged products available for the first time, other than the Member State where the producer is established.
Regulation (EU) 2025/40 ↗National implementation matters
Article 45 also allows Member States to require third-country producers to appoint a country-established EPR authorised representative. That national rule must therefore be verified rather than assumed.
Importer and reseller routes must be separated
If an independent EU importer or reseller receives the packaged goods and then makes them available, the producer position may differ from a direct end-user distance-sale model.
Open Producer Status Checker →Verified country roles
The representative's job is not the same in every national system.
Country service specifications must define both what transfers to the representative and what remains personally with the producer.
Germany
VERIFIEDFor a foreign company without a German branch that sells directly to German end users, representation is mandatory under the current post-12-August-2026 framework.
France
VERIFIEDA person that is not established in France and is subject to EPR must appoint a France-established mandataire by written mandate.
Austria
VERIFIEDForeign distance sellers supplying packaging to Austrian private final consumers must appoint an Austrian-established authorised representative.
Spain
VERIFIEDForeign operators that become the producer through first direct marketing to Spanish end users must appoint a representative in Spain for EPR purposes.
Continue the workflow
Connect representation to the rest of the compliance account.
EPR representation FAQ
Separate the representative requirement from the producer question.
No blanket EU-wide answer should be assumed for every third-country seller. PPWR Article 45 requires country-level analysis, and Member States may impose national authorised-representation requirements on third-country producers.
Not automatically. EPR authorised representation is linked to the Member State where the producer makes packaging or packaged products available. Mandates and national compliance accounts therefore remain country-specific.
Under the current German framework, the representative assumes the foreign producer's EPR obligations except the producer's personal initial LUCID registration and changes to its registration master data.
Not by itself. If the seller remains the producer and sells directly to end users through a marketplace, the marketplace channel does not automatically remove country-level EPR or representation obligations.
Producer status may shift depending on the transaction, destination and who first makes the packaged product available. Resolve the producer position before concluding that the foreign seller needs an EPR authorised representative.