What an authorised representative is — and isn't

Who actually needs one

Art. 45(3) PPWR has two sentences, and the difference between them is the whole answer.

You're established in one EU member state, selling into another

Mandatory, directly. The first sentence of Art. 45(3) applies EU-wide with no national choice involved: a producer established in another member state must appoint an authorised representative in the country it's selling into. This is the exact case a lot of the traffic looking for this page is asking about, and there is no threshold that gets you out of it.

You're established outside the EU

A national option, not an EU default. The second sentence lets each member state decide whether to extend the duty to third-country producers. Germany and France have both plainly taken it. Whether all twenty-seven have is not published anywhere as a single list — see the relevant country desk for what we've confirmed state by state, and treat an unconfirmed country as owing one until proven otherwise.

You sell only within your own member state

Not caught by Art. 45(3). You still register as a producer and join a scheme there — you just don't need a representative for that domestic sale.

What the job actually is

The representative takes on the producer's EPR duties in the destination country under a written mandate. In practice, across the desks we've built so far, that consistently means:

Registration

Opening and holding the entry in the national register of producers, in the producer's name.

Scheme membership and fees

Joining or arranging membership of the relevant compliance scheme, and paying the eco-modulated fees on the packaging actually placed on that market.

Reporting

Filing the tonnage and material reports on the schedule the national register sets — annually in most places, more often in a few.

Being reachable

Acting as the point of contact the national authority deals with, since the producer itself has no presence there.

None of this transfers legal responsibility away from the producer — a written mandate delegates the work, not the liability. What it buys is a local address and a local signature on documents that a national register otherwise has no way to accept from a company with no presence in the country.

One per country, not one for the EU

There is no single-window version of this. A representative appointed in Germany covers Germany. Selling into Austria, France and Belgium as well means three more mandates, three more registrations, three more fees — the same duty, repeated per market, because each national register is a separate legal relationship. This is the fragmentation the PPWR's own harmonisation provisions chip away at on the procedure side (shared formats, aligned deadlines) without removing: the requirement to have twenty-seven potential representatives is one article; having twenty-seven separate people to find, vet and pay is what's actually underneath it.

Who can act as one

A company established in the destination member state — but "willing to sign" is not the same as "qualified to act." Belgium is the clearest example we've documented: a representative there has to be registered with EPRiBEL in its own right. A Belgian company that signs a mandate but isn't itself on that register doesn't discharge the duty — the producer has paid for a mandate that does nothing. See the Belgium desk for the full mechanics. Whether every member state runs the same "the representative must itself be registered" check, or leaves it looser, is not something we've mapped country by country yet — verify it for the specific state before you sign anything.

What it costs

The recycling fee itself is usually small and weight-based — ship a little packaging, pay a little. The representative's fee is not weight-based in the same way: it is closer to a flat charge for being available, being registered, and doing the paperwork, and it costs roughly the same whether you ship one parcel a year into a country or a thousand. That flat structure is what turns a few hundred euros of cross-border sales into a loss, and it is the actual reason small sellers have been pulling out of markets rather than the recycling fee itself.

The other "authorised representative"

Here's a genuine trap, and it's the Regulation's own doing: "authorised representative" names two different jobs in the PPWR, and the Commission's FAQ uses the same phrase for both without ever flagging that it's doing so.

The one this page is about

Art. 45(3) — appointed by a producer, for EPR: registration, fees, reporting, in a country the producer isn't established in. This is the one every country desk on this site covers.

The other one

Art. 17(2) — appointed by a manufacturer, for conformity: it can draft the EU declaration of conformity and hold the technical documentation on the manufacturer's behalf. This has nothing to do with EPR and doesn't touch a national producer register at all. See manufacturer or producer? for the role it sits inside.

Sources

1. Regulation (EU) 2025/40 (PPWR) — EUR-Lex Read in full for this page. Source for Art. 45(3) first and second sentences, Art. 45(4) on marketplaces paying fees under mandate, and Art. 17(2) on the manufacturer's conformity representative
2. European Commission — PPWR Frequently Asked Questions, 2nd edition DG ENV Unit B01, August 2026 (KH-01-26-068-EN-N). Source for the confirmation that an online platform cannot register or report on a producer's behalf unless appointed as authorised representative, and for the Art. 17(2) description of the manufacturer's conformity representative that this page distinguishes from the EPR one. See our own note on this document
3. KontorBund — Belgium desk Source for the EPRiBEL self-registration requirement on the representative
4. KontorBund — Germany desk Source for Germany taking the third-country option in Art. 45(3)'s second sentence

Help us finish this page

The open question is which member states have taken the third-country option in Art. 45(3)'s second sentence, and which haven't — nobody has published that as a single list, so we're building it one desk at a time. If you've confirmed a country's position, tell us and we'll add it.