EU Packaging (PPWR) Authorised Representatives Guide

The Packaging and Packaging Waste Regulation (PPWR) 2025/40 requires that companies selling products in the EU appoint an authorised representative for extended producer responsibility in the EU member states where they themselves are not established.

In this guide, we explain what EU and non-EU companies must know about the new authorised representative for extended producer responsibility requirements.

• You may need an authorised representative for EPR in each EU member state
• The requirement applies where you make packaging available
• Applies to EU and non-EU companies
• Some companies offer AR EPR solutions covering all 27 EU member states

Definitions

The Packaging and Packaging Waste Regulation references two distinct types of authorised representatives, which are summarised in the table below.

	AR for EPR	AR
Scope	Fulfil the extended producer responsibility (EPR) and other obligations of that producer under Chapter VIII	Act on that manufacturer’s behalf in relation to specified tasks related to PPWR obligations Examples i. Keep DoC copy ii. Keep technical documentation copy iii. Respond to questions from national authorities Note: More information can be found in Article 17.
Appointed by	Producer	Manufacturer
Location	The EU member state/s where packaging or packaged products are made available for the first time* *Excluding the EU member state where the producer is established.	Any EU member state
Status	Required when making packaging/packed products available in (other) EU member states	i. Optional for EU companies ii. Often required for non-EU companies selling to consumers in the EU

In this guide, I primarily focus on requirements concerning authorised representatives for extended producer responsibility.

Who is a manufacturer?

• Manufactures the packaging or a packaged product
• Companies that design and brand products (made by other companies)
• EU packaging suppliers selling to micro-enterprises in the EU

Who is a producer?

The term producer includes several economic operators, including:

• Manufacturers
• Importers
• Distributor

Note that a manufacturer can simultaneously be a producer.

Additional information can be found in Article 3(13) and (15).

How do I know if we need packaging AR for EPR?

The following sections explain when an authorised representative for the extended producer responsibility is required under the PPWR.

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(123) On the other hand, when the packaging or the packaged product is made available by means of distance contracts directly to the end user, the producer could also be established in another Member State or in a third country. In such cases, if the producer is established in another Member State, it should appoint an authorised representative for the extended producer responsibility in the Member State where the end user is located.

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Point 123 of the Packaging and Packaging Waste Regulation states that companies defined as producers, located both in and outside of the EU, must appoint an EU AR in the Member States where their products are made available.

✅ Is your company defined as a producer?

✅ Are you based in the EU and making products available online to consumers in other EU member states?

✅ Are you based outside the EU and making products available online to consumers in EU member states?

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3. A producer referred to in Article 3(1), point (15)(c) and (d), shall appoint, by written mandate, an authorised representative for the extended producer responsibility in each Member State where the producer makes packaging or packaged products available for the first time, other than the Member State where the producer is established. Member States may provide that producers established in third countries shall appoint, by written mandate, an authorised representative for the extended producer responsibility when making packaging or packaged products available on their territory for the first time.

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This requirement is further clarified in Article 45, which covers extended producer responsibility.

Who is responsible?

Producers referred to in point 15(c) and (d):

	Point 15(c)	Point 15(d)
Producer	Manufacturer, importer, or distributor	Manufacturer, importer, or distributor
Producer location	EU or non-EU	EU or non-EU
Customer location	EU: Another EU Member State Non-EU: Any EU Member State	EU: Another EU Member State Non-EU: Any EU Member State
Scope	Packaging (single-use and reusable)	Products packaged in packaging
Conditions	i. Makes available for the first time on the territory of another EU Member State ii. Directly to end users, transport packaging, service packaging, or primary production packaging, whether as single-use packaging or as reusable packaging	i. Makes available for the first time on the territory of another Member State ii. Directly to end users, products packaged in packaging other than those referred to in point (c); or

EPR AR Requirements

✅ Appoint an EPR AR by written mandate

✅ Appoint an EPR AR in each member state where:

• The producer is not established
• You make packaging or packaged products available for the first time

Note: Non-EU companies are not established anywhere in the EU and therefore are requested to appoint an EPR AR in any EU member state where they sell their product.

EPR registration and reporting 

The information listed under Annex IX can be submitted by the producer or its EU authorised representative for extended producer responsibility to comply with the EPR requirements under Article 44.

Producer details

• Producer name and brand names
• Postal code and place
• Street and number
• Country
• Phone number
• Website
• E-mail address

Authorised representative details

• AR for the extended producer responsibility name
• Postal code and place
• Street and number
• Country
• Telephone
• E-mail address of the authorised representative

Code

• Producer national identification code
• Trade register number (or equivalent)
• European or national tax identification number

Declaration

• EPR declaration (Article 45)
• PRO certificate

Producer responsibility organisation details

• Name
• Postal code and place
• Street and number
• Country
• Telephone
• Web address and e-mail address
• PRO National identification code
• Trade register number (or equivalent)
• European or national tax identification number
• Represented the producer’s mandate,
• Statement by the producer/AR for the extended producer responsibility
• or the PRO stating that the information provided is true

List of Packaging EPR Authorised Representatives

AR for EPR	Coverage	Other
Lizenzero	EU-wide	Lizenzero offers packaging compliance solutions in all EU countries, including EPR AR. According to their website, their pricing starts at 499 Euros per country (299 from the second year).
Ecosistant	EU-wide	Ecosistant offers a wide range of EPR services, including EPR AR for packaging and other products.
Zentek	EU-wide	Zentek has offered recycling, sustainability, and EPR services since 1995, including packaging EPR AR.
Landbell Group	Germany, Austria	Landbell Group provides a global platform for EPR, offering packaging EPR AR and other services

FAQ

Do non-EU companies need an AR for packaging and EPR?

Yes, this requirement also applies to non-EU companies that have no entity within the European Union.

Does Amazon require that non-EU sellers have a packaging AR?

Yes, companies selling via Amazon in the EU and other marketplaces will also be required to appoint an authorised representative for extended producer responsibility.

Marketplaces are also obliged to monitor and verify that sellers have met certain obligations under the PPWR.

Do we need to appoint an authorised representative for EPR in each EU member state?

Yes, the PPWR states that producers must appoint an authorised representative for EPR in member states where they themselves are not established.

That being said, there are several companies offering EPR authorised representative solutions covering all EU member states. As such, you don’t necessarily need to appoint 27 different companies (assuming you sell EU-wide).

What is the difference between a producer responsibility organisation and an authorised representative?

A producer responsibility organisation, or PRO, is tasked with financially and/or operationally organising packaging waste collection and other PPWR obligations related to EPR

On the other hand, an authorised representative for the extended producer responsibility manages administrative tasks related to obligations under Chapter VIII of the PPWR.