Question
What is an authorised representative, and do I need one?
Reviewed 2026-08-15
Short answer
Someone established in a country who takes on your EPR duties there. Needed in any member state where you are not established.
Who it catches
- You need a representative in any EU country you sell into but are not based in.
- That includes sellers based in the EU selling to other EU countries, not just sellers outside it.
- Sellers in Great Britain and Northern Ireland count as being outside the EU for this.
Key practicalities
- One per country, not one for the whole EU.
- You appoint them in writing.
- They do the paperwork, but you are still responsible for it being right.
- France and Spain already required this before the new EU rules came in.
The proposed suspension
- A proposal would have paused this until 2035, but only for businesses based in the EU.
- Sellers outside the EU, including the UK, were never covered by it.
- Talks on it were dropped on 24 June 2026 after most EU countries objected.
- Do not count on it.
Sources
- PPWR Article 45 — extended producer responsibility and authorised representatives
- Environmental Omnibus proposal COM(2025) 982 final — would suspend Art. 45(3) for EU-established producers only; Council negotiations discontinued 24 June 2026
- France — Citeo (household packaging PRO)
- Spain — MITECO Registro de Productores de Producto
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