With the EU Packaging Regulation (PPWR) set to take effect on August 12, 2026, cross-border trade is facing profound changes.
What is an EPR Authorized Representative for packaging?
An EPR Authorized Representative (AR) is a person based in the EU. The manufacturer appoints this person in writing to ensure that the manufacturer’s Extended Producer Responsibility (EPR) obligations are fulfilled in a legally compliant manner in the respective destination country.
The most important changes at a glance
- Requirement for non-EU companies: Starting in August 2026, online retailers without an EU headquarters must appoint a local authorized representative for each EU country of delivery (B2C).
- Planned exemptions for EU companies: An exemption or limitation until 2035 is under discussion for companies based in the EU (final decision not yet made). Since the decision may take several more months, the AR requirement remains in effect for all companies not based in the destination country for the time being.
- No centralization: EPR registration and licensing remain mandatory on a country-by-country basis through national registries and take-back systems.
Current Status: Mandatory or Voluntary?
Until the PPWR takes effect, the legal situation in the EU remains inconsistent:
- Already Mandatory: In Austria, Spain, Greece, and Denmark, among other countries, foreign merchants are already required to appoint an AR.
- Still optional: In countries such as Germany and Bulgaria, appointing an AR is currently still voluntary for EU companies.
The process starting in August
Written mandate: A contract governs the representation. The AR must be based in the destination country and assumes full legal and financial liability.
EPR registration: The authorized representative registers the company with the national authorities. Important exceptions: In countries such as Germany (LUCID Register), initial registration remains the manufacturer’s personal responsibility. In addition, many EU member states require that contracts with take-back systems (PROs) continue to be signed by the company itself.
Reporting: The authorized representative submits packaging volumes and material data. Recycling fees are now calculated strictly based on recyclability.
Availability of Documentation: The authorized representative keeps the declaration of conformity and all required technical EPR and product documentation available for the authorities.
Conclusion
Companies must adapt their EPR strategy early on to avoid sales bans and hefty fines.
How is your company preparing for the requirements of the PPWR?
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