The proposed Article 45(3) suspension is not silently treated as law.
The engine records procedure 2025/0395(COD) as a proposal status and keeps current Article 45(3) logic active until an adopted legal act changes the applicable rule.
EU27 EPR Authorised Representative Appointment Engine
Determine the EPR representation route. Prepare the appointment correctly.
Assess the current PPWR Article 45(3) route, apply destination-country formalities, prepare the Producer and representative data, collect evidence and generate a country-aware appointment preparation pack without presenting a draft as a legally effective appointment.
Current Article 45(3) boundaryEU27 country adapters11 researched appointment/PoA recordsBrowser-local evidenceSHA-256 evidence hashesA4 appointment PDF
Direct answer
What is an EPR Authorised Representative appointment under the PPWR?
For the PPWR Chapter VIII EPR role, the Producer appoints a person or entity established in the relevant Member State to fulfil specified extended-producer-responsibility obligations. Article 45(3) currently requires certain cross-border EU Producers to make that appointment by written mandate in each destination Member State other than their Member State of establishment; Member States may also impose the requirement on third-country Producers.
COM(2025) 982 / 2025/0395(COD) proposes suspending Article 45(3) until 2035. A legislative proposal is not applied here as current law unless it is adopted and enters into force.The engine stores structured data in the site's local Public Workspace and evidence files in this browser's IndexedDB. It does not treat generated files as submitted or accepted.
Legal boundary
Article 45 EPR representation is not Article 17 manufacturer representation.
Article 45(3) concerns the EPR Authorised Representative for Chapter VIII producer-responsibility obligations. Article 17 concerns a manufacturer's separate technical/conformity authorised representative. The principals, tasks and documents are not interchangeable.
Generated ≠ signed ≠ accepted ≠ legally effective.
A generated appointment draft, a signed document, a portal-accepted appointment and a legally effective representation are separate states.
EU27 execution map
The written appointment is executed differently across Member States.
This matrix combines current EU-law logic with the national execution/formality status verified for each Member State. A review state is deliberate: it prevents the engine from inventing a national form or legal effect where the primary-source procedure is not yet mapped.
Austria AT
National rule- Route
- EDM / ZAReg
- Appointment mechanism
- Certified written authorisation
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Producer signature required · Written acceptance by the representative
- Research records
- 2
Belgium BE
National review- Route
- EPRiBEL transition + packaging organisations
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
Bulgaria BG
National review- Route
- National packaging EPR route
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
Cyprus CY
National review- Route
- Cyprus packaging EPR / applicable system
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
Czechia CZ
Current EU-law route- Route
- Czech packaging EPR / EKO-KOM
- Appointment mechanism
- Written appointment agreement
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Producer signature required · Written acceptance by the representative
- Research records
- 0
Germany DE
National rule- Route
- LUCID Packaging Register
- Appointment mechanism
- Written appointment agreement
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Only one EPR Authorised Representative for the route · German-language version controls
- Research records
- 2
Denmark DK
National rule- Route
- Danish producer register
- Appointment mechanism
- Portal request and acceptance
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Danish CVR for representative · Appointment request made through portal
- Research records
- 1
Estonia EE
National rule- Route
- Estonian packaging EPR route
- Appointment mechanism
- Written authorisation + written acceptance
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Producer signature required · Written acceptance by representative
- Research records
- 1
Spain ES
National rule- Route
- RPP — Sección de envases / Registro Electrónico de Apoderamientos
- Appointment mechanism
- Electronic power of attorney
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Electronic power of attorney · Portal/register confirmation required
- Research records
- 0
Finland FI
National review- Route
- Finnish producer responsibility route
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
France FR
National review- Route
- French packaging EPR route
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 1
Greece GR
National review- Route
- EMPA / Greek packaging EPR route
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
Croatia HR
National rule- Route
- RPPO
- Appointment mechanism
- Authority/register upload
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Appointment evidence uploaded to RPPO · Authority approval before effectiveness
- Research records
- 1
Hungary HU
National rule- Route
- Hungarian EPR / MOHU route
- Appointment mechanism
- Written authorisation
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Hungarian tax number for representative · Producer signature required
- Research records
- 1
Ireland IE
National review- Route
- Irish packaging EPR route
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
Italy IT
National review- Route
- Italian packaging EPR route
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
Lithuania LT
Implementation pending- Route
- GPAIS / Register of Producers and Importers
- Appointment mechanism
- Implementation pending
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National portal/functionality is not yet fully implemented
- Research records
- 0
Luxembourg LU
National review- Route
- Luxembourg packaging EPR route
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
Latvia LV
National review- Route
- Latvian packaging EPR / natural-resources-tax route
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
Malta MT
National rule- Route
- Packaging producer registration / Written Mandate
- Appointment mechanism
- Official written appointment form
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Official written appointment form published · Producer signature required
- Research records
- 1
Netherlands NL
National review- Route
- Verpact / VerpactPortal
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National implementation guidance requires explicit review
- Research records
- 1
Poland PL
National review- Route
- BDO
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
Portugal PT
National rule- Route
- SILiAmb authorised representative route
- Appointment mechanism
- Official appointment example
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Official appointment example published · Producer signature required
- Research records
- 0
Romania RO
National review- Route
- Romanian packaging EPR route
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
Sweden SE
Current EU-law route- Route
- Swedish producer responsibility e-service
- Appointment mechanism
- Written authorisation
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Producer signature required
- Research records
- 0
Slovenia SI
Current EU-law route- Route
- GEA packaging producer register
- Appointment mechanism
- Register-entry route
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · Foreign company entered through local representative
- Research records
- 0
Slovakia SK
National review- Route
- ISOH packaging producer register
- Appointment mechanism
- National execution review
- Key formalities
- Written authorisation / appointment required · Representative established in the destination Member State · National execution formality requires primary-source review
- Research records
- 0
How it works
Prepare an EPR Authorised Representative appointment without skipping the legal gates.
Confirm the EPR Producer and destination
Identify the Producer, establishment and route to final users before deciding representation.
Apply current Article 45(3) and national rules
Separate EU cross-border obligations from third-country national requirements and transitional execution issues.
Enter both legal entities
Keep the Producer and destination-country representative as separate entities with signatory authority.
Apply country formalities
Use the official form, certification, portal request, acceptance or authority approval required for that Member State.
Attach evidence
Store extracts, signatory authority, signed appointment, acceptance and confirmations as hashed browser-local evidence.
Track legal effect
Do not advance the lifecycle to legally effective without the evidence required by the applicable route.
Export the correct output class
Use official forms where controlling; otherwise export a country-aware draft, portal pack or portable preparation record.
Natural questions
EPR Authorised Representative appointment — direct answers
Do I need an EPR Authorised Representative in every EU country where I sell packaging or packaged products?
Not every sales situation has the same result. Under current PPWR Article 45(3), a Producer covered by Article 3(15)(c) or (d) appoints an EPR Authorised Representative by written mandate in each other Member State where it first makes packaging or packaged products available. Third-country obligations depend on national rules. Producer status and route to the end user must be established first.
Can one EPR Authorised Representative cover all EU27 countries?
Article 3(20) ties the EPR Authorised Representative to establishment in the Member State where the relevant EPR obligations are fulfilled. A legal or service group can operate across countries, but the appointment and national establishment must satisfy each destination-country rule.
Is a signed written appointment automatically legally effective?
No. Some national routes add certification, portal acceptance, register confirmation or authority review. The engine therefore separates signature-ready, signed, accepted, confirmed and legally-effective states.
Is the EPR Authorised Representative the same as the PPWR Article 17 manufacturer authorised representative?
No. Article 17 is a technical/conformity role appointed by the manufacturer. The Article 45 EPR role concerns Chapter VIII producer-responsibility obligations. The documents and delegated tasks must remain separate.
Has the Article 45(3) EPR representative obligation been suspended until 2035?
A Commission proposal, COM(2025) 982 / 2025/0395(COD), proposes suspension. The engine does not treat a proposal as current law before adoption and entry into force.
Does Germany let the representative perform the Producer's initial LUCID registration?
No. The German route keeps the initial LUCID registration as a personal Producer obligation. The appointment engine marks that registration task as non-delegable and separately tracks the representative's LUCID confirmation.
What happens in Denmark after I choose an authorised representative?
The producer-register route sends an appointment request to the representative using its Danish CVR. The representative must accept the request; current DPA guidance gives a seven-day acceptance window before the request expires.
Do I need an official government form?
Where the competent body publishes a controlling form or official appointment example, that output takes priority over a Beyoğlu draft. Malta and Portugal are examples of routes where the official document layer must be surfaced explicitly.
Where are my appointment documents and evidence stored?
Structured draft data is stored in the site's browser-local Public Workspace. Evidence files are stored in IndexedDB with SHA-256 hashes. Nothing becomes submitted merely because it is stored or exported.