First confirm whether your company is the EPR Producer in the destination country. Then select where that Producer is established, the destination Member State, the buyer route and any local entity structure. The checker returns REQUIRED, NOT APPLICABLE or COUNTRY RULE MUST BE VERIFIED and shows the official source used.
PPWR Article 45(3)EU27Country-specific resultEPR Authorised Representative ≠ technical representativeEU law checked 1 September 2026
Check your EPR representation status
Run a separate result for each destination Member State and materially different sales route.
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Is your company the EPR Producer for this sale in the destination Member State?
An EPR Authorised Representative is relevant only for the legal entity that carries the EPR Producer obligation. If this is unresolved, use the Producer Status Checker first.
Brand ownership or micro-enterprise status does not replace the Producer test for ordinary packaged-product sales. Determine the Producer from the sales chain.
Legislative status: COM(2025) 982 proposes suspending application of the EPR Authorised Representative appointment rule in PPWR Article 45(3) until 2035. Legislative file 2025/0395(COD) remained in progress at the 1 September 2026 review. The proposal is not treated as law in force; the checker applies the current Article 45(3) text.
Legal logic
Being established outside the EU does not by itself mean “representative required”.
First identify the EPR Producer in the destination country. Then apply the PPWR rule or the destination country's current national rule based on establishment and sales route.
PPWR ARTICLE 45(3)
EPR Producer established in another EU Member State
For the relevant Article 3(1)(15)(c) or (d) cross-border route, an EPR Producer placing packaging on the market for the first time in a Member State other than its Member State of establishment appoints an EPR Authorised Representative there by written mandate.
PPWR permits Member States to require a third-country EPR Producer to appoint an EPR Authorised Representative established in that Member State. A Turkey-to-EU direct-sale route therefore uses the current national rule for each destination.
ARTICLE 17 ≠ ARTICLE 45
Technical representative and EPR Authorised Representative are different roles
Article 17 governs written authorisation for manufacturer technical-conformity and technical-documentation tasks. Article 45 is the separate country-specific relationship for packaging EPR obligations.
COM(2025) 982 proposes postponing application of the current appointment rule. At the 1 September 2026 review, 2025/0395(COD) remained in progress, so the proposal is not substituted for the current rule.
Attach the EPR Authorised Representative to the correct legal role.
No. First determine the EPR Producer in each destination country. When the Turkish company is the EPR Producer, check the current third-country representation rule separately for each destination. Do not use one EU27 answer.
When your company is the destination-country EPR Producer in the relevant Article 3(1)(15)(c) or (d) cross-border route, the current Article 45(3) requires a written EPR Authorised Representative appointment in the destination Member State.
No. Marketplace intermediation alone does not create the required legal mandate. Marketplace EPR-verification duties are a separate layer.
No. Article 17 governs manufacturer technical-conformity representation. The EPR Authorised Representative is the separate role under Article 45 and applicable national packaging EPR rules.
Return to the EPR Producer determination first. An importer/reseller route is assessed for the Producer before any representation mandate is created.
The Commission proposed a suspension. At the 1 September 2026 review, legislative file 2025/0395(COD) remained in progress. The proposal is not used in place of the current Article 45(3) rule.
This tool assesses the packaging-EPR requirement for an EPR Authorised Representative. It does not assess manufacturer / technical-conformity representation under PPWR Article 17. A REQUIRED result is not produced for a third-country EPR Producer without a source-backed national route. Country dataset review: 29 August 2026. EU law and legislative-file review: 1 September 2026.