# Do you need an EPR Authorised Representative?

> Check whether the EPR Producer needs an EPR Authorised Representative for one EU destination and sales route, with country-specific official-source evidence.

Canonical: https://beyogluprofessional.com/tools/epr-ar-checker

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.

**CRITICAL DISTINCTION:** An EPR Authorised Representative and the PPWR technical authorised representative are different legal roles.

This checker covers packaging EPR representation only. It does not assess the manufacturer / technical-conformity representation governed by PPWR Article 17.

## Deterministic result model

- REQUIRED
- NOT APPLICABLE
- COUNTRY RULE MUST BE VERIFIED
- RECHECK EPR PRODUCER STATUS
- VERIFY ENTITY STRUCTURE

The checker does not convert an unresolved legal state into a probability statement. It returns an explicit Producer recheck, entity-structure verification or country-rule verification state when the supplied facts or national source do not support a final appointment result.

## Check your EPR representation status

Run a separate result for each destination Member State and materially different sales route.

### 1. 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.
- Yes — our company is the EPR Producer for this sale
- No — another legal entity is the EPR Producer
- Not determined yet

### 2. Which EU country is the sale going to?

Select the Member State where the packaging is used and becomes waste. Do not select a transit, trans-shipment or storage-only country.

Austria (AT), Belgium (BE), Bulgaria (BG), Croatia (HR), Cyprus (CY), Czechia (CZ), Denmark (DK), Estonia (EE), Finland (FI), France (FR), Germany (DE), Greece (GR), Hungary (HU), Ireland (IE), Italy (IT), Latvia (LV), Lithuania (LT), Luxembourg (LU), Malta (MT), Netherlands (NL), Poland (PL), Portugal (PT), Romania (RO), Slovakia (SK), Slovenia (SI), Spain (ES), Sweden (SE)

### 3. Where is the EPR Producer legal entity established?

Use the legal entity that invoices the buyer or is seller under the sales contract. A warehouse, VAT registration or marketplace account is not by itself an establishment.
- Established in an EU Member State
- Established outside the European Union
- I do not know

### 4. What will the actual buyer in the destination country do with the product?

A business can be a final user when it does not resell the product in the form supplied.
- Use it as an individual consumer
- Use it in its business and not resell it in the form supplied
- Importer, distributor or reseller; it will resell the product
- More than one route / route not resolved

### 5. Do you have a company structure in the destination Member State?

A branch and a separately incorporated local subsidiary are not the same. The structure can change which entity is the EPR Producer and whether the selected entity is foreign to the destination.
- No — no branch or separate local company in the destination
- The same legal entity has a branch in the destination
- A separate local subsidiary exists and that company sells / invoices the customer
- A separate local subsidiary exists but the foreign company remains the seller
- The company structure is not verified

## Legislative status

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.

## Country representation dataset

### Austria (AT)

- Dataset mode: mandatory
- Dataset scope: consumer
- Reviewed: 2026-08-29
- Source: [EDM — authorised representative for foreign distance sellers](https://edm.gv.at/edm_portal/cms.do?get=%2Fhilfetexte%2FerasregJSF%2Fhilfe%2Fregistrationapplication%2Factivityprofilewastespecific%2Fauthorisedrepresentativeforforeigndistancesellerspackaging.main&ubastyle_lang=en&ubastyle_nav=true)
- The verified Austrian route requires an Austria-established EPR Authorised Representative when a foreign distance seller supplies packaging directly to private final consumers in Austria.

### Belgium (BE)

- Dataset mode: mandatory
- Dataset scope: foreign_producer
- Reviewed: 2026-08-29
- Source: [IRPC / EPRiBEL — PPWR FAQ](https://www.ivcie.be/fr/nouvelle-faq-questions-frequentes-sur-le-ppwr/)
- The current Belgian PPWR guidance identifies appointment of an EPR Authorised Representative as an additional obligation for in-scope foreign EPR Producers.

### Bulgaria (BG)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [Bulgarian Ministry of Environment and Water](https://www.moew.government.bg/)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Croatia (HR)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [FZOEU — RPPO producer register](https://www.fzoeu.hr/en/register-of-producers-with-extended-responsibility-rppo/10208)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Cyprus (CY)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [Cyprus Department of Environment](https://www.moa.gov.cy/moa/environment/environmentnew.nsf/page21_en/page21_en?Click=&OpenDocument=&print=)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Czechia (CZ)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [Czech Ministry of Environment — packaging obligation register](https://mzp.gov.cz/cz/pro-media-a-verejnost/katalog-sluzeb/zverejneni-seznamu-osob-ktere-jsou-nositeli-povinnosti-zpetneho-odberu-nebo-vyuziti-odpadu-z-obalu-s18918)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Denmark (DK)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [Dansk Producentansvar — packaging producer responsibility](https://producentansvar.dk/en/products-and-responsibility/packaging/)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Estonia (EE)

- Dataset mode: mandatory
- Dataset scope: foreign_producer
- Reviewed: 2026-08-29
- Source: [Estonian Ministry of Climate — Extended Producer Responsibility](https://kliimaministeerium.ee/en/extendedproducerresponsibility)
- The current Estonian packaging EPR route uses an Estonia-established authorised representative for an in-scope foreign Producer that is not established in Estonia.

### Finland (FI)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [Rinki — Producer responsibility](https://rinkiin.fi/en/producer-responsibility/)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### France (FR)

- Dataset mode: mandatory
- Dataset scope: foreign_producer
- Reviewed: 2026-08-29
- Source: [Légifrance — Code de l’environnement L541-10-9-1](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054403121)
- A person subject to EPR and not established in France appoints a natural or legal person established in France as EPR mandataire by written mandate.

### Germany (DE)

- Dataset mode: mandatory
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [ZSVR — authorising a representative](https://www.verpackungsregister.org/en/knowledge-bases/authorising-a-representative)
- A foreign company without a German branch that sells empty packaging or packaged goods directly to German final users must appoint an EPR Authorised Representative.

### Greece (GR)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [EOAN — Greek packaging EPR infrastructure](https://www.eoan.gr/)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Hungary (HU)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [MOHU — EPR system](https://mohu.hu/hu/epr-rendszer)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Ireland (IE)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [Government of Ireland — EPR](https://www.gov.ie/en/department-of-climate-energy-and-the-environment/publications/extended-producer-responsibility-epr/)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Italy (IT)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [MASE — PPWR self-assessment](https://www.mase.gov.it/portale/autovalutazione-della-qualifica-soggettiva-ppwr)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Latvia (LV)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [State Environmental Service of Latvia — packaging obligations](https://www.vvd.gov.lv/lv/iepakotaji-un-pienakumi)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Lithuania (LT)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [GPAIS — Lithuanian environmental reporting system](https://www.gpais.eu/)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Luxembourg (LU)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [Luxembourg Environment Agency — EPR](https://environnement.public.lu/fr/emweltprozeduren/rep.html)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Malta (MT)

- Dataset mode: mandatory
- Dataset scope: consumer
- Reviewed: 2026-08-29
- Source: [Malta ERA — Packaging and Packaging Waste](https://era.org.mt/topic/packaging-and-packaging-waste/)
- A Producer established outside Malta that sells packaging or packaging material directly by distance selling to consumers in Malta appoints an EPR Authorised Representative established in Malta.

### Netherlands (NL)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [Verpact — Dutch packaging EPR](https://www.verpact.nl/en)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Poland (PL)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [BDO — Polish producer/waste register](https://bdo.mos.gov.pl/)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Portugal (PT)

- Dataset mode: mandatory
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [APA — Product Producers Register / SILiAmb](https://apambiente.pt/residuos/registo-de-produtores-de-produtos)
- A foreign Producer that sells packaged goods directly by distance selling to final users in Portugal follows the mandatory Portuguese EPR Authorised Representative route.

### Romania (RO)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [AFM — Environmental Fund online system](https://online.afm.ro/)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Slovakia (SK)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [ISOH — Packaging Producers Register](https://www.isoh.gov.sk/uvod/registre/zoznam-vyrobcov-obalov.html)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

### Slovenia (SI)

- Dataset mode: mandatory
- Dataset scope: foreign_producer
- Reviewed: 2026-08-29
- Source: [GOV.SI — Packaging producers register](https://www.gov.si/zbirke/storitve/evidenca-proizvajalcev-embalaza-in-plasticni-proizvodi/)
- Entry of a foreign company into Slovenia's packaging producer register is handled by its authorised representative established in Slovenia, with written authorisation forming part of the national route.

### Spain (ES)

- Dataset mode: mandatory
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [MITECO — RPP Packaging Section](https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/prevencion-y-gestion-residuos/prevencion-y-gestion-residuos/registro-productores-producto-seccion-envases.html)
- An EPR Producer established outside Spain that directly first markets packaged goods to a final user in Spain appoints an EPR Authorised Representative in Spain.

### Sweden (SE)

- Dataset mode: review
- Dataset scope: end_user
- Reviewed: 2026-08-29
- Source: [Swedish EPA — packaging producer responsibility](https://www.naturvardsverket.se/en/guidance/extended-producer-responsibility-epr/producer-responsibility-for-packaging/)
- The third-country EPR Authorised Representative result is not closed by this dataset; verify the current national route using the official source below.

## 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.

### EPR Producer established in another EU Member State

**PPWR ARTICLE 45(3)**

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.

[Regulation (EU) 2025/40 · Article 45 ↗](https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng)

### There is no single answer for 27 countries

**THIRD-COUNTRY EPR PRODUCER**

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.

### Technical representative and EPR Authorised Representative are different roles

**ARTICLE 17 ≠ ARTICLE 45**

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.

[PPWR · Articles 17 and 45 ↗](https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng)

### The suspension proposal is not law in force

**LEGISLATIVE FILE**

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.

[EUR-Lex · 2025/0395(COD) ↗](https://eur-lex.europa.eu/procedure/EN/2025_395)

## The same “foreign seller” label produces different operations in different Member States.

The checker supports all 27 Member States. These examples show source-backed mandatory routes with different national mechanics.

### Germany

A foreign company without a German branch that sells directly to German final users follows the German EPR Authorised Representative route.

- Initial LUCID registration remains the Producer's personal task.
- After approval, the representative handles later LUCID and other authorised EPR actions.

### France

A person subject to EPR and not established in France appoints a France-established mandataire by written mandate.

- The mandataire succeeds to the EPR obligations accepted in the mandate.
- The role is operational EPR representation, not an address-only service.

### Austria

A foreign distance seller supplying Austrian private final consumers uses an Austria-established representative.

- The representative is a natural or legal person established in Austria.
- The appointment uses the certified German- or English-language power of attorney required by the route.

### Spain

An EPR Producer outside Spain that directly first markets packaged goods to a final user in Spain appoints an EPR Authorised Representative in Spain.

- The representative can handle RPP registration and annual information reporting within the authorised scope.
- If a separate Spanish subsidiary makes the sale, the Producer determination is run again.

## Keep the representation decision connected to the rest of the country obligations.

### CALENDAR · Compliance Deadline Calculator

Turn registration, declaration, payment and recurring country tasks into an operating calendar.

[Build the calendar →](https://beyogluprofessional.com/tools/compliance-deadline-calculator)

### COUNTRY OBLIGATIONS · EU Country Obligation Checker

See EPR Producer, representative, registration, PRO/system, declaration, payment and evidence layers together.

[Check country obligations →](https://beyogluprofessional.com/tools/eu-country-obligation-checker)

### COST · EPR Cost Estimator

Keep representation service fees separate from regulatory charges and PRO/system contributions.

[Estimate cost →](https://beyogluprofessional.com/tools/epr-cost-estimator)

## Attach the EPR Authorised Representative to the correct legal role.

### Does every seller from Turkey have to appoint representatives in all 27 Member States?

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.

### What happens if I sell directly from one EU Member State to a final user in another?

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.

### Is Amazon or Etsy my EPR Authorised Representative?

No. Marketplace intermediation alone does not create the required legal mandate. Marketplace EPR-verification duties are a separate layer.

### Is an EPR Authorised Representative the same as the PPWR technical authorised representative?

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.

### What if the destination-country importer buys and resells in its own name?

Return to the EPR Producer determination first. An importer/reseller route is assessed for the Producer before any representation mandate is created.

### Did the Commission already postpone the EPR representative rule?

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.

## Regulatory note

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.

- [Regulation (EU) 2025/40 · Article 45](https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng)
- [EUR-Lex · 2025/0395(COD)](https://eur-lex.europa.eu/procedure/EN/2025_395)

## LLM discovery

- llms.txt: https://beyogluprofessional.com/llms.txt
- llms-full.txt: https://beyogluprofessional.com/llms-full.txt
- Markdown: https://beyogluprofessional.com/tools/epr-ar-checker/index.md