Update December 2025: Possible suspension of AR requirement for EU companies
The EU Commission has proposed suspending the obligation to appoint EPR representatives for companies based in the EU until 2035. This would affect packaging, WEEE, batteries, single-use plastics and general waste. The proposal still needs to be approved by the European Parliament and Council.
Important: Producers from third countries are not affected by the planned suspension. Existing registrations via representatives remain valid and all producers are still required to register with national Producer Responsibility Organizations in order to fulfill their EPR obligations. More details can be found in the section “Planned simplifications until 2035.”
Environmental rules in Europe are moving quickly and getting more demanding every year. At the center of this change is Extended Producer Responsibility, or short EPR. The idea is simple: producers should be responsible for the whole life cycle of their products and pay for their recycling costs. In practice, this is often anything but simple. Every country has its own laws, deadlines and reporting formats. This is where the Authorized Representative for EPR steps in.
Authorized Representatives act on behalf of producers that are not based in a given country and make sure all local EPR obligations are fulfilled. ARs are supposed to make things easier for you. But finding the right AR for each country and for different waste streams such as packaging, WEEE or batteries can be a real headache.
However, as of December 2025, the EU Commission is planning a simplification: the obligation to appoint authorized representatives for certain waste streams is to be suspended for companies based in the EU until 2035. If this proposal is accepted, it would simplify the compliance landscape for EU companies. The basic EPR registration and reporting obligations will remain in place.
This article tells you everything you need to know about Authorized Representatives for EPR: what is their role, which waste streams are they needed for and most importantly, how do you find one?
Content
- TL;DR
- The Role of an EPR Authorized Representative Today
- Current Challenges Faced by Producers
- Planned simplifications: Suspension of the requirement for Authorized Representatives until 2035
- Authorized Representative WEEE and Authorized Representative Batteries
- Authorized Representative Packaging under the PPWR
- Preparing for the Future: How to find an EPR Authorized Representative
- Conclusion: Challenges and Solutions
- FAQ: Authorized Representatives in Europe
TL;DR
- Authorized Representatives for EPR are appointed representatives that fulfil EPR duties on behalf of producers.
- As of December 2025: The EU Commission has proposed suspending the obligation to appoint EPR representatives for companies based in the EU until 2035. The proposal still has to be approved by the Parliament and Council.
- For producers from third countries, the representative requirement remains in place as specified in the revelant regulations.
- The tasks of ARs are generally registration, quantity reporting and communication with national authorities.
- The ARs tasks typically include registration, reporting and communication with national authorities.
The Role of an EPR Authorized Representative Today
An EPR Authorized Representative is a designated entity appointed by a producer to fulfil specific regulatory responsibilities under Extended Producer Responsibility schemes. In this context, the AR acts as the official liaison between the producer and national compliance bodies, ensuring that all legal obligations are met in the target markets.
The concept of ARs has been well established in sectors such as Waste Electrical and Electronic Equipment (WEEE), where producers appoint representatives to register, report and manage compliance in EU member states where they have no physical presence. More recently, with the introduction of new regulations targeting batteries and packaging, the AR’s importance is expanding. The EU Parliament and Council are expected to decide in the coming months whether the EU Commission’s proposal from December 2025 will invalidate the AR regulations until 2035.
In addition to handling registrations, Authorized Representatives in EPR act as the primary point of contact between producers and national authorities or compliance organizations. Their responsibilities typically include managing correspondence, responding to inquiries, facilitating audits or inspections and ensuring that producers meet their reporting obligations, such as declaring packaging volumes, product quantities and paying waste management fees.
It is important to note that the scope of services provided by each AR can vary significantly depending on the country and the specific organization they represent. This makes it crucial for producers to carefully evaluate potential AR candidates before entering into any agreements.
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Current Challenges Faced by Producers
Managing compliance across Europe’s multitude of national EPR systems is complex. Producers and their ARs must deal with a patchwork of regulations that vary by country and product category. Reporting deadlines can differ from monthly to quarterly or annually. Fees are calculated with different methods, and data requirements can range from simple volume declarations to detailed reporting.
These differences complicate relationships between producers and their Authorized Representatives. Clear communication and well defined service agreements are essential to avoid misunderstandings or compliance gaps. Missed deadlines or inaccurate reporting can otherwise lead to warnings, penalties or even sales bans on online marketplaces.
Planned simplifications: Suspension of the requirement for Authorized Representatives until 2035
In December 2025, the EU Commission presented two legislative proposals that could significantly simplify EPR compliance for many companies. Proposals COM(2025) 982 (batteries and packaging) and COM(2025) 983 (general waste, WEEE, and single-use plastics) provide for the suspension of the obligation to appoint Authorized Representatives for companies based in the EU until 2035.
What would change?
If the proposals are adopted, the obligation to appoint EPR Authorized Representatives for EU-based companies would be removed. A German online retailer selling to France, Poland, and Italy would then no longer have to appoint ARs in these countries.
Who is not covered by the planned suspension?
Producers from third countries (outside the EU) remain excluded from the plan. The representative requirement continues to apply to them, where relevant. A British or US online retailer will therefore still have to appoint a representative for certain waste streams.
EPR obligations remain in place
The planned suspension of the AR obligation does not mean that EPR obligations will be waived. All producers are still required to register with the national Producer Responsibility Organizations (PROs), report packaging and product quantities and pay recycling fees.
Status and next steps
The legislative proposals have been submitted to the European Parliament and the Council for adoption. Until formal adoption, the existing regulations will continue to apply (as of December 2025). Existing registrations via Authorized Representatives remain valid and should be maintained until there is clarity on the final legal situation.
Companies should closely monitor developments and prepare for the AR obligation for packaging to come into force as planned from August 2026, before a possible suspension takes effect.
Authorized Representative WEEE and Authorized Representative Batteries
Authorized Representatives for WEEE have existed for quite some time. The EU WEEE Directive (Directive 2012/19/EU) has been in place since 2012 and requires producers to comply with obligations around waste electronics, take back, reporting and more. Selling electronic goods in EU countries is only allowed if you are established there and meet all the national requirements, or if you appoint a WEEE Authorized Representative in each country where you sell without being established.
In Germany, the Electrical and Electronic Equipment Act (ElektroG) requires that companies without a German establishment appoint a WEEE representative in Germany. German online retailers must also have an AR in every other member state where they sell, unless they have a legal presence there themselves. For example, a German online shop selling headphones to France without a French entity must appoint a WEEE AR in France. The same principle applies in the electrical laws of all other EU countries, so cross border sales are not possible without ARs.
For batteries, a similar obligation applies. The new EU Batteries Regulation (Regulation (EU) 2023/1542) introduced a mandatory Authorized Representative for batteries requirement that started on 18 August 2025. Companies that sell batteries in a member state where they are not established must appoint an AR in that country. Whether this obligation will be suspended from December 2025 to 2035, as proposed by the EU Commission, is expected to be decided in the coming months.
Looking for Authorized Representatives?
ecosistant can handle all your duties regarding recycling compliance including the appointment of Authorized Representatives within Europe, for WEEE, batteries as well as packaging. Contact us and say goodbye to time consuming recycling compliance processes!
Authorized Representative Packaging under the PPWR
The same rules that already apply to electronic products will soon also apply to packaging. This means that practically all online retailers in the EU will be affected. The EU’s new Packaging and Packaging Waste Regulation (PPWR) introduces the AR obligation in article 45(3).
The EU Commission has proposed suspending this AR requirement for EU-based companies until 2035. However, until a final decision is made, companies should assume for safety’s sake that the regulation will come into force in August 2026 as originally planned.
According to the PPWR regulation, a producer from within the EU must appoint an Authorized Representative for packaging in every member state where they sell products, except for the state where they are established. Producers from outside the EU may also be required to appoint an AR when they sell into the EU. This rule will apply from 12 August 2026.
The requirement does not include any exceptions for company size or sales volume. Even the smallest retailers who only occasionally sell abroad will need to appoint an AR for packaging in each EU country where they have customers. According to the PPWR, ARs may take over registration and reporting duties to the national producer registers that each EU member state must set up by October 2027 at the latest. The exact scope of AR responsibilities in each country will become clearer as we move closer to that deadline.
Criticism of this rule includes concerns overregulation and additional trade barriers. For online retailers, cross border sales in the EU will involve more administrative steps and costs. It remains to be seen whether the EU Commission’s proposal will be accepted.
Preparing for the Future: How to find an EPR Authorized Representative
To future proof your EPR strategy, a proactive and informed approach is essential. Early registration in relevant schemes and accurate, timely data collection are foundational steps. Selecting an experienced EPR Authorized Representative in each EU country you sell to, with expertise across different product categories, is equally important.
Step-by-Step Approach
1. Identify the countries where you “place packaging on the market”
This is the first point of sale: where you sell D2C. In some cases, B2B sales can also equal EPR responsibility, if your sold goods are used by businesses directly (e.g. you are selling office furniture to companies across borders). Make a list of all relevant EU Member States.
2. Prioritize countries by risk / turnover / complexity
Start with the large markets (DE, FR, IT, ES, PL), then the smaller ones. This helps you reduce compliance risk quickly.
3. Search for candidates
- National PROs / government registries (Producer Responsibility Organizations or national registries): they often have lists, requirements and recommended partners (e.g. CONAI in Italy, Ecoembes in Spain).
- Specialized EPR/PPWR service providers (one-stop Authorized Representative services): providers such as ecosistant offer to take over the appointment of ARs in multiple countries for you. This is often the fastest route.
4. In parallel: Standard Request for Information (RfI)
Send a short RfI to your candidates with standard questions about scope, liability, prices, reporting frequency, POA & formalities as well as termination terms.
5. Due diligence & contract negotiation
Read the contract carefully and renegotiate terms as necessary.
6. Appointment & Power of Attorney (POA)
Formalize the appointment with a written power of attorney.
ecosistant is your one-stop solution for solving your Authorized Representative woes. We recommend the best compliance partners and solutions tailored to your needs on our digital platform or can even manage your whole EPR compliance, serving as your communication link to all your ARs.
Conclusion: Challenges and Solutions
The EPR landscape in Europe continues to evolve. While current regulations require online retailers to appoint an EPR representative for WEEE, batteries and packaging in up to 27 EU countries, this could change for EU-based companies until 2035. The planned suspension of the representative requirement could significantly reduce the administrative burden, provided the proposal is accepted.
In our view, it makes more sense for retailers to be able to fulfill their EPR obligations independently, without having to appoint representatives for each country. We therefore welcome the Commission’s proposal. For companies outside the EU, a single Authorized Representative for the entire EU would make sense.
However, as the rules currently stand, online retailers should prepare themselves. Our team at ecosistant supports you in finding Authorized Representatives and PROs throughout Europe, ensuring your compliance, and freeing up time for your core business.
FAQ: Authorized Representatives in Europe
An EPR Authorized Representative is a legal entity that acts on behalf of a producer in an EU country where the producer has no local presence.
Extended Producer Responsibility (EPR) means that producers, as entities making available products in countries for the first time, need to take responsibility for the waste that their products and its packaging causes. They do this through registering with national recycling schemes, providing data on their sold items regularly and paying recycling fees accordingly.
The AR ensures that all EPR obligations are met, including registration, reporting and communication with local authorities.
In December 2025, the EU Commission proposed suspending the Authorized Representative requirement for companies based in the EU until 2035. This would affect packaging, WEEE, batteries, single-use plastics, and general waste. The proposal still needs to be approved by the European Parliament and Council. The AR obligations would continue to apply to producers from third countries, where they are relevant. Even if the Authorized Representative obligation is suspended, the basic EPR obligations (registration with PROs, reporting, fees) will remain in place.
The regulations have already been in force for Authorized Representatives in the field of waste electrical and electronic equipment for several years. For batteries, the new EU Battery Regulation (EU 2023/1542) stipulates the obligation to appoint an Authorized Representative from August 18, 2025. For packaging, the EU Packaging Regulation (PPWR) is set to introduce the obligation to appoint an authorized representative from August 12, 2026. However, in December 2025, the EU Commission proposed suspending the AR obligation for EU-based companies until 2035. Until this proposal is finally adopted, however, companies should assume that the originally planned regulation will apply.
You must appoint an Authorized Representative if you sell products in an EU member state where your company is not established. This applies to packaging, electronic products (WEEE) and batteries under EU EPR rules.
No. Each EU country can require its own EPR Authorized Representative. National EPR systems differ from country to country. However, some service providers can coordinate all your Authorized Representatives across Europe for you.
An Authorized Representative typically handles registrations, reports packaging or product quantities and communicates with compliance schemes and authorities. The AR should ensure that your business remains compliant and avoids penalties. However, the scope of AR services may vary between entities. This is why you should do your research before choosing your ARs.
You risk non-compliance, which can lead to warnings, fines or even sales bans. Online marketplaces may also remove or block your listings if you cannot prove compliance with EPR obligations.
You can check national producer responsibility organizations (PROs), government registries or specialized EPR Authorized Representative services like the one ecosistant offers. Compare services, experience, liability coverage and costs before deciding.
Yes. The requirement applies to all producers, regardless of size or turnover. Even small retailers who only sell abroad occasionally must appoint Authorized Representatives in each EU country where they sell.
A specialized EPR service provider can help you find and coordinate Authorized Representatives for packaging, WEEE and batteries in all EU countries. They handle communication and reporting, helping you stay compliant while saving time and effort.
Questions about EPR Authorized Representatives for recycling compliance? Contact ecosistant’s EPR experts for individual advice. We will help you implement all the necessary steps in a timely and cost-efficient manner.