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. 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
- 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.
- In the EU, they are already mandatory for WEEE and batteries and will also be required for packaging starting August 2026.
- If a producer is not established in a member state they sell to, they need to appoint an AR there.
- The ARs tasks typically include registration, reporting and communication with national authorities.
- Each EU country can require a separate AR, which creates significant effort and costs for online retailers.
- Outsourcing AR management to a single service provider can save time and reduce complexity.
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.
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.
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.
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).
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. Planning ahead will be crucial to stay compliant.
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
Dealing with 27 different EPR Authorized Representatives per waste stream could soon become a reality for online retailers that sell across the EU. Appointing ARs in each country takes a lot of time and money, which makes the process particularly challenging for smaller businesses. For companies that operate in several EU markets, it can quickly become overwhelming to coordinate multiple representatives and keep track of national obligations. Outsourcing this responsibility to a trusted service provider can reduce complexity and save resources.
From our perspective, it would have been more efficient if retailers were trusted to handle their EPR compliance themselves without ARs in every country. For businesses outside the EU, one single AR for the entire EU would have been a more practical solution.
However, as the rules stand today, online retailers need to prepare for these requirements. Our team at ecosistant helps you cut through the complexity. We coordinate ARs across Europe, keep you compliant and free up your time for growing your 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.
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.
For WEEE Authorized Representatives, the rules have existed for years. For batteries, the new EU Batteries Regulation (EU 2023/1542) makes ARs mandatory from 18 August 2025. For packaging, the Packaging and Packaging Waste Regulation (PPWR) introduces the AR obligation from 12 August 2026.
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.