Packaging EPR · Authorised representative · Updated 24 October 2026
Authorised representative for packaging EPR in the EU: who needs one, and where the suspension stands
Short answer (24 October 2026): if you sell packaged products into an EU country where your company has no establishment, EU law has required you to appoint an authorised representative there since 12 August 2026. The European Parliament (20 October) and the Council of the EU (21 October) have each voted for a partial suspension for some EU-based sellers, but their positions differ, nothing has been agreed and the requirement still applies. Companies based outside the EU are not covered by any version of the suspension.
What an authorised representative is
An authorised representative for extended producer responsibility (EPR) is a person or company established in the destination country that you appoint, by written mandate, to fulfil your packaging obligations there. It is the authorities' local contact for you. The rule comes from Article 45 of the Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40), which has applied in every member state since 12 August 2026.
What the representative actually does depends on the country. Germany is the clearest example. According to the Central Agency Packaging Register (ZSVR), the representative takes over your system participation, your quantity reports to LUCID and your declarations of completeness. Registering in LUCID remains your own duty, the agreement must be in German and signed by hand or with a qualified electronic signature, and you can appoint only one representative. In Sweden, Naturvårdsverket says the representative is appointed with a written power of attorney and you stay legally responsible as the producer. Austria requires a notarised power of attorney.
Who needs one
You need an authorised representative in a country when all three of these are true:
- You are the producer of the packaging there. For a webshop or marketplace seller shipping directly to consumers, that is usually you. If you sell only to a local wholesaler or importer that puts the goods on the market under its own name, it is normally the producer, not you.
- Your company has no establishment (company, branch) in that country.
- You make packaging available there, for example by shipping packaged goods to end users in that country.
Company size does not matter today, and neither does whether you are based in another EU country or outside the EU. A Polish webshop selling to Germany, a Swedish brand selling to France and a UK or US company shipping to Dutch consumers all need one.
Is the requirement being suspended? Status 24 October 2026
Not yet. It is still the law in every EU country. The suspension is part of the EU's "environmental omnibus" simplification package (Omnibus VIII). Here is where each institution stands:
| Stage | Who would be exempt from appointing a representative | For how long |
|---|---|---|
| Commission proposal (10 Dec 2025) | Producers established in the EU, in member states other than their own | Until 1 January 2035 |
| European Parliament position (adopted 20 Oct 2026; 616 for, 9 against, 39 abstentions) | Only EU-based micro and small enterprises: fewer than 50 employees and annual turnover or balance sheet total under €10 million | Until 2035, or until a Circular Economy Act is adopted |
| Council of the EU position (adopted 21 Oct 2026) | EU-established producers that make less than one tonne of packaging available per calendar year in that member state, with a safeguard clause for producers in breach of their EPR obligations | Scheduled to expire in 2032; Commission to review the duration by 31 December 2030 |
| Final law | Not agreed. Parliament and Council negotiations (trilogues) come next; the Irish Council presidency wants to start them as soon as possible. The agreed text must then be formally adopted and published in the Official Journal. | No date set |
Under every version, registration, scheme (PRO) membership, reporting and fees stay exactly as they are. Only the duty to appoint a representative would be paused.
What the two positions would mean for you
The final text will probably land somewhere between the Parliament and Council positions, so it helps to see where you fall under each:
| Your company | Today | Parliament version | Council version |
|---|---|---|---|
| EU-based, under 50 staff and €10m, under 1 tonne a year into that country | Representative required | Exempt | Exempt |
| EU-based, under 50 staff and €10m, 1 tonne or more into that country | Required | Exempt | Still required |
| EU-based, 50+ staff or over €10m, under 1 tonne into that country | Required | Still required | Exempt |
| EU-based, larger, 1 tonne or more into that country | Required | Still required | Still required |
| Based outside the EU (UK, US, Switzerland, China, Norway and so on) | Required | Still required | Still required |
One tonne is a lot of packaging for a small webshop: at a typical few hundred grams of box, filler and product packaging per order, it means thousands of parcels a year into one country. Many small cross-border sellers would fall under one tonne in most of their destination countries.
National rules can still require a representative
An EU suspension would pause the EU-level duty in PPWR Article 45(3). It would not by itself repeal national laws that already required foreign producers to appoint a local representative. These include:
- France: Article L. 541-10-9-1 of the Environmental Code (Law 2026-602 of 8 July 2026) requires every EPR producer not established in France to appoint a representative established in France, with no size threshold.
- Spain: Royal Decree 1055/2022 requires producers established in another member state or outside the EU to designate an authorised representative in Spain.
- Denmark: distance sellers established elsewhere register in the Danish producer register through a Danish authorised representative.
- Austria: foreign distance sellers to Austrian consumers need an Austrian authorised representative with a notarised power of attorney.
- Portugal: non-resident producers have had to appoint a local representative since 1 January 2022 (Decree-Law 152-D/2017).
How these national rules fit with the final EU text depends on its exact wording. We check each country when we quote and will update this page when the law changes.
What to do now
- Keep (or appoint) your representatives. Neither vote has legal effect. Selling without a required representative can block your registration, and in Germany you cannot complete a LUCID registration without one.
- Look at your contract terms. If you are signing a new representative agreement now, prefer one-year terms that you can end if the suspension applies to you.
- Know your numbers per country. Under the Council version, what matters is the weight of packaging you put on each country's market in a calendar year. Keeping a kilogram figure per country is useful anyway, because it is what every scheme asks you to report.
- Do not stop registering or reporting. No version of the suspension touches registration, scheme membership, reporting or fees.
What an authorised representative costs
There is no official fee. Published prices we found in September 2026 for the representative role alone run from about €75 a year in Germany or Spain, to around €190-200 a year per EPR stream for a French representative, up to DKK 5,000 (about €670) a year where the Danish PRO VANA acts as your representative. Many providers only sell the representative bundled with registration and reporting.
With Pakkausvastuu, the representative is an external cost: we bill its actual cost at cost, with no markup, as its own line next to our yearly service fee per country (from €150 a year). If the suspension becomes law and your company qualifies in a country, that line simply drops off your invoice and your total falls by that amount. See our per-country pricing.
We serve companies based in the EU and companies outside the EU that export packaged goods into the EU. The service is not for companies that only sell to a wholesaler or importer who takes on the producer responsibility.
Country guides
Each country guide covers its register, scheme, representative rule and typical costs:
- Austria
- Belgium
- Bulgaria
- Croatia
- Cyprus
- Czechia
- Denmark
- Estonia
- Finland
- France
- Germany
- Greece
- Hungary
- Ireland
- Italy
- Latvia
- Lithuania
- Luxembourg
- Malta
- Netherlands
- Poland
- Portugal
- Romania
- Slovakia
- Slovenia
- Spain
- Sweden
Authorised representative: frequently asked questions
Do I need an authorised representative for packaging EPR in another EU country?
Yes, if you have no establishment in that country and you make packaged products available there, typically by selling directly to end users. Since 12 August 2026, PPWR Article 45(3) requires a representative in each such member state, appointed by written mandate. This applies to sellers based in other EU countries and to sellers based outside the EU.
Has the requirement been suspended for small companies?
Not yet (status 24 October 2026). Parliament voted on 20 October for a suspension for EU-based micro and small enterprises until 2035; the Council agreed on 21 October to exempt EU producers under one tonne of packaging a year per country until 2032. They now have to agree one text. Until it is adopted and published, the requirement applies in full. Details above.
My company is based outside the EU. Will the suspension help me?
No. Every version covers only producers established in the EU. UK, US, Swiss, Norwegian, Chinese and other non-EU sellers shipping to EU end users still need a representative in every EU country they sell into. We work with non-EU companies that export packaged goods into the EU.
Do I need an authorised representative in Germany if my company is based in another EU country?
Yes, if you sell directly to end users in Germany and have no German branch. The ZSVR says you must appoint the representative and enter it in LUCID before selling. See our Germany guide.
Can one authorised representative cover several EU countries?
Not legally. The representative must be established in the country it represents you in, so you need one appointment per country. One provider can arrange all of them from a single set of packaging data, which is what we do.
Should I cancel my representative now that Parliament has voted?
No. Neither vote changes the law, and France, Spain, Denmark, Austria and Portugal also have national rules requiring a representative.
How much does an authorised representative cost?
From about €75 a year for the bare role in Germany or Spain to several hundred euros in countries such as France or Denmark, based on prices published in September 2026. We pass the representative's cost through at cost, as its own invoice line.
Sources: Regulation (EU) 2025/40 (PPWR) Article 45; ZSVR, "Authorising a representative" (verpackungsregister.org); Naturvårdsverket PPWR guidance; Fost Plus, "PPWR Insights 8" (23 June 2026); Council of the EU press release of 21 October 2026, read via its EuropaWire republication because consilium.europa.eu blocked our request; Packaging Europe (21 and 23 October 2026) and packaging journal (20 October 2026) on the Parliament vote. This page is general information, not legal advice. We will update it when the Parliament and Council agree a text.
Get your country-by-country quote
Tell us where you sell and roughly what you ship. We check in which countries you need a representative today, arrange them, and show their cost as a separate line so you can see exactly what would change if the suspension applies to you. Get a country-by-country quote →