If your brand is based outside the EU but sells to EU consumers, you may need an authorised representative to manage your EPR obligations. This is a formal legal arrangement, not just a local agent — it creates specific legal responsibility.
Here's who needs one, what they actually do, and how to appoint one correctly.
An authorised representative (AR) is a natural person or legal entity established in an EU member state who has been formally mandated, in writing, to fulfil specific regulatory obligations on behalf of a non-EU company.
In EPR terms: the AR registers with national PROs on your behalf, holds the EPR contracts in their name (or jointly with yours), and takes on legal responsibility for EPR compliance in the markets where they're appointed.
This is analogous to the AR concept in product regulations (CE marking, REACH) — the same logic applies.
Definitely need one:
May or may not need one (depends on corporate structure):
Generally don't need one:
Country-specific rules:
The AR's scope depends on the mandate, but typically covers:
Registration: The AR registers with each relevant PRO (LUCID/PRO, Citeo, Verpact, etc.) on your behalf, either in their own name with a note of the brand they represent, or in a joint registration.
EPR contract holding: In some countries (France in particular), the EPR contract is held in the AR's name with a documented mandate from you. In Germany, the LUCID registration is in your company's name but the AR assists with the registration process.
Annual reporting: The AR files annual packaging data declarations to each PRO, based on data you provide.
Invoice management: The AR receives PRO invoices and either handles payment on your behalf or passes them to you for payment.
Regulatory correspondence: If a PRO or national authority contacts the registered producer, that communication goes to the AR, who handles or forwards it.
What the AR is NOT responsible for:
The AR manages the administrative relationship with PROs. The underlying compliance obligations — using recyclable packaging, minimising void space, avoiding prohibited substances — remain with you.
Several types of organisations offer AR services for EPR:
Specialist EPR compliance firms: Companies that focus specifically on EU EPR compliance. Examples include international compliance consultancies with EU EPR practices. These tend to have the most expertise but may have minimum fee thresholds.
Law firms with EU environmental practice: Some European law firms offer AR services as part of their regulatory practice. More expensive but useful if you also need legal advice on EPR-adjacent questions.
PRO-adjacent service providers: Some PROs (particularly German PROs like Landbell and Interseroh) have affiliated services that help foreign brands with registration, including acting as AR.
Logistics and 3PL providers with compliance arms: Some larger EU logistics providers offer EPR compliance services to their clients.
What to look for:
The formal appointment of an AR requires a written mandate (sometimes called an "authorisation letter" or "mandate letter"). This document:
The mandate is submitted to PROs (particularly Citeo in France) as part of registration. Keep the original signed copy on file.
Template structure for an EPR mandate:
`
AUTHORISATION FOR EPR COMPLIANCE REPRESENTATION
[Brand legal name], registered at [address], company number [X] (the "Producer")
hereby authorises:
[AR legal name], registered at [EU address], company number [Y] (the "Representative")
to act on behalf of the Producer in respect of Extended Producer Responsibility
obligations under Regulation (EU) 2025/40 (PPWR) and national implementing
legislation in the following EU member states: [list countries]
This authorisation covers:
This authorisation is valid from [date] to [date / until cancelled in writing].
Signed: [Producer officer name, title, date]
Signed: [AR officer name, title, date]
`
AR services typically cost:
Total cost for a brand with 3 EU markets and an AR: typically €800–€3,000/year for the AR service alone, on top of actual EPR fees.
For small brands with very low EPR fee bills (e.g., €400/year total EPR fees across 3 markets), AR costs can exceed the fees themselves. At this scale, it's worth evaluating whether to:
For brands with meaningful EU volumes (€1M+ annual EU revenue), the AR cost is typically immaterial as a percentage of EPR fee exposure.
If you switch AR providers:
You own your registration numbers. An AR cannot hold these hostage — they're registered to your company, not the AR.
If you establish an EU entity and no longer need an AR:
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For a full picture of multi-country EPR management, see Managing overlapping EPR deadlines across 3+ countries.