EU Authorised Representative for Non-EU Sellers: EPR, Packaging and Product Safety
A seller based outside the EU can need two different representatives, and one does not replace the other. For packaging, the Packaging and Packaging Waste Regulation (PPWR) makes you the producer in every EU country where you sell directly to end users, and Article 45(3) requires an authorised representative for extended producer responsibility in each of them, to register, report and pay fees. For product safety, the General Product Safety Regulation (GPSR) requires an economic operator established in the EU to be responsible for each consumer product, and your listings must name it. A third, optional mandate under PPWR Article 17 only holds your packaging documents. Published prices start around £185 to €1,000 per country a year for packaging EPR, and £490 to €1,150 a year for product-safety representation.
Marketplaces, providers and forum threads all say “EU authorised representative”, but the law uses the phrase for different jobs. Sellers pay for a product-safety representative and assume their packaging is covered, or the other way round. This guide separates them article by article, from the texts in the Official Journal, and compares what providers publish about price and scope.
Check your countries first: the PPWR Checker asks where you are based, where you sell and how, and lists for each country whether you are the producer, where to register and whether you need a representative.
The representatives a non-EU seller can need
| Mandate | Legal basis | Who needs it | What it does |
|---|---|---|---|
| Authorised representative for extended producer responsibility (packaging) | PPWR, Regulation (EU) 2025/40, Article 45(3) and Article 3(1), point 20 | A producer that sells packaged goods directly to end users in an EU country where it is not established: one in each such country. Mandatory. | Fulfils your producer responsibility there: registration, reporting packaging quantities, paying fees (Chapter VIII) |
| Responsible person for product safety | GPSR, Regulation (EU) 2023/988, Article 16; Regulation (EU) 2019/1020, Article 4 | Every consumer product placed on the EU market: if the manufacturer is not in the EU, an importer, an authorised representative or a fulfilment service provider there. One for the EU, not one per country. | Keeps the declaration of conformity and technical documentation available, cooperates with market surveillance authorities, checks product safety; named on the product and in online offers |
| Authorised representative for packaging conformity | PPWR Article 17 | Optional: a packaging manufacturer may appoint one by written mandate | Keeps the packaging declaration of conformity and technical documentation for authorities (5 years, 10 for reusable packaging) and answers their requests within 10 days. Does not draw up the documentation and does not handle EPR |
The first two are separate legal roles under separate laws. A product-safety representative does not register you for packaging EPR, and an EPR representative does not make you compliant with the GPSR. One provider can hold both mandates, but check that both are in the contract.
Packaging EPR: the Article 45(3) representative
Under PPWR you are the producer in an EU country when you make packaging or packaged goods available there for the first time. That includes selling from abroad directly to consumers or other end users in that country, whether you are based in another EU country or outside the EU (Article 3(1), point 15(c) and (d)). As producer you register in that country’s producer register (Article 44(2)) and carry extended producer responsibility there (Article 45(1)).
Article 45(3) adds that such a producer shall appoint, by written mandate, an authorised representative for extended producer responsibility in each Member State where it sells this way. Member States may also require one from producers established outside the EU that make packaging available on their territory for the first time in other ways. The representative must be established in that country and fulfils your obligations under Chapter VIII of the regulation (Article 3(1), point 20).
- It is per country. Selling directly to consumers in Germany, France and Poland means three registrations and, while Article 45(3) applies, three representatives.
- Germany already requires one by national law: without an establishment in Germany you appoint a Bevollmächtigter in writing, in German, before you first sell, but you register in the LUCID register yourself (VerpackDG § 5). See our German registration guide (in German).
- France registers producers through the eco-organisme you join, which enters you in SYDEREP and obtains your unique identifier. See our French PPWR page (in French).
- Poland uses the BDO register; how foreign distance sellers register there is to be settled by the Polish implementing act, still in preparation. See our BDO guide (in Polish).
The proposal to suspend it. In December 2025 the Commission proposed suspending Article 45(3) until 1 January 2035 (COM(2025) 982). The proposal would not simply exempt non-EU sellers: each Member State could still require producers established outside the EU to appoint a representative, or use other means to enforce the rules against them (proposal, Article 2 and recital 6). As of 16 October 2026 it has not been adopted and no act amending the PPWR has been published in the Official Journal, so Article 45(3) applies. We check monthly and will update this page.
Product safety: the GPSR responsible person
Since 13 December 2024 a consumer product may only be placed on the EU market if an economic operator established in the EU is responsible for it (GPSR Article 16(1)). That operator is the EU manufacturer; or, where the manufacturer is outside the EU, the importer; an authorised representative with the manufacturer’s written mandate; or, where none of those exists, a fulfilment service provider for the products it handles (Regulation (EU) 2019/1020, Article 4(2)).
- It is one person for the whole EU, not one per country.
- Its tasks include keeping the declaration of conformity and technical documentation available to authorities, cooperating with them, and regularly checking that the product matches its documentation (Regulation 2019/1020 Article 4(3); GPSR Article 16(2)).
- It must be visible. Its name and contact details go on the product, its packaging, the parcel or an accompanying document (GPSR Article 16(3)), and online offers must show the responsible person’s name, postal and electronic address when the manufacturer is not in the EU (GPSR Article 19(b)).
What marketplaces and warehouses check
- Packaging EPR: online platforms that let consumers buy from producers must obtain, before letting you sell, your registration number in the consumer’s country and a self-certification that you meet extended producer responsibility there (PPWR Article 45(4)). Fulfilment service providers, such as Amazon FBA or a third-party warehouse, must receive the same information when you sign with them and check it (Article 45(7) and (8)). A missing registration shows up as a blocked listing.
- Product safety: your offer must name the responsible person when the manufacturer is outside the EU (GPSR Article 19).
Providers and published prices
The table lists providers that publish a price, read from each provider’s own website on 16 October 2026, plus one well-known provider that quotes on request. Scope is what the provider’s page states; where a page does not say whether the Article 45(3) packaging representative is included, the table says so. Prices exclude the fees you pay the schemes, eco-organismes and authorities themselves, which depend on how much packaging you sell.
| Provider | What the price covers | Published price | Not included |
|---|---|---|---|
| Eldris | Packaging EPR registration with annual reporting, and the EPR representative where the law requires one; 27 EU countries, Norway and the UK | From £185 per country a year: Germany £185, France £295 | Scheme, authority and recycling fees, passed on at cost |
| EcoComply | Packaging compliance including EPR registration and reporting, with the representative included where required; scope agreed in a proposal | €1,000 per country a year | Scheme and producer responsibility organisation fees, authority charges, VAT |
| EPR Representative | France only: EPR representative established in France | From €190 a year per product stream, excluding VAT | Eco-organisme membership and eco-contributions |
| Der Grüne Punkt | Germany: authorised representative for extended producer responsibility (PPWR Article 45(3), VerpackDG § 5), including system participation | On request | – |
| 24hour-AR | Product-law authorised representative for the EU or the UK: GPSR representation, “PPWR packaging representation”, document storage. The page does not say this includes the Article 45(3) EPR representative | From €1,150 a year per market (up to 3,000 low-risk products) | VAT; higher plans add documentation checks |
| Euverify | EU or UK authorised representative / responsible person for GPSR and low-risk products, with PPWR packaging compliance tools. The page does not say this includes the Article 45(3) EPR representative | £490 a year for up to 5 product families; £790 for up to 20 | VAT; CE-marked, cosmetic and medical products charged extra per product |
Before you sign, ask any provider in writing: which countries it acts as your Article 45(3) representative in; whether it is established in each of them, as the regulation requires; whether registration, reporting and fee payment are included; and, separately, whether it is your GPSR responsible person. GreenCalculus earns no commission from the packaging EPR providers in this table.
Country guides
- Germany: LUCID registration under the VerpackDG and licence prices from every dual system (in German)
- France: PPWR in France and the Triman logo and Info-tri (in French)
- Poland: BDO registration for packaging (in Polish)
- The regulation itself: PPWR explained
Sources
- Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), Articles 3, 17, 44 and 45
- Regulation (EU) 2023/988 on general product safety (GPSR), Articles 16 and 19
- Regulation (EU) 2019/1020 on market surveillance, Article 4
- European Commission, proposal COM(2025) 982 of 10 December 2025 suspending the rules on authorised representatives for extended producer responsibility
- Provider pricing pages as linked in the table, read on 16 October 2026
Frequently asked questions
Usually yes, and possibly two. For product safety, every consumer product needs an economic operator established in the EU responsible for it (GPSR Article 16). For packaging, if you sell directly to end users in an EU country, PPWR Article 45(3) requires an authorised representative for extended producer responsibility in each such country.
No. The GPSR responsible person covers product safety for the whole EU. The PPWR Article 45(3) representative covers packaging producer responsibility (registration, reporting and fees) in one country. One company can hold both mandates, but they are separate appointments.
In every country where you sell packaged goods directly to end users without being established there (PPWR Article 45(3)). Where you sell only to a business that resells in that country, that business is usually the producer there instead.
Published prices on 16 October 2026 ranged from £185 a year per country (Eldris, Germany) and €190 a year per stream (EPR Representative, France) to €1,000 per country a year (EcoComply), before the scheme and authority fees, which depend on the packaging you sell.
The Commission proposed in December 2025 to suspend Article 45(3) until 2035 (COM(2025) 982). Even then, Member States could still require producers established outside the EU to appoint one. As of 16 October 2026 the proposal has not been adopted, so the rule applies.
For packaging EPR, no: under PPWR Article 45(4) and (7) marketplaces and fulfilment warehouses collect and check your registration numbers, they do not register for you. For product safety, a fulfilment service provider is the responsible person for the products it handles only where no manufacturer, importer or authorised representative is established in the EU (Regulation 2019/1020 Article 4(2)(d)).