EPR duties fall on the business that places packaging on a national market — but a regulator cannot easily enforce against a company with no legal presence in the country. Several member states therefore require a non-established business to appoint an authorised representative (AR): a locally-established party that takes on the EPR registration, declarations and fee payments on the seller's behalf.
Who typically needs one
Non-EU manufacturers and brand owners selling into the EU.
EU businesses selling cross-border into a member state where they have no establishment — increasingly required under national rules (Germany and France among the movers here).
Distance and marketplace sellers who mistakenly assume the platform carries their obligations.
Key characteristics
Country-by-country — an AR appointment is per member state; there is no single EU-wide AR for packaging.
Distinct from a customs or product-safety representative — the EPR AR is a separate role from the GPSR "responsible person" or a customs indirect representative, though one provider may offer several.
Formally appointed — usually via a written mandate the register and scheme will want to see.
Whether an AR is mandatory, optional or unavailable depends on the specific country — verify against that member state's current EPR law.
