Do I need an Authorised Representative in every country where I sell?

In general, an Authorised Representative may be required if your company places products or packaging on the market in an EU country where it does not have an establishment. This is particularly relevant for cross-border distance sales, for example through your own online shop or marketplaces.

As a simplified general orientation, B2C sales to end users in a country where the producer has no establishment generally fall within the scenarios in which an Authorised Representative is required. The same can apply to sales to commercial end users, although individual EU countries may implement this differently. For transport packaging or B2B sales to resellers, an Authorised Representative is generally not required, but national deviations can apply.

The decisive factors are therefore not only where your company is established, but also who receives the products, how they are distributed and who places the relevant packaging on the destination market.

An Authorised Representative is also only one part of EPR compliance. It does not automatically replace registration, participation in a Producer Responsibility Organisation (PRO), licensing or reporting requirements.