Legal Requirement
In many countries, producers not established in the Member State cannot register or sell products without appointing an AR.
Full EPR Compliance in Europe
When a producer places products on the market in an EU Member State where they lack a legal presence, they may be legally required to appoint an Authorised Representative (AR). The AR acts as the local entity responsible for meeting the producer’s Extended Producer Responsibility (EPR) obligations—covering areas such as packaging, electrical and electronic equipment (EEE), batteries, and other regulated product categories.
At H2 Compliance, we help producers navigate the complex EPR landscape by supporting the selection, appointment, and ongoing management of Authorised Representatives across Europe—ensuring regulatory compliance and uninterrupted market access.
What is an Authorised Representative?
An Authorised Representative is a person or legal entity established in a Member State who is formally mandated to act on behalf of a producer not established in that country. The AR becomes the official contact point for national authorities and assumes responsibility for the producer’s compliance obligations under local EPR legislation.
This role is increasingly important as EPR rules are being expanded and harmonised across Europe, particularly with the new EU Packaging and Packaging Waste Regulation (PPWR), which makes AR appointment mandatory in all Member States.
Why do you need an Authorised Representative?
Compliance
Accountability
Authorities must have a domestic contact to oversee compliance, reporting and enforcement.
Market
Access
Without an AR, producers may face registration barriers, fines, or sales restrictions.
Regulatory Complexity
With 27 Member States applying their own EPR rules, an AR ensures obligations are managed locally and correctly.
What responsibilities does an AR cover?
While requirements differ by country and product category, an Authorised Representative typically:
-
Registers the producer in the national producer register. - Submits periodic reports on placed products and packaging.
- Manages payments of EPR fees to national schemes.
- Ensures compliance with collection, recycling and take-back obligations.
- Acts as the legal point of contact with national authorities.
- Maintains all necessary documentation for inspections or audits.
How H2 Compliance Supports You
Our experienced compliance team helps companies assess where an AR is required and provides complete support for appointment and management:
Gap Assessment
Identify where AR appointment is legally required for your products.
AR Appointment
Manage the legal mandate and ensure full compliance with national law.
Registration & Reporting
Handle all filings, registrations and reporting obligations.
Scheme Management
Liaise with national compliance schemes and manage associated fees.
Ongoing Monitoring
Track regulatory developments, ensuring your compliance strategy is future-proof.
