PPWR packaging authorised representative: what to do now that it applies

Do you need one? Start here

Whether you need a packaging authorised representative, and where, depends first on where your business is established. Find your row, then read on.

What is a packaging authorised representative?

A packaging authorised representative is a person or company established in an EU member state that a producer appoints, by written mandate, to handle its Extended Producer Responsibility obligations for packaging in that country. They register you with the national scheme, file your packaging reports, and act as the local point of contact for the authorities. The role exists so that a foreign seller placing packaging on a national market still has someone inside that market who is accountable for it.

It is created by the EU Packaging and Packaging Waste Regulation (PPWR), which replaces the old Packaging Directive with a single regulation that applies directly across the EU. PPWR entered into force on 11 February 2025 and became generally applicable on 12 August 2026, which is the date the authorised-representative rule started to apply.

Who needs one?

You need a packaging authorised representative if all of these are true:

• You place packaged goods on the market of an EU member state (selling direct to consumers there counts);
• you are not established in that member state; and
• you are the producer for packaging purposes, which for a direct-to-consumer seller usually means you.

There is a distinction in how PPWR reaches these two groups, and it is the thing most write-ups get wrong. For a producer established in the EU that sells into other member states direct to consumers, PPWR itself requires the appointment in each one it is not established in. For a seller established outside the EU, PPWR does not impose it everywhere: it leaves each member state to decide. In practice several of the countries Shopify sellers ship to most, France, Spain and Austria among them, already require a local representative for a foreign distance seller under their own law, while Germany makes the foreign seller directly responsible (you register in LUCID in your own name), so for those markets you should plan to be represented or registered regardless. Treat it country by country rather than as one blanket EU rule.

One per country, not one for the EU

This is the part sellers misread. Unlike the GPSR Responsible Person, which one appointment can often cover for the whole EU, packaging representation is never EU-wide. Where a representative is required at all, it is required per member state, so shipping to France, Spain and Austria means three separate appointments, three registrations and three sets of reports. Germany is the exception worth knowing: it makes a foreign seller register in LUCID in its own name instead, so you carry the registration without the appointment.

What changed on 12 August 2026

Packaging EPR itself is not new. In Germany you already register in LUCID and license with a dual system; in France you already work through Citeo. What PPWR added is a single EU legal basis for that appointment, on a written mandate, where before it rested on national law alone. For a producer established in the EU, PPWR itself now requires the appointment in every member state it sells into and is not established in. For a producer established outside the EU it does not: the countries that already required a local representative still do, and the ones that did not are free to introduce it but have not all done so.

You have not appointed one. What now?

This is the common position, not the unusual one. National registers have been taking on producers who arrive late since long before PPWR gave the representative rule a single EU legal basis, and registering late is the normal route in. It does not erase the period you were unregistered, so start with the market where your volume is largest.

The first thing to understand is that there is no EU-wide switch you failed to flip. The obligation is national. You are unrepresented in Germany, or in France, or in the Netherlands, and each of those stands on its own, with its own register, its own scheme and its own enforcement culture. That is a nuisance when you are setting up and an advantage when you are catching up, because it means you can fix the countries that matter first instead of facing 27 at once.

So start with scope rather than paperwork. Take your last twelve months of orders and list the member states you actually shipped packaged goods to, ranked by volume. Do not use your Shopify Markets settings for this: most stores have markets switched on that they barely sell into, and each of those is a full set of obligations for a handful of orders. Appoint and register in the countries at the top of that list and work down. The ranking sets your order of work, and that is all it does: a country further down the list is one you are non-compliant in until you cover it, regardless of how few parcels go there. So pair the ranking with a decision on the tail. For any member state you are not going to appoint and register in soon, the practical option is to turn shipping and checkout off for it until you are covered. Be precise about what that achieves. Closing checkout stops the obligation growing from new sales. It does not remove what has already accrued, and you can still owe registration, reporting and fees for the period you were selling there.

Expect to be asked about the past. A scheme taking you on now will often want the volumes you have already placed on that market, not only what you ship from the day you sign. Have your packaging weights by material ready before you start the conversation rather than assembling them under time pressure afterwards.

The one thing that makes it worse is waiting. Every week you keep selling into a country you are not registered in adds to the volume you may have to account for, and leaves a marketplace check or a fulfilment provider's compliance check sitting in front of you. Appointing and registering reduces one category of ongoing non-compliance, the one where you keep placing packaging on a market with nobody registered for it. It does not complete scheme participation, reporting or the conformity duties that sit alongside them, and it does not erase what has already accrued. Closing an uncovered market stops that particular meter running while you work through the rest.

No, it was not suspended

In December 2025 the Commission's Environmental Omnibus included a proposal, COM(2025) 982, to suspend the PPWR authorised-representative rule until 1 January 2035. It circulated widely and a lot of sellers concluded the requirement had gone away. It did not. The proposal targeted producers already established somewhere in the EU, and in June 2026 the Council reported that negotiations had been discontinued after strong reservations from a large majority of member states. The adopted regulation stands, and for a producer established in no member state at all the proposal would never have helped. More on what did and did not land in August in PPWR since 12 August 2026: what actually changed.

What appointing one actually involves

The appointment itself is a document, not a project. You give a written mandate to a company established in that member state, setting out what it is authorised to do for you, and it deals with the national register and the scheme from there.

1. Check what you already have in each country. Plenty of sellers have some packaging EPR in place already, a German LUCID registration or a French mandataire appointed years ago. Confirm what each one actually covers before you buy anything, so you do not pay twice for the same market.
2. Give a written mandate, per country. One representative, one member state, one mandate. The same provider can hold several for you, but they are separate appointments and they are priced separately.
3. Hand over accurate packaging data. Your representative reports the weight and material of what you place on each market. It reports what you give it, and the figures have to hold up if anyone looks.
4. Keep it current. Registration is not one-and-done. Schemes expect periodic declarations of what you actually placed on the market, so the data has to keep coming.

How Assuro helps

The hard part was never appointing one representative. It is seeing, across a whole catalogue, which countries you genuinely sell packaging into, which of them you already cover, and which have been running uncovered while you assumed otherwise. Assuro connects to your Shopify store, totals your packaging by material, and flags where you ship into one of its six supported countries without a registration on record: Germany, France, the Netherlands, Austria, Italy and Spain. Obligation tracking covers those six, so a destination outside that list stays yours to check by hand. It does not act as your representative, register you, or file anything, and it links every flag to the rule behind it.

• Confirm PPWR applies: you place packaging on an EU market and are not established there
• List every member state you shipped packaged goods to in the last twelve months, by volume
• Check which of those you already cover, so you do not appoint twice
• Appoint a packaging authorised representative in each remaining one, by written mandate
• Start with your largest market instead of trying to fix all of them at once
• Turn shipping and checkout off for any member state you are not going to appoint and register in soon
• Keep a single, live view of which countries are covered and which are not