PPWR: the packaging authorised representative non-EU sellers need by 12 August 2026

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 in early 2025, and the authorised-representative requirement applies from 12 August 2026.

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.

The catch for non-EU sellers is the words *in that member state*. A US, UK, or Asia-based seller is not established in any member state, so the requirement can bite in every country you ship to. An EU seller appoints a representative only in the other countries where it is not established.

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, the packaging authorised representative is per member state. Ship to Germany, France, and the Netherlands and you are looking at three separate appointments, three registrations, and three sets of reports.

What changes 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 adds is the formal requirement that a non-established producer route those obligations through an appointed representative in each country, on a written mandate, rather than handling them remotely or informally. Countries that already expected a local representative now have a single EU legal basis for it, and the ones that did not will from this date.

How to prepare

1. List the member states you actually ship packaged goods to. That list is your scope, one representative per country on it.
2. Confirm where you already have packaging EPR in place (for example a German LUCID registration) so you do not double up.
3. Appoint a representative in each remaining country, by written mandate, well before 12 August 2026.
4. Keep your packaging data accurate, because the representative reports the weight and material of what you place on each market, and the figures have to hold up.

How Assuro helps

The hard part is not appointing one representative. It is seeing, across your whole catalogue, which countries you sell packaging into, which you already cover, and which still need a representative before the deadline. Assuro connects to your Shopify store, totals your packaging by material, flags the member states you ship to but have not registered for, and tracks the 12 August 2026 date so it does not slip. It does not act as your representative or file for you, 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 ship packaged goods to
• Appoint a packaging authorised representative in each one, by written mandate
• Do it before 12 August 2026, not on the day
• Keep a single, live view of which countries are covered and which are not