How to start
How to appoint your PPWR representative
Appointing a representative under Article 17 is straightforward and can be done in a few steps.
- Sign the written mandate, which is the actual legal step
- Share your company details and packaging types
- Send us your Declaration of Conformity and technical documentation
- Receive your representative details and proof of appointment
- Add our name and address where your documentation and buyers need it
Setup takes a day if your documentation is in order.
Is a PPWR authorised representative mandatory?
No, and anyone telling you otherwise is selling you something.
Article 17 of the Packaging and Packaging Waste Regulation says a manufacturer may appoint an authorised representative. It is a right, not an obligation. The regulation places the hard duties elsewhere: on the manufacturer for conformity, and on the EU importer for checking that the manufacturer did its job.
So why do non-EU manufacturers appoint one anyway? Because of what happens if you do not.
Without a representative, your EU importer or distributor carries the documentation burden for your packaging. They have to produce your Declaration of Conformity and technical file when an authority asks, and they have ten days to do it. Increasingly they refuse to take that on, or they price it in, or they simply pick a supplier who has already arranged it.
Appointing a representative keeps that responsibility where it belongs and keeps you the party authorities talk to. It also removes a very practical objection from your buyer, which is usually the reason our clients call us in the first place.
PPWR representative or EPR representative? They are not the same
The PPWR uses the word representative for two completely different roles, defined separately in Article 3. Buying the wrong one is a common and expensive mistake.
| Authorised Representative | Authorised Representative for EPR | |
|---|---|---|
| Defined in | Article 3(1)(19) | Article 3(1)(20) |
| Set out in | Article 17 | Article 45(3) |
| Appointed by | The manufacturer | The producer |
| Must be established | Anywhere in the EU | In that specific member state |
| Coverage | One mandate, all 27 member states | One per member state |
| Covers | Conformity documentation and market surveillance | Waste and recycling obligations |
| Mandatory? | No, Article 17 says "may" | Yes for distance sellers to end users |
| This service | Yes, 150 EUR per year | No, see our EPR registration services |
In short: the Article 17 representative looks after your paperwork. The EPR representative pays for your packaging to be collected and recycled, country by country.
Most sellers who ship packaged goods into more than one EU country end up needing both. They are separate appointments with separate scopes, and we can arrange either.
What we cover
What we do as your authorised representative
Article 17(2) sets a minimum that every mandate must include. Ours covers all of it.
We keep your EU Declaration of Conformity and technical documentation available to national market surveillance authorities. Five years for single use packaging, ten years for reusable packaging.
We cooperate with the competent national authorities on any question of non-compliance relating to your packaging.
We supply the information and technical documentation those authorities need to demonstrate conformity.
We make requested documents available within ten days. That deadline is in the regulation, not something we invented.
We are obliged to terminate the mandate if you act contrary to your obligations. We mention this because it tells you the appointment is real, not a rubber stamp.
What stays with you
The regulation is explicit that two things can never be delegated. Making the packaging compliant in the first place, meaning the sustainability requirements in Article 15(1). And drawing up the technical documentation. We hold it and produce it on demand, but you or your packaging supplier create it.
If the documentation does not exist yet, say so when you contact us. We can prepare it as a separate service, and it is better to find out now than when an authority asks.
Why do I need an PPWR Authorised Representative?
You will need a PPWR Authorised Representative in below cases.
You are established outside the EU
This includes UK companies, which count as non-EU since Brexit.
You are the manufacturer or brand owner
Article 17 mandates come from the manufacturer.
If you have products made to your own specification and put your name on them, that is you, whoever runs the factory.
Your packaging enters the EU market
Any packaging: the box, the filler, the label, the pallet wrap.
PPWR covers all of it, whether you ship direct to consumers or into a distributor.
If your company is established inside the EU, you do not need this service.
ou are already the economic operator authorities will approach.
150 EUR per year.
That is the whole price.
One written mandate, valid across all 27 member states. Unlimited packaging types under that mandate. No per-item surcharge, and no extra fee when an authority asks a question, because answering them is the job.
What is not included: creating your technical documentation or Declaration of Conformity if you do not have one, and any EPR registration, which is a separate obligation with its own fees per country.
free check
Applies from 12 August 2026
The PPWR replaces Directive 94/62/EC and applies from 12 August 2026. From that date your packaging needs an EU Declaration of Conformity and supporting technical documentation, and an authority can ask to see both.
The harmonised labelling pictograms come later, so there is no need to redesign artwork yet. The documentation is the part that is live now.
Frequently Asked Questions
Here are some common questions about this service.
No. Article 17 says a manufacturer may appoint one. The practical reason to do it is that without a representative the documentation burden falls on your EU importer or distributor, and many now refuse to carry it.
They are separate roles with separate definitions. The Article 17 representative holds your conformity documentation and can be established anywhere in the EU, one mandate for all 27 countries. The EPR representative under Article 45(3) handles waste and recycling obligations and must be appointed per member state.
They are separate mandates under separate regulations, because GPSR covers product safety and PPWR covers packaging. We can hold both, so in practice it is one relationship and one point of contact.
No. EPR registration is a country-by-country obligation with its own fees. We handle EPR registration for France and Germany as separate services and can advise on other countries.
An EU Declaration of Conformity for your packaging and the supporting technical documentation. If you do not have them yet, tell us. We can prepare them as an additional service.
Five years for single use packaging and ten years for reusable packaging, counted from when the packaging is placed on the market. That comes from Article 17(2).
We respond and supply the documentation within ten days, which is the deadline the regulation sets. You are informed at the same time. There is no extra charge for this.
Yes. Since Brexit the UK is outside the EU, so a UK manufacturer shipping packaged goods into the EU is in exactly the situation Article 17 is written for.
Still not sure which representative you need?
Plan a free call and we will tell you whether Article 17, Article 45(3) or both apply to your situation.
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What our customers are saying about us.
"Trying to wrap my head around GPSR and Joe made it super easy to do and understand."
Leanne
Botanical arts seller
United Kingdom
"Joe has been unbelievably helpful to keeping me up to date with ALL GPSR related compliance and questions, essential for business."
Jesse
Vinyl records seller
United States
"Very helpful in my hour of Amazon frustrations!!"
Martin
Amazon seller
"Joe and Youri are amazing. They walked me through the complex world of GPSR and CE compliance and made the process easy. Couldn't have done it without them. Highly, highly recommended."
Eugene
Wheelchair glove seller
Lithuania
"I would recommend his services to anyone looking to start selling in the EU again with the GPSR regulations in place."
Amanreet
Board game seller
"Joe is very accommodating & works with you to find solutions."
Hasan
Plastics manufacturer
Canada
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Company details
We'd love to hear from you! If you have any questions, feedback, or need assistance, please feel free to reach out to us using the contact details provided. Our team is here to help and will respond as soon as possible. Thank you for getting in touch!
Phone
Office
Fellenoordstraat 52 Unit 2.38, 4811TJ Breda, Netherlands
VAT
NL865927534B01
Chamber of Commerce
NL 92195873