When do I need an authorised representative in another EU country?

When selling at a distance to a country where you are not established

An authorized representative is required as soon as packaged products reach end users in an EU Member State via distance selling — think of an online shop — where the responsible party itself is not established. This is the core of Article 45 of Regulation (EU) 2025/40: whoever supplies in that manner must appoint a representative in that country in writing who assumes the obligations under the regulation on behalf of the supplier.

This is not a voluntary choice based on turnover or quantity: the obligation depends on the fact that goods are supplied to a country where you are not established, not on a threshold. This also means that an authorized representative may be needed in a country where your own national registration threshold has not yet been reached. An example: if you remain below the Verpact threshold of 50,000 kg per year in the Netherlands, you may still need a representative in Germany as soon as you supply there via distance selling, because Germany has no lower limit in LUCID — registration applies from the first package onwards. The representative then usually also handles registration in that country's producer register, which is a separate obligation in itself.

Where this appears in the regulation: Articles 45 and 44

Article 45 of Regulation (EU) 2025/40 establishes the obligation for a written mandate for an authorized representative for distance selling to end users in a Member State where you are not established. This obligation is separate from, but linked to, the registration obligation per country under Article 44: packaging from an unregistered producer may not be placed on the market, and the authorized representative is often the one who arranges that registration on behalf of the supplier. Because the PPWR is a regulation, Article 45 applies directly and uniformly in every Member State — it is the national registers and their thresholds that differ from each other.