PPWR Packaging Authorized Representative
Under Article 18 of the EU Packaging and Packaging Waste Regulation (EU) 2025/40, non-EU manufacturers and importers must appoint an authorized representative. We deliver the written mandate, EPR registration and recyclability assessment — end to end.
Why Do You Need a PPWR Authorized Representative?
The EU Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) entered into force on 11 February 2025 and applies from 12 August 2026. Under Article 18, manufacturers or importers established outside the EU must, by written mandate, designate an authorized representative established in the EU before placing packaging or packaged products on the EU market.
The representative is the legal point of contact with Member State authorities, and its name and address must be indicated on the packaging or accompanying documentation. Extended producer responsibility (EPR) registration and reporting obligations apply in parallel — non-compliance risks market exclusion.
- Applies to packaging and packaged products placed on the EU market (including cross-border e-commerce)
- The representative's name and address must appear on the packaging or accompanying documentation
- Independent from the medical-device EC-REP — the two mandates can be handled together
Regulatory Basis
Our PPWR services follow the current EU regulatory framework.
Packaging and Packaging Waste Regulation (PPWR)
Replaces Directive 94/62/EC; entered into force 11 February 2025, applies from 12 August 2026. Recyclability and recycled-content requirements phase in from 2030.
Authorised Representative Provision
Mandatory for non-EU manufacturers and importers: designate an EU-based authorised representative by written mandate and indicate its name and address.
Extended Producer Responsibility
Member States run EPR registration, fee payments and annual packaging-quantity reporting. We assist with registration and producer responsibility organisation (PRO) onboarding.
Recyclability & Recycled Content
From 2030 packaging must be recyclable and graded by performance (A/B/C); plastic packaging must meet phased minimum recycled-content targets in 2030/2040.
Our Services
Full-lifecycle PPWR coverage, from pre-contract assessment to annual reporting and maintenance.
PPWR Representation Agreement
Written authorized-representative agreement defining the scope of mandate, document retention and liability boundaries, compliant with Article 18.
EPR Registration Support
Assist with producer registration, fee payments and annual packaging-quantity reporting in your target Member States, including producer responsibility organisation (PRO) onboarding.
Recyclability Assessment
Assess packaging design and materials against the performance grades (A/B/C), with improvement recommendations to meet the recyclability requirements from 2030.
Recycled Content & Sustainability Assessment
Assess recycled-material use in plastic packaging against the phased 2030/2040 minimum-content targets and propose a compliance roadmap.
Label & Documentation Review
Review the representative indication, material identification markings and Single-Use Plastics Directive requirements on packaging and accompanying documents.
Competent-Authority Communication
As the legal point of contact, receive and relay enquiries, inspection notices and compliance requests from Member State authorities — with bilingual support throughout.
Reporting Support
Assist with annual packaging-quantity reporting, data reconciliation and record keeping — reducing the risk of missed or incorrect filings.
Ongoing Compliance Maintenance
Track PPWR and implementing acts, run annual compliance reviews and manage packaging-design changes.
Our Process
A clear, predictable process — registration and assessment start right after signing.
Needs Assessment
Confirm packaging types, target Member States and applicable obligations; receive a proposal and quote.
Agreement
Sign the PPWR authorized-representative agreement with the authorized products and both parties' duties.
Compliance Assessment
Recyclability, recycled content and labelling assessment with improvement recommendations.
Registration & Marking
Complete Member State EPR registration and update packaging markings before market placement.
Ongoing Maintenance
Annual reporting, regulatory tracking and change management.
Our Advantages
Established EU Entities
Representation through established local entities in Portugal and Estonia — real places of business with local compliance capability.
Bilingual, Zero Time-Zone Friction
Direct communication with our Shenzhen-based team; EU-side partners handle local matters. Correspondence and filings in both languages.
Bundled with EC-REP
Medical-device EC-REP and PPWR packaging representation under one roof — one team, no duplicated onboarding, no information gaps.
Frequently Asked Questions
Who must appoint a PPWR authorized representative?
Manufacturers or importers established outside the EU that place packaging or packaged products on the EU market must designate, by written mandate, an authorized representative established in the EU — per PPWR Article 18. Medical device manufacturers' packaging is covered too.
When does the PPWR start to apply?
The PPWR was published on 22 January 2025, entered into force on 11 February 2025 and applies from 12 August 2026. Substantive requirements such as recyclability and recycled content phase in from 2030.
Is the PPWR representative the same as the medical-device EC-REP?
No. They belong to different regulations (PPWR 2025/40 vs MDR/IVDR) with independent obligations and separate labelling indications — but the same provider can handle both, and we bundle them.
What is the difference between EPR registration and the authorized representative?
EPR (extended producer responsibility) covers the producer's registration, fees and packaging-quantity reporting, managed by each Member State separately. The authorized representative is the non-EU producer's legal point of contact in the EU. Both are prerequisites — and we handle both.
What must be indicated on the packaging?
Besides the authorized representative's name and address, material identification markings and Single-Use Plastics Directive indications may apply. We review labels and documentation before market placement.
What are the recyclability performance grades?
From 2030, packaging must be recyclable and assessed against performance grades (A/B/C): packaging below grade C cannot be placed on the market, and from 2035 it must also meet recycled-at-scale conditions. Assess your packaging early and leave time for redesign.
How are the fees calculated?
Fees typically comprise a contracting assessment fee and an annual maintenance fee, determined by packaging volumes and target Member States (EPR registration and reporting fees are charged separately by the Member States). Submit your product information via the contact page and we will quote within 24 hours.
Placing packaging on the EU market?
Submit your packaging information and target Member States — receive a proposal and quote within 24 hours.