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Authorised Representative (AR): when you need one and how to appoint

Many companies selling into the EU are EPR producers but not established in each Member State. In those cases, law often requires an Authorised Representative (AR) to fulfil packaging, WEEE, battery or textiles obligations locally. This guide explains the triggers, documents, timeline, and a clean appointment process.

Focus: EPR operations Streams: WEEE • Batteries • Packaging • Textiles

When is an AR required?

  • Non‑EU entity selling in the EU. If your producer is not established in the Member State with obligations, an AR is typically required.
  • Distance sales inside the EU. An EU company selling directly to end users in another Member State often needs a local AR in that target state.
  • Marketplace vendors. Some platforms register for parts of EPR, but many laws still require the vendor to appoint an AR.
  • Multiple streams. ARs can cover WEEE, batteries, packaging, and textiles. Scope depends on local law and contracts.

Exact rules vary by country. Always verify per Member State and stream.

What an AR does

Acts locally: represents the producer toward authorities and PROs.
Registers: secures producer IDs and handles enrolment with PROs.
Files & pays: manages reporting deadlines and related fees.
Evidence: keeps records and proof of compliance for audits.

AR appointment — step by step

  1. Confirm producer roles by country. Identify where you are the producer and which streams apply.
  2. Select AR entity. Usually a specialist or partner established in the target country.
  3. Sign Power of Attorney (PoA). Company details, scope (streams), term, and rights to register and file.
  4. Prepare documents. Certificates of incorporation, IDs, VAT/Tax numbers, product and brand list, weight/chemistry/material data.
  5. Register with authority & PRO(s). Obtain producer IDs; onboard to correct schemes.
  6. Operate reporting. Set calendar, data model, evidence pack, and payments.

What we typically need

  • Legal entity details and signatory info.
  • Registered brands and product categories.
  • Sales model (distributors vs end users; marketplaces).
  • Weight/material breakdowns (packaging), categories (WEEE), chemistry & weight (batteries), textile type & SKU mapping (textiles).
  • Sales countries and go‑live plan.
Sample PoA wording

“The Company appoints [AR legal name] as its authorised representative for [streams] in [Member State], to apply for registrations, enter into agreements with Producer Responsibility Organisations, submit reports, and perform acts required by law for EPR compliance.”

Timelines

  • PoA countersignature: 1–5 business days.
  • Authority + PRO onboarding: 1–4 weeks typical (varies by country).
  • Reporting cadence: monthly/quarterly/annual depending on stream and volumes.

Costs to expect

  • AR service fee (per country/stream).
  • Authority registration fees (where applicable).
  • PRO membership & EPR fees based on weights, chemistry, or categories.

Common pitfalls

  • Delaying PoA, which delays producer IDs and first filings.
  • Wrong stream classification or missing embedded batteries.
  • Unstructured data → fee errors and audit findings.
  • Assuming marketplace obligations fully cover the vendor.

FAQs

Can one AR cover multiple streams?

Often yes, depending on local law and the AR’s accreditation with schemes. viron consolidates where possible to reduce administrative overhead.

Do distributors still need an AR?

Distributors typically do not appoint ARs unless they become the producer (e.g., own‑brand or importer). They may still have take‑back and information duties.

We are established in Germany but sell to France. Do we need a French AR?

For distance sales to French end users, AR appointment is commonly required. viron confirms per stream and sets up the appointment.

Need an AR? We’ll appoint and onboard fast

Send a short scope and we return with the per‑country AR requirement, documents list, and producer registration path.

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This article summarises typical AR rules in EPR. It is not legal advice.