Not for EPR, unless it is established in that country and accepts the obligations. The Article 45 authorised representative must be established in the country of sale: a French consultancy or supplier therefore cannot be your EPR authorised representative in Spain or Belgium. And it is not the same job: the authorised representative carries your producer responsibility (membership, unique identifier, declarations, fees) and does not advise, while your supplier answers for the conformity of the packaging it sells you, not for that responsibility. Not to be confused with the Article 17 authorised representative for conformity, optional and established anywhere in the Union, which keeps the manufacturer's declaration of conformity at the disposal of the authorities. A consultancy's role comes upstream: mapping flows by country, settling who is the producer of what and selecting the authorised representative provider.
Read the source article: French EPR authorised representative: who must appoint one