This is the regulation's most onerous obligation for a maker shipping within the EU. Since 12 August 2026, the PPWR has required two things in each country where you place packaged products on the market: registration on the national producer register (Article 44, through existing registers until PPWR registers are available) and, if you are not established in that country, appointment of a local extended producer responsibility authorised representative (Article 45). There is one representative per country, with no European one-stop shop. France has applied this rule since 10 July 2026 (Article L. 541-10-9-1 of the French Environmental Code): a seller established outside France shipping there must appoint an authorised representative, even if it already pays its EPR fees. If you are established in France, this national requirement does not affect you. You have 3 options: limit shipments to countries that justify this cost (a perfectly legitimate strategy), use specialist providers pooling representation and declarations country by country or sell through channels that handle these obligations. In December 2025, the Commission proposed suspending this authorised representative obligation until 2035 for sellers established in the EU. The Council rejected the suspension in June 2026, and Parliament is discussing a suspension limited to companies with fewer than 50 employees. Nothing has been adopted: the obligation applies, and we will update this page as soon as the situation changes. To identify your specific situation, check it with 3 questions. Our dedicated article on the EPR authorised representative sets out the steps.
Read the source article: PPWR small business obligations: the micro-enterprise rule