Packaging-EPR Authorised Representative vs Product-Safety Authorised Representative

Quick answer: "EU authorised representative" refers to two different roles. A product-safety authorised representative handles product conformity (technical file, EU declaration of conformity, market-surveillance contact) under the GPSR and the CE regime. A packaging-EPR authorised representative carries your packaging producer obligations under PPWR Article 45 (registration, reporting, scheme contact), per country. You may need one, the other, or both.

TL;DR

Two roles share the name authorised representative. One is about whether your product is safe and conformant; the other is about who is registered and reporting for your packaging in each country. They are not interchangeable and they are priced differently.

Why the confusion exists

Both roles use the phrase authorised representative and both exist because you are a non-EU company selling into the EU. But they answer different questions. The product-safety AR answers: is this product safe and conformant, and who in the EU is accountable? The packaging-EPR AR answers: who is registered and reporting for the packaging in each country? A supplier can be covered on one and exposed on the other.

The two roles side by side

Which do you need?

• Sell CE-marked or general consumer products into the EU without an EU entity: you likely need a product-safety authorised representative.
• Place packaging on EU markets (almost every physical-goods seller): you need a packaging-EPR authorised representative in each in-scope country from 12 August 2026.
• Most physical-product sellers need both, because the product and its packaging are regulated separately.

How this maps to EcoComply's services and pricing

• Product-safety authorised representative - the EU Authorised Representative service, from €1,500 per product category per year. See EU Authorised Representative.
• Packaging-EPR authorised representative - included in packaging PPWR/EPR compliance at €1,000 per country per year, alongside registration and reporting. See EPR registration.
• Full EPR across all streams (packaging, batteries, electronics) - €2,000 per country per year, which includes the EPR-mandated authorised representative for those streams.

The €1,000 packaging price is not the same as full EPR; if you have batteries or electronics as well as packaging, the €2,000 full-EPR scope applies.

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FAQs

Is a packaging-EPR authorised representative the same as a product-safety authorised representative?

No. A product-safety AR handles product conformity under GPSR and the CE regime. A packaging-EPR AR handles packaging producer obligations under PPWR Article 45, per country.

Do I need both authorised representatives?

Often yes. If you place a regulated product on the EU market you may need a product-safety AR; if you place packaging on national markets you need a packaging-EPR AR in each in-scope country.

How many packaging-EPR authorised representatives do I need?

One per country where you place packaging on the market, under PPWR Article 45 - not a single EU-wide appointment.

How much does each cost?

EcoComply's product-safety EU authorised representative is from €1,500 per product category per year; the packaging-EPR authorised representative is included in packaging PPWR/EPR compliance at €1,000 per country per year. Full EPR across packaging, batteries and electronics is €2,000 per country per year.

Does one authorised representative cover the whole EU?

A product-safety AR often can. A packaging-EPR AR cannot - it is appointed per country under PPWR Article 45.