Regulation (EU) 2025/40 (PPWR) distinguishes conformity authorised representatives from authorised representatives for extended producer responsibility (EPR). This guide covers confirmed PPWR text for distance sellers (Art. 45(3)) and quotes Art. 44(4) on producer registration without asserting when it already applies in practice. Product Registry helps you record per-market EPR facts and an org-wide summary; it never files EPR for you.
Art. 45(3): mandate in each other Member State
Article 45(3) PPWR states: "A producer referred to in Article 3(1), point (15)(c) and (d), shall appoint, by written mandate, an authorised representative for the extended producer responsibility in each Member State where the producer makes packaging or packaged products available for the first time, other than the Member State where the producer is established."
Producer types (c) and (d) in Article 3(1)(15) cover distance selling scenarios. Confirm how your business is classified with your adviser before appointing a representative.
Art. 44(4): registration wording
Article 44(4) PPWR states: "Producers shall not make available packaging or packaged products on the territory of a Member State for the first time on the market of that Member State if they or, where applicable, in accordance with Article 45, their authorised representatives for the extended producer responsibility are not registered in that Member State."
Whether this already applies before new national PPWR registers are fully operational, and whether existing national EPR registers count, is to confirm with your adviser. Product Registry does not interpret national register law.
Track facts in Product Registry
On each SKU, use the PPWR markets tab to record roles, register names, PRO contacts and whether you flagged a distance-seller EPR authorised representative for that country.
Use the org-wide EPR registration summary under Markets to print or download CSV rows for every packaging unit and channel country, including gaps still missing data.
How Product Registry helps
Product Registry stores your declarations and evidence paths. It does not appoint representatives, does not register producers with national bodies and does not compute EPR fees.
For authority hand-over after a reasoned request, use the separate authority request mode on a packaging record. That workflow is described in the PPWR authority request guide.
Primary legal text
Product Registry organises evidence and inspection files. It is not legal advice and does not file anything with an authority for you.