How a US Shopify or Amazon Seller Appoints an EU Authorized Representative

If you sell into the EU through Shopify or Amazon, the PPWR isn’t an abstract regulation — it shows up as a field you can’t leave blank and a listing that gets suppressed. Here’s the practical path from “I think this applies to me” to “I’m compliant and still selling.”

Why marketplaces are the pressure point

Marketplaces are legally on the hook to check that their sellers meet extended producer responsibility (EPR) rules. So they’ve turned the law into a data field: in markets like Germany and France, Amazon already asks for your EPR registration numbers and will restrict listings without them. Expect packaging to follow the same enforcement pattern the electronics and battery streams already did.

Shopify doesn’t police you the way a marketplace does — you’re the merchant of record — but that cuts both ways: nobody is holding the compliance for you.

The steps

1. Confirm you’re the producer. If you’re a US seller shipping your own branded, packaged goods to EU consumers with no EU legal entity, you’re very likely the producer on the hook (see our self-check).

2. List your target member states. Registration is national, so start from where your orders actually go. You don’t have to open all 27 — sequence by volume.

3. Appoint an authorized representative in each of those states. This is a written mandate to a locally established representative who registers you and stands in for your EPR obligations. This is the step that takes weeks rather than the quarters a subsidiary would.

4. Register and collect your numbers. Your representative registers you with each national packaging register or eco-organization — for example Germany’s LUCID packaging register, or France’s EPR unique identifier — and you receive the registration numbers.

5. Put the numbers into your marketplace account. Add them to Amazon’s compliance/EPR dashboard for each country so your listings stay live. For Shopify, keep them on file and on your invoices.

6. Handle your other streams. If you sell electronics or anything with a battery, those are separate EPR registrations (WEEE, batteries) with their own numbers — don’t solve packaging and forget the rest.

Two traps to avoid

• The “one EU office” shortcut doesn’t work. A branch office can’t act as your importer under the Commission’s guidance — you need either a subsidiary per market (slow) or a representative (fast).
• Northern Ireland is not a 28th market. Its packaging EPR runs under the UK’s scheme, not the EU’s — a representative offering you an EU authorized rep “for Northern Ireland” has misread the rule.

The realistic timeline

Collecting Declarations of Conformity from your suppliers is the long pole — it depends on third parties who may never have heard of PPWR. Start that now, appoint representatives in your top markets in parallel, and you can be selling again in weeks, market by market, rather than waiting to solve all 27 at once.

Want this handled end to end — representation, registration numbers, and the marketplace paperwork? See how our EU authorized representative service works, or read the full PPWR breakdown.

This article is general information, not legal advice. Marketplace requirements and national registration steps vary by member state and change over time.