EU Authorized Representative vs. Responsible Person vs. EPR: What US Sellers Keep Confusing

If you sell into the EU, you have probably run into three phrases that sound interchangeable and are not: authorized representative, responsible person, and EPR registration. Getting them mixed up is the fastest way to either over-buy compliance you don’t need or miss one you do. Here’s the clean version.

1. The GPSR “Responsible Person” — product safety

Since 13 December 2024, the EU’s General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) says no consumer product can be placed on the EU market unless there is an economic operator established in the EU responsible for it — a manufacturer, importer, authorized representative, or fulfilment service provider. Their name and address must appear on the product or its packaging.

This is about safety: technical documentation, corrective actions, and being the contact for market-surveillance authorities. It’s one responsible person for the EU, tied to the product.

2. The PPWR “Authorized Representative” — packaging waste

This is the newer one, in force since 12 August 2026. Under Article 45 of the PPWR, a producer not established in a member state must appoint an authorized representative for extended producer responsibility — for the packaging.

The logic is completely different from GPSR. It’s not one for the EU; it’s one per member state where you first make packaging available, because packaging-waste registration is national. It’s about who pays for and reports the end-of-life handling of your boxes, labels, and fillers.

3. “EPR registration” — the thing the representative actually files

Extended Producer Responsibility (EPR) is the principle — producers fund the collection and recycling of what they put on the market. EPR registration is the concrete act: signing up with a national register or eco-organization, getting a registration number, reporting quantities, and paying fees.

And packaging is only one EPR stream. Batteries, electrical and electronic equipment (WEEE), textiles, tyres, and oils each have their own EPR registration, their own fees, and sometimes their own representative requirement. You can hold several at once — one per country, per stream.

Putting it together

A US company selling a packaged electronic gadget direct to EU consumers can, realistically, need all three at once:

• a GPSR responsible person for the product’s safety,
• a PPWR authorized representative for the packaging, in each member state, and
• separate EPR registrations for the packaging and for the electronics (WEEE) and any batteries.

That sounds like a lot because it is — but each piece is knowable, and one provider can coordinate them so you’re not managing a dozen relationships yourself.

The takeaway

“Responsible person” is safety. “Authorized representative” is packaging waste, per country. “EPR registration” is the filing underneath it. If a vendor uses them interchangeably, slow down — the details decide what you actually have to file, and where.

Not sure which of these apply to your products? See our PPWR self-check for US sellers, or learn how our EU authorized representative service coordinates it.

This article is general information, not legal advice. Your exact obligations depend on your products, packaging, corporate structure, and destination markets.