Your EU authorized representative, run by a US company
Since 12 August 2026, packaging placed on the EU market needs a Declaration of Conformity and a locally established representative. We collect the documents, hold the mandates, and answer the authorities. You keep one point of contact, in your time zone, under US contract.
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Certified GSA Schedule Holder - Veteran-Owned (VOSB)
- GSA Schedule Holder
- Meets and exceeds ISO 27001 standards
- Resident representatives across all 27 member states and Northern Ireland
The problem, stated plainly
If your company is not established in an EU member state and you ship packaged goods to customers there, two things are now true.
You need documentation you probably don’t have. Every unique packaging type placed on the EU market requires a signed EU Declaration of Conformity, backed by technical documentation from a conformity assessment. You did not design most of that packaging. Your suppliers did. The documents have to come from them.
You need someone standing in the EU. Under Article 45 of Regulation (EU) 2025/40, a producer not established in a member state must appoint an authorized representative there for extended producer responsibility. One per member state. There is no single filing that covers all 27.
Without both, shipments can be held at the border and marketplaces can delist you. Some US retailers have simply stopped shipping to the EU rather than solve it.
What we do
Declaration of Conformity collection
We run the campaign against your suppliers, in their languages. Request, chase, verify the document is the right one and current, translate where needed, and index it so it can be produced on demand. Most suppliers have never heard of PPWR and will send the wrong document twice before they send the right one. That is the work.
Technical documentation custody
We assemble and hold the technical file to Article 39 and Annex VII standard, retained for the full statutory period and available when a market surveillance authority asks. We meet and exceed ISO 27001 standards, which matters when someone else’s compliance record is sitting in your archive.
Authorized representative mandates
Resident representatives, established in the member state, named on a written mandate and entered in the national producer register. Not a subcontractor performing tasks. The named party of record.
EPR registration and fee handling
Registration with the national scheme in each market, ongoing reporting, and fee payment. Structured as direct pay or escrow to each eco-organization so it does not sit on your balance sheet or ours.
Northern Ireland, handled correctly
PPWR conformity requirements reach Northern Ireland through the Windsor Framework, but the extended producer responsibility provisions do not. NI remains in the UK’s own pEPR scheme. It is a separate workstream, not a 28th EU market. Anyone offering you an Article 45 representative for Northern Ireland is offering you something that does not exist.
Why a US company
Most authorized representative providers are EU brokers selling a mailbox and a registration number. That works until something goes wrong.
One accountable contact. Not a different provider in each of 27 countries.
US contract, US law, US recourse. You are not enforcing an agreement against an entity in a jurisdiction you have never visited.
Your time zone. When an authority in Poland raises a question, you call Texas.
Language capability built in. Supplier chasing, document translation, and authority correspondence in 300+ languages is the business we have been in since 2009. For most AR brokers it is the part they subcontract.
Beyond packaging
PPWR is one stream. If your catalog includes batteries, electronics, tires, textiles, or oils and fluids, each carries its own extended producer responsibility obligations, its own national registration, and often its own representative requirement. A producer can hold several EPR representatives at once, one per country per stream.
We map the full surface before you commit to a reopen date, so the second shutdown does not arrive a month after the first.
How it works
- Scope. Send us a catalog export and your supplier list. We map packaging types, product streams, and destination markets, and tell you what you actually owe where.
- Priority markets. We stand up mandates and registrations in your highest-volume markets first, so revenue restarts in weeks rather than waiting on all 27.
- Documentation. We run the supplier DoC campaign in parallel and build the technical file.
- Rollout. Remaining markets go live in waves. You are billed per market as each one does.
- Maintenance. Annual reporting, fee filings, register updates, and regulatory monitoring. When the rules change, and they will through 2040, you hear it from us first.
Who this is for
- US and other non-EU e-commerce retailers shipping direct to EU consumers
- Manufacturers and brand owners placing packaged goods on the EU market
- Distributors and marketplace sellers facing platform verification requirements
- Any company that has paused EU shipments and wants them back
Frequently Asked Questions
Does an authorized representative have to be a company?
No. The regulation accepts a natural or legal person established in a member state. That is why a resident representative network works and 27 subsidiaries are not required.
Can I just open one EU office instead?
No. The European Commission's PPWR guidance confirms a branch office cannot act as an importer, because it lacks independent legal personality. A non-EU manufacturer with only a branch must either set up a subsidiary or appoint an authorized representative.
Does one representative cover the whole EU?
For conformity purposes, a single mandate can. For extended producer responsibility under Article 45, no. It is one representative per member state, and registration is national. A Spanish registration does not cover Germany.
How long do we have to keep the documentation?
Technical documentation and declarations must be retained and producible on request for years after placing on the market. Retrospective audits are possible, and missing documentation is treated as non-compliance.
We already paused EU sales. Is it too late?
No. Reopening is a documentation and registration project, not a penalty situation. The work is the same whether you paused or never started.
What about the UK?
Great Britain sits outside PPWR and under UK pEPR. A consultation on whether to align GB with PPWR has been signaled but no decision has been taken. Northern Ireland is the split case described above.
Get your EU markets back
Send us a catalog export and we will tell you what you owe, where, and how fast it can be fixed. No charge for the scoping conversation.