Authorised representatives handle key compliance tasks such as registration, reporting, and packaging licensing under Extended Producer Responsibility (EPR) rules. However, these services create extra costs and administrative work, particularly for small businesses selling into multiple EU markets. As a result, some retailers have already reduced or stopped cross-border shipping because compliance is no longer economically viable.
According to the Händlerbund, appointing an authorised representative typically costs between 300 and 500 euros per country per year, regardless of whether a retailer sends a few parcels or large quantities. Within take-e-way’s partner network, the authorised representative for packaging costs an average of just 180 euros per year.
The European Commission is discussing ways to reduce the compliance burden, including a more flexible enforcement approach. However, removing the authorised representative requirement could create significant new challenges.
A compliance and competition issue
From VERE’s perspective, authorised representatives help authorities enforce packaging rules and provide a local point of contact for compliance matters. This can be particularly important when dealing with suppliers from outside the EU who may otherwise be difficult to monitor or hold accountable. Without effective enforcement mechanisms, compliant businesses could face increasing competition from companies that ignore registration and EPR obligations while continuing to access EU markets. VERE therefore argues that the current system can help protect compliant European businesses from unfair competition while somewhat maintaining a level playing field.
As discussions about PPWR simplification continue, the debate is no longer only about compliance costs. It is increasingly about how to balance administrative relief with effective market surveillance and fair competition across the EU.
VERE e.V. is in contact with all relevant stakeholders and keeps its members informed of further developments via the “VERE Insider”.
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