PPWR Article 45: EPR & Authorised Representatives
What does Article 45 actually cover?
Article 45 addresses extended producer responsibility for packaging. It should not be reduced to a universal statement that every overseas seller automatically needs the same representative arrangement. First determine the producer profile and market; then identify the applicable EPR, representation and reporting duties.
Written mandates and third-country producers
Article 45(3) links written EPR representation to the producer profiles in Article 3(1)(15)(c) and (d). The same paragraph allows member states to require an EPR representative for producers established in third countries. US, UK and Chinese businesses therefore need a country-specific assessment; the rule should not be presented as identical in all 27 countries.
Platform verification: distinguish the legal rule from rollout
Article 45(4) concerns information online platforms obtain from producers. Current Commission guidance explains that the new harmonised-register process is not yet a blanket obligation for platforms to ask for an EPR number. Existing national obligations and platform policies must still be checked by country and waste stream. A future legal framework is not evidence that Amazon has already blocked all non-compliant listings.
A practical next step
Record the selling entity, establishment, products, destination countries, sales channels and existing registrations. Ask for a written scope covering any mandate, filing and reporting tasks. Treat GPSR product safety as a separate appointment and service.