PPWR authorized representative vs GPSR Responsible Person
9 min readRepresenta GmbH
PPWR authorized representative, GPSR Responsible Person, cosmetics Responsible Person: what each EU role covers and which ones non-EU makers need.
A PPWR authorized representative, a GPSR Responsible Person, an EU Authorized Representative and a cosmetics Responsible Person sound alike, but they rest on different laws. One address on your label does not cover all four. Here is what each role does and which ones a manufacturer outside the EU typically needs.
The GPSR Responsible Person: your EU contact for product safety
Since 13 December 2024, a consumer product may only be placed on the EU market if an economic operator established in the EU is responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020 (opens in a new tab) (Articles 16(1) and 52 of the General Product Safety Regulation (EU) 2023/988 (opens in a new tab), GPSR). This Responsible Person can be an EU manufacturer, an importer, an Authorized Representative with a written mandate or, as a fallback, a fulfilment service provider (Article 4(2) of Regulation (EU) 2019/1020; decision path in Who can be your GPSR Responsible Person). Its tasks show what the other roles do not cover:
- Documents: verify that the technical documentation exists and can be provided to authorities (Article 4(3)(a) of Regulation (EU) 2019/1020).
- Authorities: answer reasoned requests, report risks and cooperate on corrective action (Article 4(3)(b) to (d)).
- Checks and accidents: where the risks justify it, check products against the technical documentation and have accidents notified through the Safety Business Gateway (Articles 16(2) and 20(4) GPSR).
- Visibility: name, postal and electronic address on product, packaging, parcel or accompanying document and in every online offer (Articles 16(3) and 19(b) GPSR).
For CE-marked products under the acts listed in Article 4(5) of Regulation (EU) 2019/1020, such as toys and electrical equipment, the same role follows from Article 4 of that Regulation; Article 16 GPSR does not apply to them (Article 2(1)(b) GPSR).
The EU Authorized Representative: a mandate that needs the right tasks
An Authorized Representative is a person established in the EU with a written mandate to act for the manufacturer on specified tasks (Article 3(9) GPSR). Under the GPSR, the appointment is optional; the mandate covers at least documents for authorities, informing you of dangerous products, notifications in the Safety Business Gateway and cooperation with authorities (Article 10 GPSR).
It becomes your Responsible Person only if the mandate also assigns the tasks of Article 4(3) of Regulation (EU) 2019/1020 (Articles 4(2)(c) and 5(1); Commission GPSR guidelines, sections 3.1.2 and 3.2). For the comparison with an importer, see Authorized Representative or importer.
The PPWR authorized representative: packaging waste, country by country
Since 12 August 2026, the Packaging and Packaging Waste Regulation (EU) 2025/40 (opens in a new tab) (PPWR) applies (Article 71). It separates two actors that product law does not.
The authorized representative for extended producer responsibility (EPR), in the Regulation's words the "authorised representative for the extended producer responsibility", is established in the Member State where the producer first makes packaging available and fulfils the producer's obligations there (Article 3(1), point (20)): registration, annual reporting and paying for the collection and recovery of packaging waste (Articles 44 and 45; Commission guidance C/2026/3084, section 3).
Who needs one: a producer selling directly to end users in a Member State where it is not established, for example from its own web shop, appoints one by written mandate in each such Member State (Article 45(3), first sentence; Article 3(1), point (15)(c) and (d)). From producers established outside the EU, each Member State may expressly require the appointment (Article 45(3), second sentence; recital 123). Without registration, you may not make packaging available there (Article 44(4)).
Who usually does not: if an EU importer or retailer buys your goods and first makes them available in its own country, it is the producer there (Article 3(1), point (15)(b)).
A packaging manufacturer may also appoint an authorized representative under Article 17 PPWR to keep its declaration of conformity and technical documentation available to authorities. Batteries have their own EPR representative (Article 56(3) of Regulation (EU) 2023/1542; see the Batteries Regulation in 2027).
Where the PPWR representative stands
When this article was checked on 28 September 2026, the Commission had not yet adopted the harmonised format for registration and reporting (Article 44(14)). Member States then have 18 months to set up their registers (Article 44(1)). A Commission proposal of December 2025 would suspend Article 45(3) until 1 January 2035 and leave producers from outside the EU to the Member States (COM(2025) 982, Article 2); according to the European Parliament, Council negotiations on it were discontinued.
The cosmetics Responsible Person: a role of its own
Cosmetic products need a Responsible Person designated in the EU under Regulation (EC) No 1223/2009 (opens in a new tab) (Article 4(1)). For imported cosmetics, this is each importer for the products it places on the market, unless it designates another EU person by written mandate (Article 4(5)).
The role is broader than under the GPSR: compliance with the Regulation's core requirements, a product information file kept for ten years after the last batch, notification to the Commission before placing on the market, and name and address on container and packaging (Articles 5(1), 11(1), 13(1) and 19(1)(a)). The GPSR rules on the Responsible Person do not apply to cosmetics (Article 2(1)(b) GPSR).
The roles at a glance
| Role | Legal basis | Main tasks | Who needs it |
|---|---|---|---|
| GPSR Responsible Person | Article 16 GPSR; Article 4 of Regulation (EU) 2019/1020 | Documents, authorities, product checks, accidents | Consumer and most CE products from outside the EU; EU-wide |
| EU Authorized Representative | Article 10 GPSR; CE sector law | Tasks in the mandate; Responsible Person only if assigned | Optional; the usual route for direct sales |
| PPWR representative for EPR | Articles 3(1)(20), 44 and 45 PPWR | Registration, reporting, EPR obligations | Direct sellers to end users; one per Member State |
| Cosmetics Responsible Person | Article 4 of Regulation (EC) No 1223/2009 | Compliance, product information file, notification, label | Every cosmetic product; by default the importer |
Which roles a manufacturer outside the EU typically needs
Check in this order:
- Consumer or CE product sold in the EU? You need a Responsible Person; if no importer covers all channels, mandate an Authorized Representative for the Article 4(3) tasks.
- Selling directly to end users in a Member State, from your own shop or through a marketplace? You are usually the PPWR producer there (Article 3(1), point (15)(d)): register, and appoint an EPR representative where Article 45(3) and national rules require one.
- Cosmetics or batteries in the range? Add the cosmetics Responsible Person and check the separate EPR rules for batteries.
Practical example: a U.S. outdoor brand with two channels
A U.S. brand sells folding camping chairs (GPSR products without CE marking) and sunscreen (a cosmetic product):
| Channel | Product safety | Packaging (PPWR) |
|---|---|---|
| Own web shop, chairs shipped from the U.S. to consumers in Germany and France | No importer: a mandated Authorized Representative as Responsible Person | The brand is the producer in both countries: registration, EPR representative where required |
| Chairs and sunscreen on pallets to a Dutch outdoor retailer | Chairs: the retailer as importer, or the representative. Sunscreen: the retailer as cosmetics Responsible Person unless it designates another | The retailer is the producer in the Netherlands |
One mandate covers the chairs in both channels; packaging duties depend on channel and country, and the sunscreen needs its own role.
Common mistakes with EU representative roles
- One address for everything. A Responsible Person does not register your packaging, and an EPR representative does not answer market surveillance authorities on product safety.
- Leaving it to the marketplace. On a written mandate, a platform can pay your EPR fees, but registration and reporting stay with you, your producer responsibility organisation or your representative (Article 45(4) PPWR; Commission FAQ, section XVIII).
- Waiting for the omnibus. The suspension is only proposed and would still let Member States require a representative from producers outside the EU (COM(2025) 982, Article 2).
Conclusion: separate roles, separate mandates
Without a Responsible Person, your consumer product may not be placed on the EU market at all. Packaging waste and cosmetics need roles of their own. Map your products and channels once, then assign each role in writing.
Representa acts as your GPSR Responsible Person in the EU: we review labeling and manuals, keep your compliance files ready for inspections and handle communication with authorities. For CE-marked products, we act as your EU Authorized Representative by written mandate and maintain your technical documentation for 10 years.
Frequently asked questions
Is a PPWR authorized representative the same as an EU Authorized Representative?
No. The PPWR representative for extended producer responsibility handles registration, reporting and the producer's other EPR obligations in one Member State (Article 3(1), point (20), PPWR). An EU Authorized Representative under product law acts for the manufacturer toward market surveillance authorities.
Do I need a PPWR representative if I only sell to an EU importer?
Usually not. An importer or retailer established in a Member State that first makes your packaged products available there is the producer (Article 3(1), point (15)(b), PPWR). You become the producer where you sell directly to end users in a Member State.
Can one company be my Responsible Person and my PPWR representative?
Only with separate mandates and where it meets each role's requirements: the Responsible Person must be established in the EU (Article 16(1) GPSR), the EPR representative in the Member State concerned (Article 3(1), point (20), PPWR).
Does a cosmetic product need a GPSR Responsible Person?
No. Cosmetics need a Responsible Person under Article 4 of Regulation (EC) No 1223/2009, usually the importer. The GPSR rules on the Responsible Person do not apply to products covered by EU harmonisation legislation such as cosmetics (Article 2(1)(b) GPSR).
Since when does the PPWR apply?
Since 12 August 2026 (Article 71 PPWR). Some duties start later: the harmonised material label from 12 August 2028 at the earliest (Article 12(1)), and first reports in the harmonised register format by 1 June 2030 according to the Commission's FAQ.