Extended Producer Responsibility (EPR)
What is EPR?
Example: EPR compliance – multi-market distribution
Challenge
- Separate registration in each country
- Knowledge of and compliance with different fees, deadlines, and formats
- Burden on internal resources due to administration
Solution
Collaboration with an authorized representative for the respective countries, who takes care of all EPR tasks—from registration and reporting to submitting evidence.
- Harmonised registration obligations in all EU countries
- Standardised data and reporting obligations
- Predictable costs and reduced administrative burden
- Provision of an authorised representative if your company is not established in Germany or has a branch abroad
Advantages of an authorized representative
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Less administrative work
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Compliance with legal requirements/legal conformity
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Full delivery capability in all markets
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Focus on core business
Differing rules, reporting obligations and fees
Different registration and reporting requirements in each country
Varying fee models and calculation bases
Different data and reporting obligations
Various labelling and design standards
EPR under the PPWR – uniform standards for all
Each country has its own requirements – from registration to fees.
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Separate registration processes in each country
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Different portals and deadlines
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Varying fee models
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Country-specific labelling and design standards
Uniform rules provide clarity and reduce effort.
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Harmonised registration requirement in all EU countries
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Standardised data and reporting obligations
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Common calculation bases for fees
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Uniform design and labelling requirements
| ASPECT | TODAY | UNDER PPWR |
|---|---|---|
| REGISTRATION | Separate for each country, different requirements | Harmonised, identical core requirements |
| REPORTING OBLIGATIONS | Country-specific | Uniform formats and definitions |
| LICENCE FEES | Vary by country | Aims for uniform licence fees |
| DESIGN REQUIREMENTS | Mostly only national ecodesign requirements | EU-wide binding minimum standards |
| LABELLING | Varies, often with country-specific mandatory labelling | Uniform EU labelling |
| AUTHORISED REPRESENTATIVE | Mandatory in some cases | Mandatory in all countries without a branch |
| CONTROL MECHANISMS | National market surveillance, varying verification priorities in some cases | Controls and data exchange coordinated EU wide |
| DATA AND REPORTING OBLIGATIONS UNDER THE EPR SYSTEMS | Different transparency and reporting obligations | Uniform minimum transparency obligations and reporting standards |
| SCOPE OF PRODUCER RESPONSIBILITY | Often only costs for collection and recycling are covered | Extended to include financing of information campaigns and waste prevention measures |
The PPWR creates a single EU framework for packaging design and recycling.
Harmonised rules
Less effort
More certainty
Authorized representatives according to PPWR
‘Authorised representative’
for producers
[Article 17]
The authorised representative can be appointed by the producer of packaging or packaged products to take on certain obligations of the producer in accordance with the PPWR. They act on behalf of the producer and perform certain tasks, such as compliance obligations, preparing the necessary evidence or communicating with authorities. In this way, the authorised representative supports the producer in complying with the legal requirements of the PPWR.
‘Authorised representative’ for extended producer responsibility
for manufacturersUnder the PPWR, an authorised representative is required in particular when companies place packaging or packaged products on the market in EU Member States where they do not have their own establishment (Article 44). In this case, the authorised representative assumes the tasks of extended producer responsibility (EPR), including: registration in the respective Member State, quantity reports, reports and ongoing communication with authorities. In this way, the authorised representative ensures that manufacturers can fulfil their EPR obligations in a legally compliant manner throughout the EU.
‘Authorised representative’ under VerpackDG (Section 5)
Germany (from 12 August 2026)For producers without an establishment in Germany who place packaging or packaged products on the German market for the first time, the following applies:
- The authorised representative must be appointed before the first placing on the market in Germany
- The power of attorney must be granted in writing and in German
- The authorised representative must be notified to the ZSVR without undue delay after appointment
- The notification is made as part of the registration process; confirmation by the ZSVR is required
- Registration and data reporting cannot be carried out by the authorised representative – these obligations remain with the producer
We’re here to help you.
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Training and advice without further operational effort
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Recording of your country-specific master data and volumes
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Registration with authorities and/or in systems
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Contract management
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Organisation and appointment of an authorised representative
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Volume reporting and data management
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Invoice validation and complaints management
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Handling of all correspondence with authorities and systems
Zentek – 360° service EPR compliance
The Zentek Group offers comprehensive support for fulfilling EPR obligations in European markets. This includes registration-related services, country-specific advice and the assumption of operational obligations within the framework of Extended Producer Responsibility.
Expertise