EU authorised representative mandates in 2026: formal requirements by country (and the 12 August PPWR deadline)

An authorised representative (AR) mandate is easy to mistake for paperwork: a producer signs a document, the agency files it, everyone moves on. In reality a mandate is a legal relationship with statutory formal requirements, a validity period, a registry-facing confirmation status and real consequences on termination. Agencies that manage hundreds of them in a contract drawer and an Excel sheet are carrying more risk than they can see — and 2026 is the year that book of mandates is set to multiply.

12 August 2026: the PPWR deadline

Under Article 45(3) of the EU Packaging and Packaging Waste Regulation (PPWR), from 12 August 2026 producers without an establishment in an EU country who sell packaged goods there by distance sale must appoint an authorised representative in every EU country they sell packaging into. A seller shipping to consumers in Germany, France and Austria will need an AR in each of the three — not one AR for the EU. For non-EU e-commerce sellers this converts the AR from a per-market option into a per-market precondition for selling at all.

Two practical consequences follow for agencies. First, volume: a client list that today carries one or two mandates per producer becomes a matrix of producers × countries. Second, heterogeneity: each mandate has to satisfy the formal requirements of its own country's law, and those requirements differ. (At the time of writing there is political discussion about deferring parts of the obligation — the source above tracks the current state — but agencies that wait for a deferral that may not come are gambling with their clients' market access.)

Germany, WEEE: ElektroG §8

For electrical and electronic equipment, ElektroG §8 sets out the formal requirements for appointing an authorised representative in Germany. The appointment must be made in writing and in German, must be effective for at least three months, and each manufacturer may appoint only one authorised representative at a time. The AR is registered with stiftung ear, the national WEEE register, and changes to the appointment run through the ear portal.

These are not stylistic preferences — a mandate that fails the form requirements fails as a mandate. An agency onboarding a non-EU electronics producer should be able to show, for each mandate, that the written-form, language, duration and single-representative requirements were checked before the mandate was treated as active.

Germany, packaging: VerpackG §35 — and the registration nobody can do for the client

For packaging, VerpackG §35 allows a producer without a German establishment to appoint a single authorised representative, again in writing and in German. But the packaging regime contains a trap that surprises many sellers: registration in the LUCID packaging register is a personal obligation of the producer. As the register operator's own guidance puts it, LUCID registration must be completed by the obligated company itself and cannot be delegated to the authorised representative. The AR can take over system participation, data reporting and the rest — but only after the producer has registered in their own name.

For agencies this is a delegation boundary worth making visible in every client-facing surface: if a client believes 'the agency handles everything', the one obligation that legally cannot be handled for them is exactly the one that will lapse. Software should mark these non-delegable obligations explicitly rather than leaving the distinction to an onboarding call.

Mandates cost money at the registry

Mandate events also trigger registry fees, which agencies typically advance and re-invoice. For WEEE authorised representatives, stiftung ear's fee schedule charges per represented company: a €9.50 registration fee and a one-time €50.60 confirmation fee for the authorised-representative relationship, plus an ongoing fee of €32.80 per company per quarter. Multiply by a book of fifty represented producers and the administrative fee line becomes a real reconciliation task of its own — another reason mandate events belong in a system rather than a memory.

Changing representatives: what good looks like

Mandates end: producers switch agencies, agencies resign accounts, companies restructure. The cleanest description of a well-managed changeover in EU law comes from an adjacent regime — Article 12 of the Medical Device Regulation (EU) 2017/745 requires the detailed arrangements of an AR change to be defined in an agreement between the manufacturer, the outgoing AR and the incoming AR, covering the termination and start dates and the transfer of documentation. Even where your regime does not mandate it, that three-party structure — explicit dates, explicit document handover, explicit responsibility for the gap — is the template worth copying for EPR mandates too.

Whatever the regime, the operational minimum on termination is the same: notify the registry through the prescribed channel, and archive the registry's confirmation with the mandate record. The termination is not 'done' when the client relationship ends; it is done when the register reflects it.

Running mandates as records, not documents

The pattern across all of the above: a mandate has a lifecycle — drafted, checked against its country's formal requirements, active, approaching expiry, terminated — and each stage has evidence attached. Complywerk models exactly that: mandates as first-class records per client, country and stream, with country-specific formal-requirements checklists recorded per your licensed review, expiry reminders through the same engine that tracks filing deadlines, and termination checklists that create the registry-notification task automatically. When the PPWR multiplies your mandate book next August, the difference between a drawer of PDFs and a system of record will be measured in missed renewals.

This article is general information about formal requirements, not legal advice. Mandate templates and the legal sufficiency of any specific appointment should be confirmed by qualified counsel in the relevant country.