Authorised representative

Article 45 requires a producer that makes packaging available in a member state where it is not established to appoint an authorised representative in that member state. The appointment is made by written mandate, and it has applied since 12 August 2026.

There is no single-window appointment. One representative is required per member state, so a seller shipping to Sweden, Germany and France needs three. Sweden is what we cover.

The suspension did not apply to you

A proposal to suspend the authorised representative obligation received wide attention and left a general impression that the requirement had gone away. It had not, and the detail matters: the proposed suspension covered producers established in the EU. Producers established outside the EU were excluded from it and remain fully in scope.

If your company is outside the EU, you are therefore in the unusual position of carrying an obligation that some of your EU-established competitors may not. Acting on the headline rather than the text is the most common reason a non-EU producer is unregistered today.

What we do as your representative

• Accept the appointment by written mandate and register it with Naturvårdsverket
• Register you in the Swedish producer register
• Arrange affiliation with an approved producer responsibility organisation
• Submit the annual report by the 31 March deadline
• Act as the contact point for Swedish authorities and answer their enquiries
• Tell you what is coming before it falls due, rather than after

Why this sits with a law firm

An authorised representative carries obligations towards Swedish authorities on your behalf. When a question arrives about how a packaging item is classified, whether a volume was correctly reported, or whether an obligation applies at all, the answer is a legal one. We would rather give it than forward the question to you and wait.

We carry out client due diligence before accepting any appointment, and we need accurate volume data from you to report. We will say so plainly if we cannot act.

What the appointment fee covers. One mandate, one registration with Naturvårdsverket and one round of follow-up questions. Corrections needed because the data you supplied changed, re-registration after a change of entity, and disputes with authorities are charged on a time basis. The annual fee covers the recurring duties described above.