Glossary
Glossary term

authorised representative for extended producer responsibility

A regulatory term referring to a natural or legal person established in a Member State in which the producer places batteries on the market and which i.

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What does authorised representative for extended producer responsibility mean?

This is a distinct role from the general "authorised representative" under the EU Battery Regulation. An authorised representative for EPR is established in the Member State where the non-EU producer places batteries on the market and is specifically mandated to fulfil EPR obligations — collection, take-back, recycling financing, and registration with the national producer register — on behalf of that producer. Every non-EU producer that sells batteries into an EU Member State must either establish a local entity or appoint such a representative in each relevant Member State.

Official definitions by source

EU Battery Regulation

Regulation (EU) 2023/1542 concerning batteries and waste batteries

a natural or legal person established in a Member State in which the producer places batteries on the market and which is different from the Member State where the producer is established, and is appointed by the producer in accordance with Article 8a(5), third subparagraph, of Directive 2008/98/EC to fulfil the obligations of that producer under Chapter VIII of this Regulation;

Reference: Article 3, point 48

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Practical application

This role has direct operational and financial consequences: the EPR representative registers with national authorities, pays EPR fees, and is legally accountable for collection and recycling targets in that Member State. Non-EU e-commerce sellers of batteries, including those embedded in devices, who sell directly to consumers frequently miss this requirement. Each Member State may have different registration procedures, fee structures, and reporting deadlines, requiring a multi-country compliance approach.

Minespider commentary

For Minespider, the EPR representative role is part of the broader actor-mapping challenge: identifying which legal entity in each jurisdiction holds which obligation, so that data flows and compliance evidence can be routed to the right place.

Common confusions

  • Treating the EPR representative as the same role as the general authorised representative under Chapter IV/VI — they are separate roles with separate mandates and obligations.
  • Assuming a single EPR representative can cover all EU Member States — representation must be established in each Member State where the producer places batteries on the market (though some Member States permit representation through producer responsibility organisations that operate across borders).
  • Confusing the EPR representative with a producer responsibility organisation (PRO) — a PRO collectively fulfils EPR obligations for multiple producers; an EPR representative is the individual mandated actor for a specific non-EU producer.