Before Brexit, a UK company selling into the EU was an EU company. That changed the moment the UK left the single market. Now a UK seller faces the same authorised representative obligation as a US or Chinese seller — and a lot of UK businesses haven't noticed yet.
TL;DR — Brexit made the UK a third country, so UK sellers now face the same EU authorised representative obligation as any non-EU seller — one AR per country of sale, from 12 August 2026.
Brexit changed your status
Under EU law, a "third country" is any country that is not an EU member state and not part of the European Economic Area. Since 1 January 2021, the UK is a third country. That single change ripples through every EU compliance framework — and it applies fully to the PPWR (Regulation (EU) 2025/40).
In practice: a UK company selling packaged goods into Germany, France or Belgium is now treated exactly like a US or Chinese company. Your UK company number means nothing to an EU packaging register.
The authorised representative obligation now applies
Article 45(3) of the PPWR requires any producer not established in the country of sale to appoint an authorised representative (AR) established in that country. A UK company is, by definition, not established in any EU member state — so the obligation applies.
This has been in force since 12 August 2026. There is no grace period, and the proposed suspension of the duty (which some UK sellers have read about) was vetoed by the Council in June 2026 — and would only ever have applied to EU micro-enterprises, never to third-country sellers.
One AR per country — no UK-style shortcuts
The UK's own packaging regime (pEPR) doesn't translate. Under the PPWR there is no single EU-wide representative: each member state requires its own AR established in that state. Sell into five EU countries and you need five ARs — five registrations, five declaration calendars, five sets of fees.
What you can do is appoint one coordinating partner that manages the whole set under a single contract, so you deal with one contact and one accountable party rather than five providers.
What actually changed vs before Brexit
To be blunt, the comparison matters because many UK sellers still operate on pre-2021 assumptions:
- Before Brexit: a UK company was an EU-established producer and could register directly with national schemes like Fost Plus or LUCID.
- After Brexit: a UK company is a third-country producer and must appoint an AR in each country of sale before it can register.
If you were registered before Brexit, those registrations are stale — you now need an AR to hold them validly.
What marketplaces will do
From 12 August 2026, Article 45(4) obliges marketplaces — Amazon, eBay, Etsy, and others — to verify sellers' EPR registration numbers before allowing listings in each country. Amazon has enforced EPR deadlines on the day every time. If a UK seller cannot produce a valid registration number for Germany, the German listings get suppressed.
The practical takeaway: if you're a UK seller shipping into the EU, Brexit already made you a third country — and the PPWR has been in force since 12 August 2026. Map your countries, appoint an AR in each, and register before the marketplaces ask.
Sources: PPWR (EU) 2025/40 and the EcomWatch analysis of Article 45.
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