compliance teamThe PPWR authorised representative in the Netherlands
Step 1
Assess applicability
Step 2
Define the powers
Step 3
Separate the roles
Step 4
Version the mandate
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
When it applies
Article 45(3) currently requires a producer established in another EU Member State that makes packaging or packaged products available in the Netherlands for the first time directly to the end user to appoint an EPR authorised representative in the Netherlands by written mandate. Distance contracts are included rather than defining the whole scope, and the rule covers producer profiles 3(15)(c) and (d). Article 45(4) separately obliges online marketplaces to obtain registration information and a self-certification from sellers. For a third-country producer the Dutch national choice must be verified rather than assumed.
Applicability is assessed against the facts of the file rather than assumed from the sales channel.
It is not fiscal representation
An EPR authorised representative is not a fiscal representative. The Dutch VAT role imports joint liability and is a different arrangement entirely.
We do not take that role, and we do not sell a Dutch VAT number, a KvK registration or eHerkenning.
What the mandate records
A usable mandate records the powers, their limits, their duration and the separation between representation, filing delegation and any tax role.
Representation does not remove the registration question; the two are documented separately.
Conclusion
Scope comes before a form. Connect the legal entity, product, sales channel and EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. CONAI, public registers, collective systems and marketplaces control their own procedures, timing and decisions.