An Authorized Representative in Environmental Compliance

An Authorized Representative in Environmental Compliance

Navigating environmental compliance regulations can be complex, especially when expanding into new markets. Regulations like the new EU Packaging and packaging waste regulation, the EU WEEE (Waste Electrical and Electronic Equipment) Directive, and the EU Battery Regulations require businesses to meet specific obligations and have a local presence.

This glossary guide will explain what an authorised representative does and how they support compliance.

What Is an Authorized Representative?

An Authorized Representative (AR) is a person or entity appointed by a company to act on its behalf to meet legal environment compliance obligations in a specific region, which is especially critical for international businesses, where local regulations often require in-country representation.

Role of an Authorized Representative?

Authorised Representatives (ARs) are essential for producers to comply with environmental regulations in countries where they do not have a physical presence. Under local laws, ARs take on the legal obligations of a producer, ensuring compliance with directives. An AR must be appointed in every country where a producer places products on the market without a physical presence.

AR’s responsibilities can include:

  • Compliance Records Management: Preparing and maintaining essential documentation for audits or inspections.
  • Product Registration: Registering products with local compliance schemes, such as electronic waste recycling programs.
  • Legal Representation: Serving as the official point of contact for regulatory bodies.

Who Can Be an Authorised Representative?

Not just anyone can serve as an AR. To qualify, the individual or entity must meet the following criteria:

  • Local Presence: Regulations like WEEE require the AR to be located within the region, such as an EU member state.
  • Impartiality: They must act without conflicts of interest, representing your company transparently and professionally.

 

Many businesses choose specialised compliance firms, experienced consultants, or trusted local subsidiaries to act as their AR.

Navigating Country-Specific Requirements for Authorised Representatives

While the role of an AR remains consistent in its purpose—to act on behalf of the producer to comply with regional laws—the specific requirements and responsibilities can vary widely across countries.

For example, in Spain, foreign clients must possess a Spanish VAT (NIF N) to meet packaging compliance obligations. Meanwhile, businesses selling electronics (EEE) directly to end customers in Poland must appoint an AR who facilitates registration and reporting. In addition, the producer should display the EEE registration number from the AR on invoices in Poland. Similarly, Greece and Latvia require ARs for all products subject to EPR (Extended Producer Responsibility) waste streams. In France, appointing an AR means that the producer needs to report all EEE put on the market, including the EEE sold to distributors.

Some regions, such as Estonia and Cyprus, mention AR requirements in their laws but have not fully implemented them, creating uncertainty for compliance. In Belgium, ARs are only required for WEEE compliance, while in Norway and Slovenia, foreign entities with local VATs can bypass AR requirements under certain conditions. Conversely, countries like Portugal enforce comprehensive AR involvement for WEEE, BAT, and PACK compliance, ensuring thorough management of registration, reporting, and communication with authorities.

Understanding these differences is crucial for businesses. While some countries mandate ARs for specific waste streams, others permit direct registration or impose additional administrative steps, such as Bulgaria’s requirement for a Bulgarian digital signature. By partnering with experienced compliance experts, businesses can navigate these complexities confidently, ensuring adherence to regulations and avoiding potentially costly legal pitfalls.

Supporting Compliance with an Authorized Representative

An Authorized Representative is critical to meeting environmental compliance obligations, particularly for businesses operating in international markets. Their role ensures that companies meet legal regulatory requirements. However, selecting an authorised representative can be an administrative burden; working with experienced compliance experts can simplify the process.

RLG’s environmental consultants provide the expertise needed to:

  • Identify the most suitable AR for your business.
  • Manage registrations, reporting, and regulatory communication.
  • Ensure your company remains compliant with evolving regulations.

 

If you’re ready to appoint an AR or need guidance on compliance, RLG can help you find the best fit for your needs. Compliance can be daunting, but with the right support from us, it doesn’t have to be. Contact us today

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Les Griffith - Speakers

Business Development Director
RLGA

Les Griffith is currently the Business Development Director at RLGA and is tasked with expanding the company’s data management offerings for packaging EPR in the Americas. Les has over 30 years of industry experience in Environmental Services, Extended Producer Responsibility and Reverse Distribution. Les has spent these last 30 years working with organizations to develop progressively more sustainable solutions to the management of end-of-life materials. Prior to joining RLG, Les spent eleven years at Covanta most recently serving as the Business Development Director for the Healthcare Solutions division. His group covered North and Central America and specialized in providing a suite of services to healthcare PROs, take-back services to retail pharmacy and law enforcement and environmental services to the healthcare sector and reverse distributors. Prior to Covanta Les spent 10 years at Waste Management Inc. as an Area Manager for their Healthcare Solutions group.

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Andriana Kontovrakis - Speakers

Director of Compliance Services
RLG

Andriana Kontovrakis is the Director of Compliance Services for Reverse Logistics Group’s US team.  She manages a team responsible for ensuring manufacturer and retailer customer compliance with EPR laws for electronics, batteries, packaging, household hazardous wastes, and other consumer products across the US. Along with RLG partner the Household and Commercial Products Association, she is spearheading the development of the Household Product Stewardship Alliance, a stewardship organization forming under the guidelines of Vermont’s HHW EPR law.  Prior to working with RLG, she was a Policy Analyst with the global electronics recycler Sims Lifecycle Solutions where she managed programmatic implementation and customer and supplier accounts for the US EPR compliance unit and the Deputy Director for Waste Prevention for the NYC Department of Sanitation.

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