No. Software can prepare, calculate and track, but the representative has to be a person or company, established in the country, holding a written mandate.
By Razvan Toma · Founder · Last checked 31 October 2026 · Sources below
The EU Packaging Regulation (PPWR) requires a producer selling directly to end users in a country where it isn't established to appoint an authorised representative there, by written mandate. National rules add detail. In Germany the representative needs a seat in the country and the mandate must be in German. In Spain the representative must be established in Spain.
Software is the right tool for the data: which countries a seller ships to, which streams apply, how many kilos of each material, which deadline comes next. It can also collect a signature and show status. None of that makes it the representative.
Related: From orders to declarations
The representative takes on the producer's obligations in that country, is named in the register, and answers to the authorities. If a tool's vendor doesn't hold a mandate in the country, someone else has to, and the client should know who.
Related: Choosing an EPR provider
Ask three questions: which legal entity is named in the mandate, where is it established, and in which register does it appear? A provider that offers representation should answer all three in writing, per country.
Related: White-label EPR
France, Germany and Spain through one partner: a branded referral page with 20% of what your client contracts, or white label by agreement.