News
14 Oct 2026

EPR & Authorised representative

Authorised what? Known for its complexity, the Packaging and Packaging Waste Regulation (PPWR) contains few provisions as convoluted as those governing Extended Producer Responsibility (EPR). Beyond the singe question of ‘who qualifies as a producer’, one particular EPR requirement is giving businesses across the EU a headache: the Authorised Representative, AKA the AR. 

Believe it or not, despite all the recent political attention devoted to strengthening the Single Market, the PPWR requires producers established in a given Member State to appoint an AR for EPR in each EU country where they first make packaging or packaged products available on the market, other than the Member State where they are established. Yes, you got that right, EU law is effectively asking businesses to navigate an additional layer of national representation to operate seamlessly across the Single Market. 

Making amends. An unfortunate legacy of the long and complex negotiations that shaped the PPWR, in December last year the EU Commission stood by its commitment to the Union Market and put forward an Omnibus proposal to suspend the requirement under several pieces of EU legislation for operators established in the EU, until 1st January 2035.  

The rationale is straightforward: businesses already established within the Union should not have to contend with an additional layer of administrative burden when operating across borders, particularly where existing EPR registration and enforcement mechanisms are already in place, as is the case for packaging. Yet, both the EU Parliament and the Council initially proved reluctant to support the Commission’s approach.  

The realisation. It took the PPWR’s entry into application, on 12 August this year, for the practical implications of the AR requirement to come into sharper focus, also spurred by testimonies from businesses across Europe highlighting the disproportionate impact of the requirement on small and medium enterprises as well as private sellers. 

As of yet, the Environment Committee, which is leading on the file in the EU Parliament, has backed a time-limited suspension of the requirement, applicable to EU-based micro and small enterprises. On the other side of the Berlaymont, the Irish Presidency is still working to secure an agreement among EU countries. 

The continued uncertainty. Time will tell whether the EU Parliament and Member States will live up to their commitments to the Single Market, most recently reaffirmed through the ‘One Europe, One Market’ Roadmap. Meanwhile, EUROPEN continues to call for the suspension of the AR requirement for packaging, for all businesses established in the Union, in line with the EU Commission’s proposal.  

If the EU is serious about delivering the Single Market, this is its chance to prove it. 

WHAT DID YOU MISS?    

  • December 2025: publication of the EU Commission’s proposal for an Environment Omnibus VIII. 
  • March 2026: the EU Parliament’s IMCO Committee decided not to adopt an opinion on the file. 
  • October 2026: the EU Parliament’s ENVI Committee adopts its position in support of a time-limited suspension, application to EU-based micro and small businesses. 

WHAT'S NEXT?   

  • October 2026: ENVI Council’s discussion on PPWR and the proportionate extended producer responsibility framework for small producers and the internal market. 
  • October 2026: EU Parliament’s plenary votes on the ENVI report.