Industry Coalition Supports Temporary Suspension of National Authorised Representative Requirement Under EPR

A coalition of European trade associations from across sectors is supporting the European Commission’s proposal to temporarily suspend, within the Union, the mandatory appointment of an Authorised Representative (AR) for certain Extended Producer Responsibility (EPR) waste streams, as part of the Environmental Omnibus package.

The proposal comes as EU policymakers place increasing emphasis on regulatory simplification and strengthening the Single Market to improve Europe’s global competitiveness. The temporary suspension of this requirement in the EU would represent a constructive step toward a more workable and harmonised compliance framework for companies operating across the European Union.

Under current rules, companies selling products across borders may be required to appoint separate authorised representatives in each Member State where they place products on the market. This requirement creates significant administrative complexity and burden, particularly for small and medium-sized enterprises (SMEs).

“The EU’s global competitiveness hinges on a Single Market that works for all businesses—yet divergent national rules continue to fragment the market and stifle growth. The temporary suspension of Authorised Representative requirements under the Environmental Omnibus is a pragmatic step toward regulatory simplification and a stronger Single Market. This move not only boosts Europe’s competitiveness but also sets the stage for a unified, future-proof EPR framework—critical as the EU prepares to advance its Circular Economy Act,” says Francesca Stevens, Secretary General of EUROPEN. 

While we fully support efforts to combat free-riding and ensure effective enforcement of EPR obligations, the undersigned associations express concern over opposition to the proposed suspension voiced by several Member States. Maintaining divergent national requirements risks further fragmenting the EU Single Market and undermining efforts to simplify regulatory compliance.

The coalition is therefore calling on the European Parliament and the Council of the European Union to maintain the proposed temporary suspension until 1 January 2035. In the longer term, they advocate the development of a more harmonised EU-wide approach to EPR compliance. Such a framework, the coalition argues, should strengthen enforcement mechanisms while making it easier for companies, particularly SMEs, to operate across the European market.

Read the statement here.