Suspension of the EPR Authorised Representative Rules for Batteries and Packaging (Proposal)

Proposed by the Commission on 10 December 2025 (procedure 2025/0395(COD)) as part of the environmental simplification package. Article 56(3) of the Batteries Regulation and Article 45(3) of the PPWR require producers supplying products in another Member State to appoint an EPR authorised representative there. The proposal would temporarily release producers established in the EU from this obligation (appointment becomes optional) until 1 January 2035; producers established outside the EU must still appoint one. Parliament's position of 20 October 2026 limits the suspension to EU-established small and micro enterprises, until the Circular Economy Act enters into force or 1 January 2035, whichever comes first. The Council adopted its negotiating mandate on the packaging part on 21 October 2026, using a threshold of less than 1 tonne of packaging per Member State per year. Trilogues are pending; until adoption, the current authorised representative obligations continue to apply (PPWR Article 45(3) has applied since 12 August 2026).