EU Suspends Authorized Representative Requirement

On December 10, 2025, the European Commission announced a temporary suspension of the requirement for packaging producers to appoint an authorized representative in each Member State to comply with Extended Producer Responsibility (EPR) obligations. This measure, introduced as part of the Commission’s environmental "omnibus" simplification package, will apply until January 1, 2035. The suspension is designed to alleviate administrative costs for businesses, particularly small and medium-sized enterprises (SMEs), without altering the core objectives of the Packaging and Packaging Waste Regulation.

During this suspension period, producers are no longer mandated to maintain a local representative in every jurisdiction where they operate. Instead, they are granted the flexibility to either continue appointing an authorized representative or to fulfill their registration, reporting, and fee-payment obligations directly. The Commission estimates that this simplification could generate annual cost savings of approximately €300 million for the industry. This interim step serves as a precursor to a comprehensive reform of EU EPR rules, with a broader legislative proposal expected in 2026. 

Further details on the simplification package and its impact on EPR compliance are available in the Commission’s official press Q&A.