The European Parliament’s ENVI Rapporteur, Ingeborg ter Laak (EPP, the Netherlands), has published draft reports on the Commission’s proposal — part of the Environmental Omnibus — to suspend certain authorised-representative requirements under EU Extended Producer Responsibility legislation. The proposal spans four waste streams: Waste Electrical and Electronic Equipment, Single-Use Plastic products, Batteries and waste batteries, and Packaging and packaging waste. As originally tabled, the Commission would suspend, until 1 January 2035, the mandatory appointment of an authorised representative for EPR for producers established in the EU.
The draft reports propose a more targeted approach. They would limit the suspension to micro and small enterprises (companies with up to 49 employees and up to EUR 10 million in annual turnover), clarify that the measures should remain strictly temporary, and link their application to the forthcoming Circular Economy Act. Importantly, the reports maintain the current framework for producers established in third countries: Member States may still mandate authorised representatives for non-EU producers to ensure traceability, enforcement and compliance with EPR obligations. A vote in committee is expected around 1 October 2026.
EXPRA has consistently supported meaningful simplification that cuts unnecessary administrative burden — clearer reporting templates and more practical procedures for smaller operators — while stressing that simplification must not become deregulation. In its response to the Environmental Omnibus consultation, EXPRA cautioned that a broad suspension of authorised-representative obligations would weaken enforcement and traceability and risk increasing free-riding, particularly by producers established outside the EU that sell directly into the Union, including through online marketplaces. Removing a legally responsible actor in the market where products are placed risks shifting costs onto compliant producers and undermining the financing of collection and recycling.
Seen in that light, the Rapporteur’s draft reports move in a constructive direction. Limiting the suspension to micro and small enterprises, keeping it temporary and — above all — maintaining authorised-representative requirements for third-country producers reflect the balance EXPRA has called for: proportionate relief for the smallest businesses without dismantling the safeguards that keep EPR systems fair and enforceable.
EXPRA also welcomes the explicit link to the Circular Economy Act, which it sees as the right framework to address authorised representatives and wider EPR reform coherently, rather than through piecemeal exemptions.
Click here to read our 11 Recommentation for the Circular Economy Act
EXPRA will continue to engage with the Parliament, the Council and stakeholders to provide concrete, evidence-based recommendations, so that the push for simplification strengthens , rather than weakens , the producer accountability and level playing field on which effective EPR depends.