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Updated on 8 October 2026, following the ENVI Committee vote of 5 October 2026. The committee voted to limit the suspension to micro and small EU-based companies. We will update this post again after the European Parliament plenary vote.
Since August 12, 2026, PPWR has required producers selling packaged goods into EU countries where they do not have a legal entity to appoint a local authorised representative (AR) in each of those countries. That representative registers the producer in the national producer register, handles EPR reporting, and fulfils financial obligations on their behalf in that market.
For a producer selling into five EU countries without a local office in any of them, that means five separate AR contracts, five sets of fees, and five parallel reporting obligations. Scaled to all major EU markets, the obligation can reach up to 26 national appointments. The fragmentation driving that complexity is the same problem an industry coalition recently called on the Commission to address through a digital EU-wide EPR registration and reporting platform.
In December 2025, the European Commission proposed suspending this requirement for EU-established producers until 2035. In May 2026, the Parliament member leading the review proposed narrowing it significantly. On 5 October 2026, the European Parliament’s Environment Committee (ENVI) voted to limit the suspension to micro and small companies, as she had proposed.
Where the PPWR Authorised Representative Suspension Stands Now
The proposal is moving through the ordinary legislative procedure (2025/0395(COD)). Here is the sequence so far, and what still needs to happen:
- December 2025: The Commission publishes its proposal, COM(2025) 982.
- 28 May 2026: The ENVI rapporteur publishes her draft report.
- 24 June 2026: The Council pauses work on the AR suspension, according to a European Parliament research briefing.
- 5 October 2026: The ENVI Committee votes to limit the suspension to micro and small EU-based companies.
- Next: A European Parliament plenary vote, expected in the week of 19 October 2026.
- Then: The Council agrees its position, Parliament and Council negotiate a final text, and the regulation is formally adopted and published.
Until an amending regulation is formally adopted and in force, Article 45(3) PPWR applies in full. The committee vote sets out ENVI’s position and does not change any producer’s current obligations.
The Commission’s Proposal
The Commission’s proposal COM(2025) 982, would suspend Article 45(3) of PPWR (Regulation (EU) 2025/40) until 1 January 2035. During that period, EU-established producers would not be required to appoint a national AR in markets where they are not established. They could choose to do so voluntarily, but the obligation would be lifted.
For producers established outside the EU, the original proposal gave each Member State the option to accept alternative verification methods rather than requiring a formal AR appointment.
What the European Parliament’s Lead Reviewer Has Proposed Instead
On 28 May 2026, Ingeborg Ter Laak, the European Parliament member leading the Environment Committee (ENVI) review of this proposal, published her draft report (ENVI_PR(2026)788916) with sixteen amendments. Her position reshapes the Commission’s proposal in four directions.
1. The suspension would apply to small and micro businesses only
The most significant change limits the suspension to producers that meet the EU’s definition of a microenterprise or small enterprise under Commission Recommendation 2003/361/EC:
- Microenterprises: fewer than 10 employees, annual turnover or balance sheet total not exceeding €2 million
- Small enterprises: fewer than 50 employees, annual turnover or balance sheet total not exceeding €10 million
Medium-sized businesses (up to 250 employees, up to €50 million turnover) and large companies would keep the mandatory AR requirement in full. The MEP’s reasoning is practical: larger companies already have compliance teams and legal resources. Small and micro businesses are the ones that genuinely struggle to manage multiple national appointments at once.
2. The suspension would end when the Circular Economy Act becomes law
The draft adds a sunset clause: the suspension ends on whichever date comes first, 1 January 2035 or the date the Circular Economy Act (CEA) enters into force.
The Circular Economy Act is a major piece of EU environmental legislation that the Commission is currently preparing. The MEP’s draft links the end of the AR suspension specifically to the moment the CEA is officially adopted into law, not to when its rules start applying in practice. In EU legislation, there is typically a gap of one or two years between a law being adopted and its provisions becoming operative. This means the suspension window could effectively be shorter than the 2035 backstop date implies: if the CEA becomes law in, say, 2029, the AR suspension could end at that point even if the CEA’s substantive rules do not apply until 2031.
The Commission has indicated it plans to present the CEA proposal in Q3 2026, with full adoption unlikely before 2028-2029 at the earliest. Producers designing their 2028 compliance architecture around the suspension being in place should factor in this uncertainty.
3. Non-EU producers: no change
The MEP’s draft deletes the provision that would have allowed Member States to accept alternative verification methods for producers established outside the EU. For any producer based outside the EU that sells packaged goods on the EU Single Market, the mandatory AR requirement under PPWR stays exactly as it is.
Company size makes no difference here. The MEP’s reasoning: producers based outside the EU are beyond the reach of EU enforcement mechanisms, and a named, locally accountable representative is the only practical way to hold them to their obligations.
4. The suspension covers only the AR appointment, not the underlying EPR obligations
A further amendment makes clear that lifting the AR obligation does not lift any of the other producer obligations. A micro-enterprise that does not appoint a national AR cannot use that as grounds to skip registering with a Producer Responsibility Organisation (PRO), the collective scheme that manages packaging waste collection and recycling in each country, or to avoid contributing to EPR fees. Every PPWR producer obligation remains in place. Only the requirement to appoint a representative is suspended.
What the ENVI Committee Voted For
On 5 October 2026, the ENVI Committee voted to suspend the PPWR authorised representative requirement until 1 January 2035 for micro and small EU-based companies only, in line with the first change proposed in the draft report. Medium-sized and large EU-established producers would keep the mandatory AR requirement in full.
The committee’s position now goes to the European Parliament plenary, with a vote expected in the week of 19 October 2026. The plenary vote sets Parliament’s position for negotiations with the Council. It does not make the suspension law.
Where the Council Stands
The Council has not yet agreed a position on the AR suspension. On 24 June 2026, it agreed its positions on three other files in the Environmental Omnibus package, but paused work on the two texts addressing authorised representative requirements, citing reservations among a majority of national delegations and the forthcoming Circular Economy Act review, according to a European Parliament research briefing.
Discussions in the Council are expected to resume. Until the Council agrees its negotiating mandate, negotiations with Parliament cannot begin, and the final scope of any suspension remains open.
What This Means for You
If you are a small or micro EU-established producer: You are the intended beneficiary of the suspension. If the regulation is adopted as the ENVI Committee voted , you would not be required to appoint national ARs in countries where you sell but are not established. You could still do so voluntarily. The relief would last until 1 January 2035 at the latest, or until the Circular Economy Act becomes law if the sunset clause in the draft report is retained. Until then, Article 45(3) applies to you in full.
If you are a medium or large EU-established producer: The suspension as voted by the ENVI Committee does not apply to you. Your AR obligations under PPWR have applied since August 12, 2026 and remain mandatory. Nothing in the committee vote changes your current obligations.
If you are a non-EU producer: The mandatory AR requirement applies in full in every Member State where you make packaging or packaged products available. Act on the basis of current law.
What to Do Now
The ENVI vote sets out the committee’s position, not the final law. The text still needs a plenary vote, a Council position, and negotiations between Parliament and Council before anything is final. As the suspension was not adopted before PPWR became applicable on August 12, 2026, the AR obligation has applied in full since that date and continues to apply until an amending regulation is in force.
If you are a micro or small EU-established producer: Do not dismantle existing AR arrangements yet. Follow the plenary vote and the Council discussions, and only end AR mandates once the suspension is formally adopted and in force.
If you are a medium or large EU-established producer: Make sure your AR contracts are signed, your mandates are in place, and your registration with each relevant national producer register is complete. The committee vote does not change your position.
If you are a non-EU producer: Treat the current law as applying in full. Appoint ARs in every market where you sell packaged goods.
For everyone: the Circular Economy Act is now the file most likely to determine the long-term future of the AR requirement. Following its progress is the most effective way to plan ahead.
How PAQR can help
Regardless of how the authorised representative question is resolved, producers still need to know exactly what packaging they have placed on the market, in which quantities and formats, in each country. That data is what feeds your annual EPR reporting, and it is your responsibility to have it structured and accurate.
PAQR gives you a central workspace to organise your packaging data by format and market, so that when annual EPR reporting requires accurate quantities and categories, the information is ready. Learn more at paqr.com/ppwr-solution/.
Click “Try now for free” on paqr.com to start a free trial: