Joint reaction to the Environmental Omnibus: call to maintain Authorised Representatives’ obligation for EPR

The European Commission has proposed an “Environmental Omnibus” package to simplify and reduce administrative burdens in environmental legislation. However, one proposal has raised significant concerns. RREUSE, along with various European industry and civil society organisations, has issued a joint statement warning against suspending the requirement for companies to appoint an Authorised Representative for Extended Producer Responsibility (EPR).

Companies placing products on the EU market are responsible for managing the resulting waste under the Extended Producer Responsibility (EPR) scheme. For non-EU-based companies, an Authorised Representative must be appointed to handle these responsibilities locally, including registration, reporting, and financial contributions.

Suspending the requirement to appoint an Authorised Representative would hinder enforcement and make it harder to ensure all producers, especially those outside the EU, meet their EPR obligations. This proposed change could enable some producers to avoid responsibility, resulting in unfair competition for compliant companies. It would also weaken a core aspect of environmental responsibility in the EU and endanger the financing available for waste management activities, ultimately threatening progress toward the EU’s circular economy goals.

To address these concerns, we urge the co-legislators to maintain the requirement to appoint an Authorised Representative and to prioritise stronger enforcement of existing rules. A robust legal framework grounded in consistent and harmonised enforcement would ensure a level playing field and deliver on its intended objectives.

Lastly, we call for any changes to the rules for Authorised Representatives to be comprehensively addressed in the future Circular Economy Act, together with the broader EPR functioning.