First, the absence of a thorough impact assessment is worrying. Revising core environmental legislation without robust evidence risks undermining long-standing environmental protections and
creating economic uncertainty for stakeholders.
RREUSE also stresses the importance of ensuring coherence across EU legislative processes. Several of the legal acts targeted by the proposed Omnibus are already scheduled for review through other ongoing or forthcoming initiatives. Addressing these issues through parallel or overlapping processes risks creating fragmentation, duplication, and confusion for stakeholders.
The proposal to suspend the obligation to appoint an authorised representative (AR) under EPR schemes is another concerning element. Because the AR plays a key role in ensuring compliance with EPR requirements, including EPR fee payment, this proposal would automatically increase free riding and, therefore, decrease the EPR fees available. Furthermore, eliminating the AR would severely impact product traceability and complicate enforcement of upcoming legislation, such as the new EPR requirements expected under the CEA.
Lastly, robust reporting requirements are essential governance tools. Cutting these reporting obligations under EPR schemes would undermine evidence-based decision-making and prevent the effectiveness of environmental policy instruments.
