On 5 October 2026, the European Parliament will hold its first reading on a proposal to temporarily suspend the obligation to appoint an authorised representative. The European Commission’s initiative from December 2025 aims to reduce bureaucracy and strengthen the competitiveness of European companies. The sectors affected are WEEE/electrical equipment, batteries, packaging and single-use plastics. The debate focuses on the role of the authorised representative as the central point of contact for authorities in EU member states.
However, VERE strongly warns against abolishing this role, as the association’s experience shows that the authorised representative is not a bureaucratic burden, but rather the prerequisite for fair competition, compliance with national regulations, and effective enforcement. Without authorised representatives, there is a risk of a significant increase in free-riders from third countries, inefficient market surveillance and distortions of competition in favour of unregistered suppliers. While the Commission hopes to achieve cost savings and reduce the burden on small businesses, VERE argues that abolishing the requirement to appoint an authorised representative would not actually reduce bureaucracy but merely shift it onto producers. As a result, they would have to contend with potentially higher costs and legal uncertainties. Furthermore, the authorised representative stabilises the internal market and, through their position, helps to ensure that, amongst other things, environmental targets, recycling rates and product compliance requirements within the circular economy are consistently met.
According to the EU Committee on the Environment, Climate and Food Safety (ENVI), a suspension of the requirement to appoint an authorised representative should initially apply only to certain microenterprises and small businesses based in the EU to effectively alleviate their burden. This provision is intended to be temporary until the planned Circular Economy Act comes into force. For non-EU companies, however, the obligation will remain in place.
VERE e.V. is closely monitoring the proceedings and has published a detailed statement on the authorised representative requirement, setting out all the arguments in detail. Read the full article “Suspension with side effects – No fair competition without authorised representatives”. VERE keeps its members up to date on all further developments and decisions regarding the authorised representative requirement and EU enforcement via “VERE Insider”.
Not a VERE member yet? Become a VERE member today!
