9. Podium Event on 9.9.2026 in Hamburg at the Mövenpick Hotel

Increasing compliance requirements in times of protectionism and stagnant growth. Will this turn out well for European SMEs?

In our panel discussion, we will connect the topics of Extended Producer Responsibility and Product Responsibility with the current political and economic situation and examine the challenges for companies from different perspectives. Free of charge for VERE members!

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Update on the authorised representative

The debate surrounding the reform of Extended Producer Responsibility (EPR) under the EU Environment Omnibus Package continues, with significant differences emerging between the European Commission, the Council and the European Parliament. While the Member States have largely rejected the Commission's original proposal, positions within Parliament remain divided, ranging from targeted exemptions for small businesses to the complete removal of the proposed EPR provisions. The coming months will be decisive in determining the future direction of the initiative.

According to information obtained by VERE from sources close to the discussions, the European institutions are currently engaged in intensive negotiations on the future framework for Extended Producer Responsibility, particularly regarding the appointment of authorised representatives for producers operating across borders. Within the Council of the European Union, a broad consensus has emerged against the European Commission's original proposal on the Environment Omnibus Package. This position follows the non-paper previously issued by several Member States and was reaffirmed at the end of April. As a result, the Commission's proposal, in its current form, is receiving little support among national governments.

Diverging positions within the European Parliament

The debate within the European Parliament presents a more nuanced picture. The lead rapporteur, Ingeborg ter Laak, has proposed limiting any exemption from the authorised representative requirements to micro-enterprises and small enterprises operating across borders. The proposal recognises that smaller businesses often face greater administrative and financial challenges in complying with the existing obligations. Under the proposal, however, any exemption would be temporary and remain in place only until a broader review of the EPR framework is completed as part of the forthcoming Circular Economy Act (CEA). For producers established outside the European Union, the current authorised representative requirements would continue to apply without change. A different position has been taken by the rapporteur of the Committee on the Internal Market and Consumer Protection (IMCO). In her draft opinion, Klára Dostálová calls for the entire EPR section of the proposal to be rejected, reflecting a considerably more critical approach than that taken elsewhere in Parliament.

What comes next?

The legislative process is expected to continue over the coming months. The report is scheduled for discussion in the European Parliament's Committee on the Environment, Climate and Food Safety (ENVI) in June, followed by further committee deliberations in October. A plenary vote is currently expected to take place in November. This timetable is broadly aligned with the wider Environment Omnibus Package, although it could still change if the European Commission presents additional proposals on the harmonisation of Extended Producer Responsibility as part of the forthcoming Circular Economy Act.

VERE e.V. remains in close contact with the relevant stakeholders and will continue to keep its members informed of further developments via the “VERE Insider”.

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Christoph Brellinger
Contact

Christoph Brellinger
Executive secretary

info@vereev.de

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