Regulatory & Policy September 1, 2026
If you sell packaged goods straight to consumers in an EU country where your company is not established, you must appoint an authorized representative for EPR there. The duty is live now, whether you are based inside or outside the EU (Art. 45(3)), and waiting for Brussels to switch it off is a mistake.
What happened. COM(2025) 982, procedure 2025/0395(COD), which covers the Batteries Regulation and the PPWR together, proposes suspending the duty for EU-established producers until January 1, 2035. The Council dropped the extended-producer-responsibility proposals from its negotiating mandate on June 24, 2026. In Parliament, where the file awaits an environment committee decision, the rapporteur's draft report would limit the relief to micro and small enterprises trading cross-border inside the EU, make it strictly temporary pending the Circular Economy Act review, and leave producers established outside the EU where they are. The indicative first-reading plenary date of October 5, 2026 has moved since; the current forecast is on the European Parliament Legislative Observatory.
What this means for you. Nothing has been adopted, and the Parliament version is much smaller than the proposal. A large or mid-sized business should appoint representatives country by country and treat any relief as a bonus. A micro or small business selling cross-border inside the EU is the group the draft would help, so the file is worth watching, but the duty is owed today. Track it at procedure file 2025/0395(COD)
Update, October 7, 2026. The Legislative Observatory now records a vote in committee on October 5, 2026, and gives October 19, 2026 as the indicative first-reading plenary date. No committee report has been published and the file still reads "Awaiting committee decision", so what the committee actually adopted cannot be read yet. Nothing about the duty has changed. [SIGNALED]: a rapporteur draft report is one member's proposal, not Parliament's position, and the committee vote has no published text behind it.
This entry is part of the PPWR Atlas update log. See the week of August 31, 2026 or the full update archive.