If you sell packaged goods straight to consumers in an EU country where your company is not established, you have to appoint an authorized representative for EPR in that country. That duty is live now, and it applies whether you are based inside the EU or outside it (Art. 45(3)). A lot of people are waiting it out because Brussels proposed to switch it off. Do not.
What actually happened. The Commission proposal that would suspend the duty for EU-established producers until January 1, 2035 is COM(2025) 982, procedure 2025/0395(COD), and it covers the Batteries Regulation and the PPWR together. Two things have happened to it. The Council dropped the extended-producer-responsibility proposals from its negotiating mandate on June 24, 2026, so that track stopped. And in Parliament, where the file sits in the environment committee and is still recorded as awaiting a committee decision, the rapporteur has tabled a draft report that would cut the relief back sharply: available only to micro and small enterprises trading cross-border inside the EU, strictly temporary pending the Circular Economy Act review, and with producers established outside the EU left exactly where they are today. The indicative first-reading plenary date is October 5, 2026.
What this means for you. Nothing has been adopted, and the version now on the table in Parliament is much smaller than the one proposed. If you are a large or mid-sized business, appoint representatives country by country and treat any future relief as a bonus rather than a plan. If you are a micro or small business selling cross-border inside the EU, you are the group the draft report would actually help, so the file is worth watching, but you owe the duty today all the same. Track it on the European Parliament register:
procedure file 2025/0395(COD).
[SIGNALED]: a rapporteur draft report is one member's proposal, not Parliament's position, and the committee has not voted.