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NÁVRH SPRÁVY (COM(2025)0982 – C100335/2025 – 2025/0395(COD))

O návrhu nariadenia Európskeho parlamentu a Rady, ktorým sa pozastavuje uplatňovanie pravidiel týkajúcich sa vymenovania splnomocneného zástupcu pre rozšírenú zodpovednosť výrobcu v prípade batérií a odpadových batérií, ako aj obalov a odpadu z obalov

ENVI-PR-788916

Výbor pre životné prostredie, klímu a bezpečnosť potravín · Rapporteur: Ingeborg Ter Laak

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Written by a language model from the full text only; every figure comes from the text. The paragraph links open the paragraph a statement rests on — check the text itself before relying on it.

This is the rapporteur's draft report on a Commission proposal to suspend, until 1 January 2035, the rules requiring battery and packaging producers to appoint an authorised representative for extended producer responsibility in Member States where they are not established. The draft report proposes amendments limiting the suspension to micro and small enterprises, keeping the requirement for larger firms. It also makes the suspension end earlier if the future Circular Economy Act applies, and keeps the existing rules for producers established in third countries. The amendments state the suspension covers only the administrative appointment requirement and does not affect environmental objectives.

Committee position. The rapporteur proposes to amend the Commission proposal to limit the suspension to micro and small enterprises, make it temporary pending the Circular Economy Act, and maintain the authorised representative requirement for producers established in third countries.

Key points

  1. The suspension of the authorised representative requirement should remain temporary, pending the forthcoming Circular Economy Act announced in the Commission Work Programme 2026.
  2. The administrative burden of appointing authorised representatives is disproportionately burdensome for micro and small enterprises engaging in cross-border activities within the Union.
  3. The suspension should be limited to the administrative requirement concerning the appointment of an authorised representative and should not affect environmental objectives under Union legislation.
  4. Micro and small battery producers and packaging producers may choose whether to appoint an authorised representative when making products available in another Member State where they are not established; appointment is not mandatory.
  5. Existing provisions on appointing an authorised representative for producers established in third countries should be maintained, and Member States should not be allowed to use alternative means for traceability and enforcement.
  6. The suspension of the appointment requirement for producers established in the Union selling batteries by distance contracts directly to end-users in another Member State should end on 1 January 2035 or when the Circular Economy Act applies, whichever is earlier.
  7. The suspension of the appointment requirement for producers established in the Union making packaging available for the first time in another Member State directly to end users should end on 1 January 2035 or when the Circular Economy Act applies, whichever is earlier.
  8. Suspending the requirement for micro and small battery and packaging producers serves as a preliminary measure to alleviate burdens and pave the way for a comprehensive reform of extended producer responsibility.
  9. The suspension of Article 56(3) of Regulation (EU) 2023/1542 should apply until 1 January 2035 or the application of the Circular Economy Act, whichever is earlier, and only to producers established in the Union.
  10. The regulation should apply only to producers qualifying as microenterprises or small enterprises under Commission Recommendation 2003/361/EC.
  11. The suspension of Article 45(3) of Regulation (EU) 2025/40 should apply until 1 January 2035 or the entry into force of the Circular Economy Act, whichever is earlier, and only to producers established in the Union.
  12. The regulation should cease to apply on the date the Circular Economy Act applies.

Who is affected

  • Micro and small battery producers and packaging producers: may choose not to appoint an authorised representative in Member States where they are not established.
  • Medium-sized and large producers: the authorised representative requirement is preserved.
  • Producers established in third countries: must continue to appoint an authorised representative; no alternative enforcement means for Member States.
  • Member States: cannot use alternative means to ensure traceability and enforcement for third-country producers.

Figures and deadlines

  • 1 January 2035: date until which the suspension of the authorised representative requirement applies, or the application of the Circular Economy Act, whichever is earlier.

Legal basis: Article 294(2) and Article 192(1) of the Treaty on the Functioning of the European Union.