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DRAFT OPINION (COM(2025)0982 – C100335/2025 – 2025/0395(COD))

On the proposal for a regulation of the European Parliament and of the Council on suspending the application of the rules on the appointment of an authorised representative for extended producer responsibility for batteries and waste batteries and packaging and packaging waste

IMCO-PA-788819

Committee on the Internal Market and Consumer Protection · Rapporteur: Klára Dostálová

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✦ In short · AI summary of this text, generated 25 Sept 2026

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This is a draft opinion by the Committee on the Internal Market and Consumer Protection on the Commission's proposal to suspend the obligation for non-EU producers to appoint an authorised representative for extended producer responsibility for batteries and packaging. The rapporteur says the proposal is narrow and isolated, offers no systemic solution, and is premature ahead of announced comprehensive EPR legislation in 2026. The draft opinion argues that the authorised representative is essential for enforcement, traceability and fee collection, and that suspending the requirement would create enforcement gaps. It calls on the Committee on the Environment, Climate and Food Safety to propose rejection of the Commission proposal.

Committee position. The rapporteur proposes that the committee call on the Committee on the Environment, Climate and Food Safety to propose rejection of the Commission proposal, arguing it is narrow, premature and would create enforcement gaps.

Key points

  1. The Commission proposal would suspend the obligation for non-EU producers to designate an authorised representative under the Batteries and waste batteries Regulation and the Packaging and Packaging Waste Regulation.
  2. The rapporteur considers rejection of the proposal the appropriate course of action.
  3. The rapporteur finds the single-measure approach of very limited legislative value and says it fails to deliver comprehensive reform.
  4. The rapporteur says the measure is premature because the Commission has announced comprehensive EPR legislation in 2026 as part of the Circular Economy Act.
  5. The rapporteur says any extension of the legislative process from rejection is a reasonable trade-off for a more effective and durable legal framework.
  6. The rapporteur states that knowing the identity of an authorised representative is a prerequisite for Member States' enforcement and oversight of EPR obligations.
  7. The rapporteur says the authorised representative ensures traceability, legal accountability, fee collection and compliance verification for non-EU producers.
  8. The rapporteur warns that suspending the requirement would create enforcement gaps across the single market and impair Member States' capacity to administer EPR schemes.
  9. The rapporteur raises concern about progressive fragmentation of Union legislation on extended producer responsibility and environmental regulation.
  10. The rapporteur says the proposal deepens fragmentation and calls for maximum clarity, comprehensibility and legal certainty instead.
  11. The rapporteur says rejection would signal that the legislative process should prioritise systemic, cross-cutting solutions over ad hoc interventions.
  12. The committee calls on the Committee on the Environment, Climate and Food Safety, as the committee responsible, to propose rejection of the Commission proposal.

Who is affected

  • Non-EU producers of batteries and packaging, who would no longer have to designate an authorised representative.
  • Member States and their national competent authorities, who would lose a tool for enforcement and oversight of EPR obligations.
  • Economic operators and Member States, who the rapporteur says require comprehensive reform.

Figures and deadlines

  • 2026: the year the Commission has announced it will submit comprehensive EPR legislation.