Letter

Joint call to urgently launch and conclude trilogue negotiations on the authorised representative requirement

29/10/2026

European businesses, in particular SMEs, have been deeply impacted by the implementation of the Packaging and Packaging Waste Regulation (PPWR). The provisions of the PPWR, notably the requirement for businesses to appoint authorised representatives in all EU countries where they sell goods, place a disproportionate burden on smaller businesses. As a consequence, numerous companies have already decided to stop selling across borders.

As representatives of the European business community, we urge the European Parliament and the Council to launch trilogue negotiations as soon as possible on the Environmental Omnibus proposal to suspend the authorised representative requirement for extended producer responsibility. Negotiations must be concluded before the end of November. This would be a first step towards providing relief for micro and small businesses ahead of the festive season.

Further action will be needed to make the PPWR workable for businesses. The upcoming Circular Economy Act offers a timely opportunity that must be seized to deliver broader simplification, particularly for SMEs.

Joint call to urgently launch and conclude trilogue negotiations on the authorised representative requirement