Next month, the European Parliament is expected to vote on the ordinary legislative procedure 2025/0395. This procedure is part of Omnibus VIII on environmental legislation and addresses the possible suspension of the application of extended producer responsibility (EPR) rules for batteries and waste batteries as well as packaging and packaging waste. The Commission aims at alleviating administrative burden and costs from the producers of packaging and batteries, especially SMEs.
Possible suspension of EAR for EPR until 2035
The proposed amendment foresees the suspension of the application of the provisions in Regulation (EU) 2023/1542 (battery) and Regulation 2025/40 (packaging) that mandate the appointment of an authorised representative for EPR for producers established in the Union. In this way, packaging and battery producers in the Union will be able to choose whether they appoint an authorised representative for EPR when making available products on the market of another Member State where they are not established. Specifically, the proposal aims to suspend this obligation until 1 January 2035.
What comes next: Parliament to vote in October
The expected next steps in the legislative procedure are:
- Parliament’s responsible committee (ENVI) votes on the amendments (currently awaited)
- Parliament first-reading vote in plenary on 19 October 2026.
- Adoption of the Council’s position and continuation of the ordinary legislative procedure, if necessary.
What is the extended producer responsibility?
The extended producer responsibility (EPR) is a policy scheme which addresses the producer’s responsibility of a product thought its entire lifecycle. In particular, ERP schemes tackle a product’s environmental footprint and implement strategies to minimise waste and promote recycling. Currently, producers have to appoint an authorised representative for extended producer responsibility in each Member State in which they sell packaging or batteries. The authorised representative for EPR is different from the authorised representative. Specifically, the authorised representative fulfills the tasks related to communication with the authorities and regulatory guidance, whereas the authorised representative for EPR is Member State specific and its obligations are related to collection, treatment, and recycling of their products at the end of their lifecycle.
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References:
European Parliament (2026). 2025/0395 (COD). Suspending the application of the rules on extended producer responsibility for batteries and waste batteries and packaging and packaging waste (Omnibus VIII on environmental legislation). Retrieved on 21/09/2026.
European Parliament (2026). Proposal for a Regulation of the European Parliament and of the Council 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. Retrieved on 21/09/2026.
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