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Joint reaction to the Environmental Omnibus: call to maintain Authorised Representatives’ obligation for EPR

EucoLight - Publications
9 April 2026

Following the European Commission’s proposal for an Omnibus package targeting the
simplification of administrative burdens in environmental legislation (Environmental
Omnibus), a particular point has raised worries across European industry and civil society.
The signatories of this joint statement hereby express their collective concerns about the
proposed suspension of the mandatory appointment of an Authorised Representative for
Extended Producer Responsibility (EPR) in the Environmental Omnibus.
We unite our voices to ask EU co-legislators to remove the suspension, until 2035, of
the Authorised Representative obligations from the Environmental Omnibus
(Regulations 2025/0396 and 2025/0395) and call on the European Commission to address
the EPR scheme’s refinement, including the Authorised Representatives, within the
upcoming Circular Economy Act.


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