Environmental Omnibus suspends cross-border authorised representative requirements under PPWR while Commission commits to guidance on PFAS testing, labelling and reuse targets.
Producers selling packaged products across EU borders will no longer need to appoint an authorised representative in each member state for extended producer responsibility purposes.
The European Commission's Environmental Omnibus package, adopted this week (10 Dec), suspends the requirement that was set under the Packaging and Packaging Waste Regulation (Regulation EU 2025/40). The EC recognises that cross-border EPR compliance is one of the most frequently reported barriers for companies operating across the single market.
The Commission says these changes are "a stepping stone to more profound simplification", with the forthcoming Circular Economy Act in Q3 next year expected to introduce a digital one-stop-shop for EPR information, registration and reporting across member states.
Commenting on the measures, Carlos De Souza, International Services Manager at compliance scheme Ecosurety, said they would ease compliance while maintaining environmental standards: "The focus now shifts towards member states turning these reforms into practical, workable solutions," he said. "Clear guidance and continued industry collaboration will be essential to ensure these reforms achieve their full potential."
Guidance on PFAS, labelling and reuse targets
The omnibus package also commits the Commission to prioritising secondary legislation and guidance to support PPWR implementation. An EC notice and frequently asked questions will address PFAS testing requirements, application dates, labelling specifications and reuse targets – questions that have dominated industry discussions since the regs came into force in February.
A draft delegated act will exempt pallet wrappings and straps from the 100 per cent reuse targets. The Commission has indicated it will consider similar flexibilities for other packaging formats where hygiene or food safety requirements make reuse targets impractical.
The Commission says harmonised labelling rules will take account of existing systems and the particular requirements of products such as medicines, where patient safety is a concern. A newly established expert group for packaging will help develop simplified reporting requirements.
Scope limited to targeted amendments
The Communication COM(2025) 980 states that for the PPWR, the omnibus "only introduces limited and targeted amendments and a targeted suspension of certain EPR provisions", with further modifications to the underlying legislation "explicitly outside the scope of this proposal".
Zero Waste Europe network has expressed concern about broader simplification measures in the package. "Europe aspires to lead the world in circularity, yet the European Commission seems to be opening doors to weaken key files that form the backbone of the European circular economy," says Aline Maigret, Head of Policy at Zero Waste Europe.
The PPWR entered into force on 11 February 2025, with general application beginning after 18 months (next August). Implementation of the regulation's harmonised waste sorting labels is proceeding separately, with the Joint Research Centre continuing stakeholder consultations ahead of the August 2026 deadline for finalised implementing acts.
Beyond PPWR, the Environmental Omnibus proposes repealing the SCIP database tracking articles containing substances of very high concern, with the Commission stating the database "has not been effective in informing recyclers about the presence of hazardous substances" and that EU chemicals legislation and digital product passports will fulfil its intended role. The full omnibus package is estimated to reduce administrative burdens by approximately €1 billion annually.
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How will the government and DMOs address the challenges of including glass in DRS while ensuring a level playing field across the UK?
There's no easy solution to include glass in the DRS while maintaining a level playing field. Potential approaches include a phased introduction of glass, potentially with higher deposits to reflect its logistical challenges. The government and DMOs could incentivise innovation in glass packaging design and subsidise dedicated return points for glass-handling. Exemptions for smaller businesses unable to handle glass might also be necessary. Any successful solution will likely blend several approaches. It must address the differing priorities of devolved administrations, balance environmental benefits with logistical and cost implications, and be supported by robust consumer education campaigns emphasizing the importance of glass recycling.