Joint Statement: Safeguarding the Role of Authorised Representatives in EPR

APPLiA, together with a coalition of industry associations, has issued a joint statement highlighting the essential role of Authorised Representatives within the Extended Producer Responsibility (EPR) framework.

Extended Producer Responsibility (EPR) remains a cornerstone of the EU’s circular economy policy. Its effectiveness, however, depends on consistent and enforceable implementation across all actors operating in the Single Market, including those established outside the EU.

The proposal put forward in the European Commission’s Environmental Omnibus to suspend the mandatory appointment of Authorised Representatives for non-local producers raises significant concerns. Removing this requirement risks weakening enforcement, increasing free-riding, and undermining the overall functioning of EPR systems.

In this context, the co-signatories call for maintaining the obligation for Authorised Representatives and for strengthening the EPR framework in the context of the upcoming Circular Economy Act (CEA).

In particular, Authorised Representatives play a key role in:

• Ensuring effective enforcement of registration, reporting, and financial obligations
• Supporting Producer Responsibility Organisations (PROs) in the financing of waste management and recycling activities
• Improving traceability of products and materials across the value chain
• Safeguarding fair competition within the Single Market

If not properly addressed, the proposed changes risk weakening the integrity and effectiveness of EPR systems across Europe.

The signatories remain available to provide further technical input and to support ongoing discussions towards a robust and enforceable EPR framework.