On 10 December 2025, the European Commission published a major new Communication,
“Simplifying for Sustainable Competitiveness”, which includes a targeted package of changes to
Extended Producer Responsibility (EPR) and the Packaging and Packaging Waste Regulation (PPWR).
For businesses operating in the EU, these proposed amendments signal a significant shift in how packaging
compliance will be managed—offering both opportunities for efficiency and new challenges in reporting and
data management.
Disclaimer: The changes described in this blog are proposed amendments under the EU’s environment omnibus package and are currently subject to legislative approval. Until formally adopted, current EU EPR and PPWR rules remain in force. This blog reflects the Commission’s published proposals as of December 2025 and does not constitute legal advice.
1. The Rationale: Why Simplify EPR and PPWR?
The Commission’s overarching goal is to reduce administrative burdens for businesses while maintaining high
environmental standards. The current EPR and PPWR frameworks, while essential for driving circularity and
waste reduction, have led to significant complexity and reporting requirements for producers.
The omnibus package aims to streamline these processes, making compliance more efficient and less burdensome,
especially for SMEs.
2. Key Proposed Changes to EPR
2.1 Flexibility in Authorised Representatives
Under current EPR rules, producers selling packaging in multiple Member States must appoint one authorised
representative per country. This can create duplication and cost, particularly for companies with a
pan-European footprint.
The omnibus proposes:
- Choice of Authorised Representative: Producers selling in other Member States will be able
to decide whether to appoint an authorised representative in those countries, rather than being automatically
obliged to do so in each country. - Maintaining Current Set-Up: Companies that already have authorised representatives can keep
their current setup. - Future Harmonisation: Deeper reform, including harmonisation and digitalisation of EPR
schemes, is expected as part of the Circular Economy Act in 2026, including a digital one-stop-shop for
information, registration, and reporting.
2.2 Reduced Reporting Burden
The omnibus also proposes to reduce the extent of reporting that producers must undertake about the products
made available and data on the collection and treatment of waste linked to those products. Reporting frequency
will be limited to a maximum of once per year, and reporting will be simplified as much as possible via
implementing measures, in close collaboration with stakeholders and Member States.
3. Key Proposed Changes to PPWR
3.1 Simplified Reporting
The omnibus package includes targeted amendments to the PPWR to reduce administrative burdens. The Commission will:
- Issue a Commission Notice and FAQ: Providing guidance on the most frequently raised points in
the call for evidence and in bilateral exchanges, including testing for PFAS, application dates, labelling
requirements, and reuse targets. - Develop Implementing Measures: In 2026–2027, harmonised labelling specifications will be
developed, taking into account existing systems and special cases (e.g., medicines), and a draft Delegated Act
will exempt pallet wrappings and straps from the 100% reuse targets. The Commission will consider additional
flexibilities for other packaging formats, notably where hygiene and food safety issues prevent the achievement
of those targets. - Simplified Reporting: Reporting will be simplified as much as possible via implementing
measures, in close collaboration with stakeholders and Member States in the newly established expert group
for packaging.
3.2 Harmonised Labelling and Flexibilities
The omnibus package also proposes harmonised labelling specifications, taking into account existing systems and
special cases (e.g., medicines). The Commission will consider additional flexibilities for other packaging
formats, notably where hygiene and food safety issues prevent the achievement of reuse targets.
4. What This Means for Businesses
While the omnibus proposal still needs to pass through the EU legislative process, some clear practical trends
already emerge for businesses:
- Less Duplication, More “One-Time, One-Place” Data: Future EPR registration and reporting via
an EU-wide digital one-stop-shop. - More Flexibility in Compliance: Greater choice on using authorised representatives for EPR.
- Faster, More Predictable Reporting: Harmonised labelling specifications and simplified
reporting should, over time, shorten timelines and clarify expectations. - A Continuing Need to Stay Up-to-Date: Many elements (Circular Economy Act, PPWR implementing
acts, guidance under other laws) are still to come. The direction is towards harmonisation and digitalisation,
but details will matter for day-to-day compliance.
5. Conclusion
The “Simplifying for Sustainable Competitiveness” omnibus is a significant step towards a more efficient,
business-friendly EU packaging compliance framework. It demonstrates the Commission’s commitment to maintaining
high environmental standards while reducing unnecessary bureaucracy. For companies, this is both an opportunity
and a challenge: an opportunity to reduce compliance costs and streamline operations, and a challenge to stay ahead
of evolving regulations.
All the changes described in this blog are proposed and not yet final. Until formally adopted, current rules
remain in force.
Disclaimer: The information provided in this blog is intended for general guidance only and
should not be considered as professional, legal, or regulatory advice. Readers are encouraged to consult with
qualified experts and official sources to ensure compliance with the latest regulations and requirements.