On 10 December 2025, the European Commission (EC) published its Environmental Omnibus package. The package aims to enhance the competitiveness of the EU economy by reducing regulatory complexity and unnecessary administrative burden across EU environmental and circular economy legislation, including in the area of extended producer responsibility (EPR).

Several of the legislative proposals are of particular relevance to packaging and packaging-related compliance obligations. 

First of all, the proposal for a Regulation 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 (COM/2025/982 final) [1] would suspend the obligation for producers to appoint an authorised representative (AR) for EPR purposes under the Packaging and Packaging Waste Regulation (PPWR). Specifically, Article 2 of the proposal would suspend the application of Article 45(3) PPWR until 1 January 2035.

Article 45(3) PPWR requires producers to appoint, by written mandate, an authorised representative in each Member State where packaging or packaged products are made available for the first time, other than the Member State in which the producer is established. It also allows Member States to impose AR requirements on producers established in third countries. The proposed suspension would apply irrespective of the fact that certain PPWR obligations are not yet fully applicable. If adopted, this measure would significantly reduce compliance burdens for producers placing packaging or packaged products on multiple EU markets, including companies established in a single EU Member State but selling cross-border. 

In parallel, the Commission has proposed a Directive (COM(2025) 983) [2] suspending, until 1 January 2035, the authorised representative requirement under Article 8(7) of the Single-Use Plastics Directive (Directive (EU) 2019/904). This proposal also extends to similar authorised representative obligations under other waste legislation, including waste electrical and electronic equipment (WEEE).

A third proposal that could impact food-contact materials relates to the reduction of administrative burdens. Among other things, it would repeal the database for information on Substances of Concern (SCIP) since its functions are to be replaced by digital tools such as the One Substance One Assessment package and the Digital Product Passport.

Under the ordinary legislative procedure (OLP), these proposals are now submitted to the European Parliament and Council of the EU for negotiation and adoption.

[1] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025PC0982&qid=1765985452410

[2] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025PC0983&qid=1765985588015