SMEs Call on EU to Suspend PPWR Authorized Representative Requirement

SMEunited, the European association representing craft and small and medium-sized enterprises, has called on EU policymakers to suspend the PPWR’s requirement for SMEs to appoint authorized representatives in every Member State where they place packaging on the market. According to Packaging Europe, the organization presented its case at a European Parliament hearing on 25 September 2026, six weeks after the PPWR became applicable.

The requirement, which took effect on 12 August 2026, means that a producer placing packaging on the market in a Member State where it is not established must appoint an authorized representative in that country. For an SME selling into multiple EU markets, this can mean multiple appointments, each carrying registration costs of over €500 per country plus €200 to €800 for representation services.

 

What SMEunited is Αsking For

SMEunited’s position has three elements:

First, a temporary suspension of the authorized representative requirement for EU-based SMEs. The organization argues that the requirement creates a disproportionate administrative and financial burden on smaller companies, particularly those selling online across borders.

Second, short-term practical assistance for SMEs navigating the PPWR. The organization has highlighted that many smaller businesses lack the internal capacity to interpret and implement the regulation’s requirements, particularly around the Declaration of Conformity, technical documentation and EPR registration in multiple Member States.

Third, longer-term simplification of the cross-border compliance framework, including a digital one-stop shop for EPR registration, a proposal that has been supported by several industry coalitions and MEPs, as we wrote in a previous article.

 

The Political Response

The European Parliament hearing on 25 September brought together MEPs from across the political spectrum. According to Packaging Europe’s article, opinions differed.

Jessika Roswall acknowledged that the flexibilities written into the PPWR, such as allowing SMEs to source documentation from packaging suppliers and the temporary exemption from non-compliance fines, may not be sufficient in practice. Others argued that Parliament should address the issue in a targeted way rather than seeking to dismantle the Regulation, which would merely postpone the problem.

The European Commission had previously proposed, in late 2025, suspending the authorized representative requirement for EU-based companies until 2035 as part of a broader simplification package. However, this proposal was not adopted. The Council discontinued negotiations in June 2026 after a large majority of Member States raised strong reservations. The existing obligations remain in place.

 

 

Why This Matters

The authorized representative debate touches on one of the fundamental tensions in the PPWR: the regulation aims to create a single market for packaging by harmonizing rules across 27 Member States, but the practical implementation still runs through 27 separate national EPR systems, each with its own registration process, reporting format and fee structure.

For SMEs, this means that selling packaging into five Member States can require five separate registrations, five authorized representative appointments and five different sets of reporting obligations, even though the underlying PPWR requirements are identical.

For larger businesses, the administrative cost is manageable. For a small producer or an e-commerce business selling low-value products across multiple markets, the per-country compliance cost can be disproportionate to the revenue generated in each market.

The outcome of this debate will also affect non-EU businesses exporting to the EU. The PPWR requires non-EU producers to appoint authorized representatives in each Member State where they place packaging, a requirement that applies regardless of company size and that creates similar cost and complexity challenges for exporters.

 

Conclusion

The authorized representative requirement is in force and has not been suspended. SMEs and other producers must comply with the existing rules. However, the political pressure for simplification is building and the Commission has signaled that it recognizes the problem. Whether this results in legislative change, a digital one-stop shop, or targeted exemptions for smaller businesses remains to be seen. For now, businesses placing packaging on the EU market should ensure they have the necessary authorized representative arrangements in place while monitoring developments closely.