Nothing has changed yet: the suspension is a proposal under negotiation. The Commission tabled it on 10 December 2025 in its eighth (environmental) omnibus package; it would suspend until 1 January 2035 the provisions of the Batteries Regulation and the PPWR that make an EPR authorised representative mandatory for producers established in the EU selling in other member states. Sources (2)European ParliamentEuropean Parliament — Legislative train, Omnibus VIII
EUR-LexEUR-Lex — COM(2025) 982 proposal The Council set its negotiating position on 21 October 2026, to relieve small packaging producers. Council of the EUSources (5)European ParliamentEuropean Parliament — Legislative train, Omnibus VIIIEUR-LexEUR-Lex — COM(2025) 982 proposalCouncil of the EUCouncil of the EU — press release, 21 Oct 2026European CommissionEuropean Commission — PPWR SME guide
LégifranceLégifrance — article L. 541-10-9-1 of the Environmental Code (full text) European Commission
What the proposal targets
- Article 45(3) of the PPWR: a written mandate appointing an authorised representative in each member state where a producer makes packaging available for the first time, other than its own. EUR-Lex
- The matching rule in the Batteries Regulation 2023/1542. EUR-Lex
Where it stands on 6 November 2026
- 10 December 2025: Commission proposal COM(2025) 982. EUR-Lex
- 21 October 2026: Council negotiating mandate agreed by member states' ambassadors. Council of the EU
- Next: negotiations with the European Parliament (rapporteur Ingeborg ter Laak). European Parliament The Commission's own SME guide says negotiations are ongoing. European Commission
Why France is different
France's obligation does not come from the PPWR. Article L. 541-10-9-1 of the Environmental Code, created by law 2026-602, requires every producer not established in France, inside or outside the EU, to appoint a representative established in France by written mandate, for every EPR stream, since 10 July 2026. Légifrance The proposal amends EU regulations; it does not repeal French law, and it does not cover the other French streams (furniture, textiles, toys and the rest). See EU companies selling into France. Sources (2)LégifranceLégifrance — Loi n° 2026-602 du 8 juillet 2026
ADEMEADEME — the French EPR schemes
Price
Our fee. Standard is €190 a year per eligible stream, Plus is €990 a year for up to three streams in one mandate, with a median saving of €1,071 a year in eco-contributions across our published clothing, footwear, electronics and furniture examples. Setup is €0, and eco-contributions are paid at the eco-organisme's published rate with 0% markup. See pricing.
Frequently asked questions
If the suspension is adopted, can a German company drop its French representative?
Not under current French law: the French article applies on its own terms. We will update this page if France changes it.
Does the proposal affect non-EU producers?
It targets producers established in the EU. Producers outside the EU still need a representative in France under French law.
Razvan Toma is the founder of EPR France Rep, a France-established authorised representative (mandataire) for producers with no French establishment. He has worked in waste management and recycling since 2009, running waste-separation programmes inside large B2B organisations in France for clients including Chanel, Microsoft, Decathlon, Pirelli, IKEA, Vinci, Capgemini and E.Leclerc.
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