Marius Cristian Brînzea · Managing Partner
8 October 20263 min read
In the "Environmental Omnibus" package of December 2025, the Commission proposed (COM(2025) 982) suspending, until 1 January 2035, the obligation of producers established in the EU to appoint an authorised representative for EPR when they sell packaging or batteries in a Member State where they are not established - an obligation laid down in Art. 45 of Regulation (EU) 2025/40 (PPWR) and in Regulation (EU) 2023/1542 on batteries. A parallel proposal covers electrical equipment (WEEE) and single-use plastics. Appointing the representative would become, for these companies, an option rather than an obligation.
One essential detail: the suspension concerns ONLY producers established in the EU. For companies from outside the Union - the United Kingdom, Switzerland, Turkey or any other - selling packaged products in Romania without a local establishment, the authorised representative remains mandatory, both before and after the reform.
The European Parliament's ENVI Committee did not accept a general suspension. In the report voted on 5 October, the relief applies only to EU micro and small enterprises (fewer than 50 employees and at most €10 million turnover), is strictly temporary and will be tied to the future Circular Economy Act. Next come the plenary vote, scheduled for 19 October, then negotiations with the Council, which adopted its position in August. The practical conclusion: medium-sized and large EU companies have a real chance of keeping the obligation even after the reform.
If you sell packaged products from Romania to consumers in other EU Member States (online or at a distance), the obligation to have an authorised representative in each state of destination remains in force. Do not terminate existing contracts on the strength of news about the suspension: until the act is adopted and published, the absence of a representative can block your sales and expose you to sanctions in that state. If you are a foreign company placing packaging on the Romanian market, the obligations under Law no. 249/2015 and the declarations to the Environmental Fund continue to be fulfilled through the authorised representative - nothing is suspended here for now.
Circulad'OR provides the authorised representative service for packaging in Romania: we take over reporting to the PRO and the declarations to the Environmental Fund for companies without a local establishment, based on the quantities sent monthly. And through Yvora, the packaging data required by PPWR sits in one place, ready to report. If you sell cross-border - in either direction - and are not sure where you need an authorised representative, write to us at office@circulador.ro.
The first conversation is free: you find out what applies to you, by when, and who does it - you, us, or the application.