On December 10, 2025, the EU Commission presented a further package of measures (known as the environmental omnibus) to simplify some environmental regulations.
The focus is on extended producer responsibility (EPR). With the aim of ensuring a sustainable circular economy, this principle transfers the economic responsibility for the end-of-life phase of a product to the manufacturer of the product. The EPR always refers to the respective Member State in which a product is placed on the market, as it is assumed that the product will also be disposed of there and the disposal structure in the individual Member States vary greatly. The EPR covers products that require special regulation due to harmful ingredients or other environmentally hazardous properties, e.g. batteries, electrical appliances, packaging, single-use plastics, textiles (from 2028).
This obligation for a manufacturer to have an authorized representative for the EPR in each Member State in which it places its products on the market is seen as a major obstacle to the internal market and is to be adapted by the omnibus draft.
The draft provides for the obligation to appoint an authorized representative to be suspended for manufacturers based in a (different) Member State until January 1, 2035.
For manufacturers based in a third country (outside the EU), the Member States can choose between two alternatives: Either the designation of an authorized representative can (continue to) be required or traceability and enforcement in relation to manufacturers established in third countries must be ensured by alternative means.
Do you have questions about this omnibus procedure? We are at your disposal for further assistance. Simply send us an email with your question or use our contact form.
You can read more on this topic here → EU: Initiative to reduce administrative burdens in environmental law
For more basic knowledge on both environmental regulations and other material compliance topics, visit our Material & Environmental Compliance Officer "MECO" course in accordance with ISO/IEC 17024 (only in German).
Author's note
This article has been machine translated into English.
TERMS AND ABBREVIATIONS
An omnibus procedure is when several individual issues are bundled into a single procedure.
