Can EU micro and small companies stop using their German EPR representative now?

No, not yet. The European Parliament's environment committee has backed suspending the mandatory authorised-representative requirement for EU micro and small enterprises, but this is not final law: the full Parliament and the Council of the EU still have to agree, and the Council has no position. Until a final text is adopted, published and in force, an EU micro or small company that sells packaged goods directly to German consumers must keep its German authorised representative under § 5(2) VerpackDG. If the final law removes the requirement for your company, its date of application decides when you can stop.

My company is established in France, Poland, the Netherlands, Austria or another EU country. Do I still need a German authorised representative?

Yes, today, if you sell packaged goods directly to consumers in Germany and have no German establishment. Being established in another EU country does not exempt you under current law. The 5 October 2026 committee vote proposed a future suspension for qualifying EU micro and small companies, but it is not applicable law. Keep your German representative; if final legislation later removes the requirement for your company, the relevant date is the date that legislation applies, not the date of the committee vote.

If 74 MEPs voted for the suspension, won't the Council vote the same way?

Not necessarily. The 74 votes came from members of the European Parliament, elected representatives voting largely by political group, not from member states. The Council is made up of the 27 national governments and decides by qualified majority: at least 15 member states representing at least 65% of the EU population. In June 2026 a vast majority of governments had strong reservations and discontinued negotiations, and the committee vote does not change their votes.

Is the German authorised representative obligation suspended after the 5 October vote?

No. The European Parliament's environment committee voted for a suspension limited to EU micro and small enterprises, but that is a committee position. The full Parliament must confirm it, the Council must agree a position of its own after discontinuing talks in June 2026, and the final text must be published in the Official Journal. Until then, § 5(2) VerpackDG remains in force and the PPWR's authorised-representative rules are not suspended.

Does the proposed suspension apply to companies from the UK, Switzerland, the US, China or Turkey?

Not automatically, and not in Germany. The Commission's proposal keeps the PPWR rule under which member states may require producers established outside the EU to appoint an authorised representative, or ensure enforcement by other means. Germany requires a representative in § 5(2) VerpackDG, and the Parliament committee's version keeps the requirement for producers outside the EU. A seller from the United Kingdom, Switzerland, the United States, China or Turkey that ships packaged goods to German consumers needs a German representative today.

Does the proposal abolish German packaging EPR?

No. It concerns only the appointment of an authorised representative. Registration in LUCID (§ 6 VerpackDG), participation in a dual system (§ 7), the volume reports (§ 9) and the licence fees stay in place for every producer, whether or not a representative is required.

When could the suspension take effect?

Not before the Council agrees a position, which it has not done. If the Council reopens the file, 2027 is plausible for EU micro and small companies. If the question moves into the Circular Economy Act, as the Council signalled in June 2026, it is a matter of years.

Does the EU suspension affect the French authorised representative?

No. France's obligation comes from its own law, article L. 541-10-9-1 of the Environmental Code, in force since 10 July 2026. It covers all EPR streams, has no minimum volume, and applies to EU and non-EU sellers alike.

PPWR: do EU micro and small companies still need a German authorised representative after the 5 October 2026 vote?

Q: Can I cancel my German EPR representative because the PPWR authorised-representative requirement is being suspended?

No. No legal suspension is in force: the 5 October 2026 vote was a committee vote on proposed legislation, and § 5(2) VerpackDG remains applicable. Cancelling before a final suspension applies would leave you without the representation the current rules require. If you are established outside the EU, the proposed suspension creates no EU-wide exemption for you: Germany requires a representative under § 5(2) VerpackDG, and the Parliament committee's position keeps the requirement for producers outside the EU. If you are an EU micro or small company, the representative could become optional only once a final text applies, and LUCID registration, system participation and reporting would remain your own obligations. The safe rule: keep complying until the law actually changes.

Checked: 6 October 2026 — the date every statement on this page was checked against the sources below.

Quick answer

Yes. If you currently need a German EPR authorised representative, you still need one today. The 5 October 2026 vote changes the legislative outlook, not your compliance obligation today. The European Parliament's environment committee voted 74–0, with four abstentions, for a proposed suspension that could, if adopted in its current form, make the German representative optional for qualifying EU micro and small companies. It is not law: the full Parliament has only an indicative plenary date (19 October 2026), and the Council of the EU discontinued talks on the suspension in June; on 30 September it agreed only that a targeted solution for small producers' PPWR EPR obligations should be explored, which is not a position, a text or a date. As of 6 October 2026, § 5(2) VerpackDG remains in force and the PPWR's authorised-representative rules have not been suspended. There is currently no exemption and no change to your obligation. Keep your representative until a final text is adopted, published and applicable; if it then covers you, you can stop from its date of application, not from the date of the committee vote. For producers established outside the EU the proposal creates no EU-wide exemption: Germany requires a representative under § 5(2) VerpackDG, and the Parliament committee's position keeps the requirement for them. France's national representative law is not affected at all.

At a glance: what to do now

Status on 6 October 2026	German EPR authorised representative
Current German law (§ 5(2) VerpackDG)	Required for producers without a German establishment
5 October committee vote	Does not remove the obligation
Proposed suspension for EU micro and small companies	Not law
Full Parliament vote	Pending; indicative date 19 October 2026
Council position	Not adopted; on 30 September agreed only to explore a targeted solution for small producers
Final EU legislation	Not adopted
Date any suspension would apply	Not set

Where your company is established	Under the proposal, if adopted	What to do now
Another EU country, micro or small enterprise (e.g. France, Poland, the Netherlands, Austria)	The representative could become optional, from the date the final text applies	Keep your representative. The requirement applies until then
Another EU country, medium-sized or large company	Not covered by the Parliament committee's version	Keep your representative
Outside the EU: United Kingdom, Switzerland, United States, China, Turkey or elsewhere	Not exempted: member states may keep requiring a representative, and Germany does	Keep your representative
Germany	Not relevant: the rule is for producers without a German establishment	Register yourself; no representative needed

A committee vote is not the law. Nothing changes for anyone until a final text is published in the Official Journal and applies. If it covers you, we will tell you in the week it is published, and from which date you can stop.

Check in two minutes whether the German obligation applies to you →

COM(2025) 982 final VerpackDG § 5 ZSVR help 2eu.brussels

What happened on 5 October

The European Parliament's Committee on the Environment, Climate and Food Safety adopted its position on the Commission's December 2025 proposal to suspend the authorised-representative requirement in the EU's producer-responsibility laws. It did so with near-unanimity, in two votes:

Products covered	For	Against	Abstentions
Batteries and packaging	74	0	4
Textiles, footwear, electrical and electronic equipment, single-use plastics	72	0	5

The headline has travelled fast: “Parliament backs reprieve”. The detail matters more than the headline, because the committee did not vote for the Commission's version. It voted for a narrower one.

2eu.brussels Packaging Insights

Who it would cover, and who it would not

Your company	Commission proposal (Dec 2025)	Parliament committee (5 Oct 2026)	Council of the EU (member states)
EU micro or small enterprise (under 50 staff, turnover up to €10 million)	Suspended until 2035	Suspended, until the EU's planned Circular Economy Act applies, and 1 January 2035 at the latest	No position. Talks discontinued in June 2026; on 30 September agreed only to explore a targeted solution for small producers
EU medium-sized or large company	Suspended until 2035	Not suspended	No position. Talks discontinued in June 2026; on 30 September agreed only to explore a targeted solution for small producers
Company established outside the EU (UK, Switzerland, US, China, Turkey…)	Member states may keep requiring one (Germany does) or use other enforcement means	Representative still required	No position. Talks discontinued in June 2026; on 30 September agreed only to explore a targeted solution for small producers

Two points are easy to miss. First, the size limit: the rapporteur, Ingeborg ter Laak, drew the line at the EU's own definition of micro and small enterprises, so a growing seller can fall out of the exemption as it grows. Second, the suspension removes only the representative. Registration in LUCID (§ 6 VerpackDG), participation in a dual system (§ 7) and the volume reports (§ 9) stay exactly where they are. A small EU seller would still have to do all three, in German, directly with the German authorities.

2eu.brussels COM(2025) 982 final Council of the EU VerpackDG § 6 VerpackDG § 7 VerpackDG § 9

The Council already stepped back once

A committee vote is the start of Parliament's half of the work. The other half belongs to the member states, and on this file they have already said no once. When the Council agreed its position on the rest of the environmental simplification package on 24 June 2026, it set the representative suspension aside:

“Given strong reservations by a vast majority of member states, and the upcoming comprehensive review of EPR frameworks under the circular economy act, expected in autumn 2026, negotiations within the Council on the two last proposals concerning EPR were discontinued.”

Since then, Germany has pushed the other way. On 7 September 2026 the federal government tabled its own amendment in Brussels: no representative for traders placing under ten tonnes of packaging a year, and registration in the new system paused until mid-2028. Germany's craft trades federation (ZDH) welcomed the 5 October vote and said openly that negotiations in the Council “had most recently been frozen”. One member state pushing does not make a Council position. On 30 September the member states agreed that “a targeted solution should be explored” for EPR obligations under the PPWR, because of a possible disproportionate burden on small producers of packaging. That is a direction of travel, not a negotiating position: there is no text and no date, and the statement does not mention the authorised representative.

Council of the EU Council of the EU European Parliament Research BMUKN ZDH

Why 74 votes in Parliament do not predict the Council

The 74 votes came from members of the European Parliament, not from countries. The environment committee has about 90 MEPs from all 27 member states, elected directly by voters, and they vote as individuals, largely along political-group lines. A 74–0 result means the main political groups agreed a compromise. It does not mean that 74 governments, or any government, said yes.

The Council is the other half of the EU legislature: one minister per member state, voting for a national government. A decision needs a qualified majority, at least 15 of the 27 member states representing at least 65% of the EU population, and four member states representing more than 35% of the population can block one.

	Parliament committee (ENVI)	Council of the EU
Who votes	About 90 MEPs, elected by citizens	27 national governments, one minister each
How they vote	As individuals, largely by political group	As countries, by qualified majority
Position on this file	74–0, four abstentions, for a narrower suspension (5 October 2026)	Negotiations discontinued after strong reservations from a vast majority of member states (24 June 2026)

The two often see a file differently. Business associations, from German craft trades to Dutch online retail, campaigned publicly for the suspension, and a narrow exemption for the smallest EU firms is an easy cross-party compromise. Governments run the system: their national registers enforce it, and their collection schemes need every producer to pay. Gunda Rachut, president of the European network of national packaging registers (EUNR), told Packaging Insights on 6 October that relaxing the rule risks more free-riding, leaving compliant producers to cover the cost. Governments also differ among themselves: Germany is pushing for an exemption, while in June a vast majority of member states had reservations.

The committee vote signals that Parliament will probably back the narrow version in plenary, and it gives the governments that want an exemption an argument. It does not change a single government's vote. Until the Council adopts a negotiating position on this proposal, formal negotiations on it cannot begin.

2eu.brussels Council of the EU Council of the EU Packaging Insights

What still has to happen

Step	Status
1. Commission proposal, COM(2025) 982	Done, 10 December 2025
2. Parliament committee (ENVI) vote	Done, 5 October 2026
3. Plenary vote: the full Parliament confirms or amends the committee position	Not yet held; indicative plenary date 19 October 2026
4. Council position: the member states reopen the file and agree a mandate	Not adopted. Talks on this proposal discontinued in June 2026; on 30 September a targeted solution for small producers was to be explored, with no text or date
5. Negotiations between Parliament, Council and Commission on a single text	Cannot start before step 4
6. Formal adoption by both institutions, after legal-linguistic review	Not started
7. Publication in the Official Journal and entry into force	Not started. Only from this date does anything change for you

Two of the seven main legislative steps are complete. The Council, whose step decides everything, has not adopted a negotiating position on this proposal.

COM(2025) 982 final 2eu.brussels European Parliament Council of the EU Council of the EU European Parliament Research European Parliament

How fast EU delays move, and when they do not

EU institutions can move quickly when they all want the same thing. Two recent postponements show the pattern:

Postponement	Proposed	Published	Council position
Sustainability reporting “stop-the-clock”, Directive (EU) 2025/794	26 February 2025	16 April 2025	Backed it from the start
Deforestation regulation one-year delay, Regulation (EU) 2024/3234	2 October 2024	23 December 2024	Backed it from the start
Representative suspension, COM(2025) 982	10 December 2025	Not adopted, ten months on	Discontinued negotiations

Both fast cases had one thing in common: the member states wanted the delay. This one is the reverse. The Council has already told everyone where it wants the question handled: in the comprehensive review of producer responsibility under the Circular Economy Act, which the Commission has yet to table. A full new law takes far longer than a targeted delay. For scale, the PPWR itself was proposed on 30 November 2022, adopted on 19 December 2024, and has applied only since 12 August 2026.

So there are two realistic routes. If the Council reopens the omnibus file, a suspension for EU micro and small companies could plausibly be in force sometime in 2027. If the question is folded into the Circular Economy Act, as the Council itself signalled, relief is a matter of years, not months, and may not take the form of a simple suspension at all. Neither route changes anything today.

Directive (EU) 2025/794 Regulation (EU) 2024/3234 COM(2025) 982 final Regulation (EU) 2025/40 (PPW

Why waiting costs more than complying

The obligation is not suspended while Brussels debates it. § 13(1) VerpackDG bars a producer that is not properly registered from making packaging available in Germany at all, and § 13(4) bars fulfilment providers from handling its goods. Neither waits for an authority to issue a fine. Amazon, eBay and Kaufland ask sellers for their German packaging registration, and a listing that fails that check goes offline the same way, with no warning period. Fines under § 66 VerpackDG reach up to €200,000.

Set that against what compliance costs. Appointing a representative now means a written mandate and a fixed annual fee: ours is €149 a year, with no setup fee. Appointing one after a marketplace has already pulled your listings means doing the same paperwork under time pressure, while every day offline is lost revenue. If the suspension is adopted and covers you, we will tell you in the week it is published, including when that means you no longer need us.

Check in two minutes whether the German obligation applies to you →

VerpackDG § 13 VerpackDG § 66 ZSVR help Amazon eBay Kaufland Global Marketplace

France is a different story entirely

Everything above concerns the EU rule and the German law that implements it. France has its own. Since 10 July 2026, French law n° 2026-602 of 8 July 2026 (article L. 541-10-9-1 of the French Environmental Code) requires every producer subject to French EPR and not established in France to appoint a French authorised representative, in writing. It is national law, it covers every EPR stream, not just packaging, and it has no minimum volume. It applies to EU sellers exactly as it applies to sellers from outside the EU, and the Brussels debate does not touch it.

If you sell into France as well as Germany, that obligation is already in force today, whatever happens to the EU proposal. Our French sister company, EPR France Rep, acts as French authorised representative, with a free plan for one EPR stream.

Code de l'environnement, art

About the authorRazvan Toma

Razvan Toma is the founder of EPR Germany Rep and of EPR France Rep, the French sister service. He reads the statutes and the regulator's own guidance directly, and publishes what they say — including when it means telling a visitor they do not need to buy anything.

Razvan on LinkedIn ↗

Do EU micro and small companies still need a German EPR authorised representative after the 5 October 2026 PPWR vote?