Your monthly briefing on the developments, insights and opportunities shaping the corrugated packaging industry.
Welcome to Unboxing Insights, FEFCO’s monthly newsletter! This month, we look at updates to the PPWR EPR authorised-representative requirement and what they could mean for businesses operating across Europe, how reliable industry data can support better business decisions, and what to expect from FEFCO’s forthcoming circularity study. And that’s not all. We also bring you practical resources about strengthening cybersecurity and new examples you can use in your communications about how corrugated packaging helps protect food, reduce waste, and keep valuable materials in circulation.
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Packaging and Packaging Waste Regulation
FEFCO calls for suspension of the EPR authorised-representative for EU producers independently of their size
The European Parliament and Council have adopted different positions on how to suspend the PPWR requirement for businesses to appoint an EPR authorised representative when selling across borders. Trilogue negotiations are now slated to begin. For businesses selling around the continent, the stakes are practical: will there be more or less administrative burden and complexity? Will compliance be streamlined or will added hurdles be put in place?
The Parliament proposes an exemption for micro and small enterprises. The Council proposes to limit the exemption to companies placing less than a tonne of packaging per year in one EU national market.
The corrugated cardboard packaging value chain supplies businesses whose products travel across Europe. When those businesses sell packaged products in Member States where they are not established, they may need to appoint an authorised representative to meet their EPR obligations. Combined with different national registration and reporting processes, this can add complexity across the value chain.
FEFCO, in line with Fibre Packaging Europe (FPE), proposes the following recommendations for the Trilogues. To ensure a functional, competitive and truly simplified framework, we request the following text adjustments during the three-party negotiations:
- Amend the suspension text to ensure that the exemption from Article 45(3) of Regulation (EU) 2025/40 (PPWR) applies to all producers established within the European Union, independently of size.
- Retain the mandatory Authorised Representative exclusively for non-EU operators. Thus, protecting the internal market from free-riding and ensuring robust environmental traceability while supporting EU operators’ competitiveness.
- Reject volume and/or size caps: Delete any operational barriers based on annual market tonnage per Member State.
- Any suspension must be accompanied by effective mechanisms ensuring producer registration, reporting, financing of extended producer responsibility obligations and enforcement across borders.
Effective EPR rules must strike a good balance between making responsibilities traceable and enforceable, and keeping cross-border compliance proportionate, predictable and workable. The policy challenge is to remove unnecessary administrative burdens without undermining producer accountability.
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