European Commission publishes proposal COM(2025) 982 to suspend authorised representative requirement for batteries EPR (Article 56(3)) until January 2035

The European Commission published a legislative proposal (COM(2025) 982) to suspend the application of Article 56(3) of Regulation (EU) 2023/1542 (authorised representative requirement linked to extended producer responsibility for batteries) until January 2035. If adopted, the change would reduce administrative burden for certain cross-border sales scenarios by altering when/where an authorised representative must be appointed for EPR purposes. This is a proposal (not yet adopted), and should be tracked for potential downstream impacts on EPR registration strategy and representation arrangements across Member States.