EU Commission wants to scrap authorised representative obligation under PPWR

According to the German Retail Association (Händlerbund), the European Commission responded to a post by the association on social media on 12 August.
Image: wasanajai / Shutterstock.com

The Händlerbund welcomes the European Commission's proposal to abolish the obligation to appoint an authorised representative for cross-border shipping within the EU. The association is calling for the PPWR (EU Packaging and Packaging Waste Regulation) rule, which has been in force since 12 August 2026, to be suspended until a practical solution is found.

According to the Händlerbund, the European Commission responded to a post by the association on social media on 12 August, stating that it had already called on Parliament and member states to abolish the authorised representative requirement. The Commission submitted a corresponding legislative proposal in December 2025. Until the legal situation changes, the competent national authorities are therefore initially expected to issue warnings and refrain from imposing sanctions.

Händlerbund sees burden for smaller retailers

The Händlerbund considers the current regulation to be a particular burden on small and medium-sized online retailers who only occasionally ship goods to other EU member states. In such cases, the associated administrative burden could be disproportionate to the turnover generated.

„We very much welcome the fact that the European Commission has recognised the problem and put forward a concrete proposal. That is precisely what we have been demanding for months,“ explains Tim Arlt, CEO of the Händlerbund. „The current regulation mainly affects small and medium-sized retailers who have previously occasionally shipped goods to other EU countries. For a two-person partnership (GbR), the requirement entails an administrative burden that is completely disproportionate to its turnover.“

According to the association, the requirement for an authorised representative could also have an impact on the EU single market. If smaller traders were to stop cross-border shipping because of the additional costs and administrative requirements, this could affect trade between member states.

„Suspending the obligation to appoint an authorised representative would ensure that small and medium-sized merchants can continue to trade across the EU without being excluded from foreign business by disproportionate bureaucratic effort. That is precisely what matters to us, said Arlt.

Legislative change not yet passed

According to the Händlerbund, the European Commission's proposal to abolish the requirement has been on the table since December 2025. However, discussions in the Council of the EU were suspended a few weeks ago after a majority of member states spoke out against it.

A restricted version is currently being discussed in the European Parliament. According to this, an exemption is only to apply to micro-enterprises with up to 49 employees and an annual turnover of a maximum of 10 million euros. A first reading is scheduled for October 2026 at the earliest.

„The Commission (…) has spoken directly to us on social media: Under an Instagram video of the Retailer association she stated that she had called on Parliament and member states to abolish the obligation to appoint an authorised representative.“

According to the Händlerbund, the requirement for an authorised representative therefore remains part of the PPWR regulations applicable from 12 August 2026. The association is appealing to the European Parliament and the member states to take up the Commission's proposal and adopt a solution that takes account of different company sizes and structures in online retail.

„A regulation without a de minimis threshold treats structurally unequal cases equally. In the end, that harms precisely the retailers who keep the European Single Market alive, explains Arlt.

The Händlerbund also provides affected companies with a template that they can use to submit feedback on the PPWR directly to the European Commission.

Source: Retailer association