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FEAD calls to retain national authorized representative rules in EU waste system.

Environment, Energy, & Infrastructure · Environment · html · 2026-04-09

FEAD, the European Waste Management Association, calls for maintaining a national authorised representative (AR) requirement within the EU's Extended Producer Responsibility (EPR) systems. They warn that removing AR would invite free riders and weaken enforcement across member states, and therefore oppose suspension in favor of harmonisation, simplification, and greater transparency through a long-term, EU-wide approach. The association notes concerns raised by member states about access to enforcement information, tight implementation timelines, and the shift of responsibilities potentially leading to divergent approaches undermining harmonisation. FEAD supports reforms including harmonising AR definitions and liabilities, creating a central EU register linking ARs to producers and EPR schemes, establishing minimum qualification standards and professional liability insurance, simplifying AR appointment procedures, clarifying 'establishment' for digital commerce, and allowing a single AR per country for multiple EPR streams to reduce duplication. FEAD highlights wide variation in AR liability, the lack of a central registry, and the lack of quality control, which create non-compliance risks and unfair competition. It also notes that in many member states, anyone with a legal presence can act as an AR, and calls for EU-wide rules. FEAD represents over 3,000 companies across 21 national associations, supporting more than 500,000 local jobs and €5 billion in annual investments. For more information, contact info@fead.be.

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