The European Union has moved to reduce the administrative burden imposed on smaller businesses by its packaging legislation, agreeing a negotiating position that would relax requirements for companies selling limited quantities of packaged goods in other member states.

The Council adopted its position on 21st October, proposing an exemption from the obligation to appoint an authorised representative in another EU country when the amount of packaging placed on that country’s market remains below one tonne per calendar year.

The measure addresses complaints from small and medium-sized enterprises that the Packaging and Packaging Waste Regulation, which became applicable on 12th August 2026, creates unnecessary expenses for companies engaged in relatively modest volumes of cross-border commerce.

The proposal forms part of the EU’s eighth legislative simplification package and will now be negotiated with the European Parliament.

Cross-border compliance costs under scrutiny

Under the Packaging and Packaging Waste Regulation, businesses placing packaging or packaged products on the European market are subject to obligations concerning waste management and extended producer responsibility.

The extended producer responsibility system requires producers to contribute to the management of waste generated by products and packaging placed on the market.

For businesses operating across borders, the framework also includes requirements concerning authorised representatives in member states where producers are not established.

These representatives perform specified compliance functions and provide a point of contact for national authorities.

The system can create substantial administrative obligations for businesses trading in several countries, particularly when the quantity of packaging supplied to individual markets is limited.

A small Belgian retailer, for example, may sell products to customers in Germany, France and the Netherlands without maintaining physical operations in those countries.

The requirement to arrange representation separately across different markets can add compliance costs regardless of whether the volume of trade justifies them.

Under the Council’s proposal, eligible EU-based producers placing less than one tonne of packaging annually on another member state’s market could be exempted from appointing a representative there.

The threshold would be assessed by reference to the quantity placed on the market of the member state concerned.

However, the proposed exemption would not abolish the wider principle of extended producer responsibility or automatically release businesses from their other environmental obligations.

Packaging reform follows early implementation problems

The regulatory changes come only two months after the EU’s revised packaging framework began applying across the single market.

The legislation, Regulation (EU) 2025/40, is intended to reduce packaging waste, improve recyclability and establish more consistent requirements for products and packaging materials.

It covers an extensive range of commercial activities, including manufacturing, retail, food distribution, transport packaging and online sales.

As EU Today reported when the regulation began applying in August, the legislation introduces new requirements affecting packaging design, materials and waste prevention.

However, the practical implications for smaller firms have generated pressure for modifications.

In September, EU Today examined the emerging campaign for simplification, as business organisations questioned whether the compliance system adequately reflected the circumstances of smaller producers.

The Council’s latest agreement represents a further legislative step, replacing general calls for administrative relief with a specific negotiating position.

The Commission also issued detailed implementation guidance in June 2026 after receiving numerous questions from member states and businesses about how the regulation should be interpreted.

Safeguards and temporary exemption

The proposed exemption would not apply without conditions.

The Council’s negotiating mandate includes a safeguard allowing the relevant authorities to respond when a producer fails to comply with extended producer responsibility obligations.

It also provides for the European Commission to review the duration of the temporary suspension by 31st December 2030, ahead of its scheduled expiry in 2032.

The timetable reflects the possibility that broader reform of producer responsibility arrangements could replace the temporary measure.

The Commission is preparing a Circular Economy Act intended to address additional problems affecting Europe’s recycling and secondary raw materials markets.

That initiative could provide a more comprehensive framework for the administration of producer responsibility systems across member states.

For now, the Council has opted for a narrower intervention designed to reduce the immediate burden on smaller companies without reopening the entire packaging regulation.

Single market objectives and environmental obligations

The proposal also reflects a broader problem with European regulatory integration.

Although companies can sell goods throughout the single market, compliance requirements often remain administered through national systems, requiring businesses to deal with separate authorities and procedures.

For multinational corporations, such costs can be distributed across substantial commercial operations. For smaller exporters and online retailers, similar administrative requirements can consume a much greater proportion of turnover.

The Council argues that removing unnecessary representation requirements would support cross-border trade while preserving the objectives of European environmental legislation.

The Irish presidency will now seek agreement with the European Parliament on the proposed amendment.

Until that legislation is adopted and becomes applicable, businesses must continue to comply with the existing rules, including relevant national producer responsibility requirements.

“The European Union has decided that the textile and clothing sectors must become circular. But there is a gap – one that no one has yet measured – between the strategy set out in Brussels and the factory that has to implement it, and it is this gap that will determine whether or not the European textile and clothing industry will survive its own transition,” writes César Araújo, President of ANIVEC, the Portuguese Association of Clothing, Apparel and Fashion Industries, and Chair of the Executive Committee of the Lusitano Project Consortium.

The textile and clothing sectors are by no means minor players in the European industrial landscape. We are talking about a turnover of around 166 billion euros, nearly 1.2 million jobs and almost 200,000 companies – the overwhelming majority of which are micro, small and medium-sized enterprises. We are talking about an industrial sector which, according to the latest figures from EURATEX (the European confederation for the sector, of which ANIVEC is a member), exports €61 billion worth of goods and, in 2024 alone, invested a total of €5.3 billion in tangible assets.

This is an industry that has demonstrated truly exemplary resilience within the European Single Market, operating in a highly competitive and profoundly unequal environment; one that is open to all manner of external sources, whose requirements are applied relentlessly to domestic producers, but which, in practice, operates without any form of effective control or trade safeguards vis-à-vis external producers.

Without first rectifying the unfairness in the European Single Market, new requirements are now being imposed on the European textile and clothing industry, requiring it to absorb, simultaneously and within a short space of time, new eco-design rules, the introduction of the digital product passport and extended producer responsibility, amongst countless other demands.

The decision to move towards a circular economy is not in question. Indeed, this is probably the only way forward for an industry that Europe should wish to retain within its borders. The problem lies in the way this future is being shaped: with rules devised exclusively from the top down, aimed at a sector that continues to compete on a daily basis under conditions that no one else would tolerate. We are, moreover, well aware of the measures, support and initiatives from which the European automotive industry has benefited, precisely because it is now experiencing what the textile and clothing sectors have been facing for decades.

Let’s look at what happened a few weeks ago in Paris, on the fringes of Première Vision. The European textile and fashion federations have once again joined forces to denounce the competitive imbalance caused by fast fashion. The abolition of the customs exemption for low-value parcels and the introduction of a transitional customs duty of 3 euros were a first step. But that is just that: a first step. Now, the federations are calling for a more ambitious European handling fee, closer to 10 euros, capable of reflecting the real cost of customs control, market surveillance and the safety of the millions of products entering the EU every day. We continue to demand of compliant European brands what we do not demand of those who flood our market from outside. What is being called for is not protectionism; it is simply reciprocity.

That is why circularity cannot be treated as a mere exercise in documentary compliance. A factory that already complies with strict European environmental and social standards, operates under recognised certifications and ensures traceable supply chains, should embark on this transition with a real advantage. But this advantage will only translate into competitiveness if the EU is able to distinguish it – and reward it – from production that disregards circularity criteria and, consequently, does not internalise these costs in the final price of the product.

We have long known what needs to be done to ensure that, by 2030, we have sustainable and circular textiles and clothing in the EU. European industry is the right partner to drive the value chain forward, ensuring that products placed on the market are genuinely durable, repairable and recyclable; made largely from recycled fibres; free from hazardous substances; and produced with full respect for social rights.

However, whilst we must ensure fairness within the Single Market, the key question that remains to be answered in order to realise the 2030 vision is not a conceptual one, but a strictly operational one. Who collects? Who sorts? Who recycles? Who pays and on what scale? What is needed for textile recycling to move beyond the pilot project stage and truly become an industry?

It is to answer these questions, backed by data and practical experience, that ANIVEC, CENIT and the Lusitano Project are organising a meeting at the European Parliament in Brussels on 30 September. Under the patronage of MEPs Paulo Cunha (PT/EPP) and Bruno Gonçalves (PT/S&D) and under the theme “Making circular textiles work in Europe: Transparency, Recycling and Industrial Competitiveness” (https://shorturl.at/r8Ml4), the aim is clear: to bring together European institutions, industry and organisations that are already implementing circular solutions on the ground – with practical experience in extended producer responsibility and recycling – to discuss what is actually needed for textile circularity to work on a European scale.

At the end of the day, the question is not whether the European textile and clothing industry wants to be circular. The answer to that question is given in the affirmative, every single day, by our companies. The question on the table is whether Brussels wants to rely on the European textile and clothing industry as its chosen partner to make this circularity a reality within the European Single Market. To this end, it is imperative to ensure the industrial and commercial conditions that make circularity genuinely competitive. If the response continues to be regulation without reciprocity, we run the very real risk of being left with only the world’s most stringent standards whilst exporting whatever production we have left.

The circular economy is no longer an aspiration—it is becoming a necessity. As industries seek to reduce their environmental footprint while preserving valuable resources, extending the life of products through refurbishment has emerged as one of the most effective strategies available, writes Julien Morganti, General Manager of P.E.P. ecopassport®.

Across the electrical, electronic and HVAC sectors, demand for refurbished equipment is growing rapidly. Customers are increasingly looking for solutions that combine environmental responsibility with economic value, while manufacturers and service providers are investing in refurbishment capabilities to meet these expectations. Yet one major challenge has remained: how can we assess the environmental performance of refurbished products in a way that is both robust and transparent?

For new products, environmental declarations have become an established tool for measuring and communicating environmental performance. Refurbished products, however, have lacked a common methodology capable of reflecting their specific characteristics while ensuring consistency and credibility across the market.

This is precisely the challenge that P.E.P. ecopassport® has sought to address through the publication of a new methodological guide dedicated to refurbished equipment—the first initiative of its kind in France and, to our knowledge, across Europe for electrical, electronic and HVAC equipment.

Developing this methodology required answering a fundamental question: how should the environmental impacts and benefits associated with refurbishment be allocated? Inspection, repair, component replacement and testing all generate environmental impacts, yet refurbishment also avoids the production of an entirely new product and extends the useful life of existing equipment.

Finding the right balance was only possible through close collaboration between manufacturers, industry associations and technical experts. The resulting methodology recognises the environmental contribution of both the refurbished product and the original product designed with refurbishment in mind. Rather than focusing solely on carbon emissions, it evaluates the full range of Life Cycle Assessment (LCA) indicators, including material and resource consumption, providing a far more comprehensive picture of environmental performance.

This broader perspective matters because the transition to a circular economy cannot be measured by greenhouse gas emissions alone. Conserving raw materials, reducing resource depletion and maximising product longevity are equally critical objectives if we are to build truly sustainable industrial systems.

Importantly, this guide is not intended to be the final word. It provides a shared foundation that the industry can build upon as experience grows. As more refurbished products are assessed, the methodology will continue to evolve and, ultimately, become integrated into the

programme's Product Category Rules (PCRs) and Product Specific Rules (PSRs), where applicable.

Standardised environmental assessment is about more than technical consistency. It creates confidence. Manufacturers gain a recognised framework for communicating the environmental value of refurbished products. Specifiers and purchasers receive comparable, reliable information to support procurement decisions. Ultimately, the entire market benefits from greater transparency.

The transition towards circularity requires more than innovation in products—it also requires innovation in the way environmental performance is measured. By establishing a common methodology for refurbished equipment, we hope to remove one of the barriers that has limited wider adoption and provide the market with the confidence needed to accelerate the circular economy.

Because if refurbishment is to become a mainstream component of sustainable industry, it must be supported by environmental assessment methods that are as rigorous, credible and forward-looking as the products themselves.

About the P.E.P Association

Founded in 2009, the P.E.P Association is a non-profit organization whose purpose is to help reduce the environmental impact of electrical, electronic, and digital products by facilitating the dissemination of reliable, transparent, and verified information across the entire value chain.

In compliance with ISO 14025, its mission is to define governance rules, develop, verify, and publish Product Environmental Profiles (PEP) or Environmental Product Declarations (EPD), while adhering to principles of transparency and ethics. It also aims to bring together industry stakeholders to promote these practices.

Recognized as a leading operator in the sector at the international level, the P.E.P Association contributes to national and European standardization and works toward harmonizing programs across countries.

This consultation invites stakeholders to propose changes to the VAT rules so that they  better support circular business models. 

The European Commission has launched a consultation on the alignment of VAT rules with the principles of the circular and low emission economy. This initiative, part of the upcoming Circular Economy Act, aims to support the transition towards a more sustainable and competitive European economy.

The Circular VAT consultation seeks stakeholder input on how VAT rules can be adapted to better support circular business models. The focus will be on three key areas: the treatment of second-hand goods, the destruction of  viable goods, and the VAT deduction rules for passenger cars used for business purposes.

The consultation is part of a broader evaluation and impact assessment process, which will run in parallel and is expected to conclude in early 2027. The findings from this process will inform a legislative proposal aimed at amending the VAT Directive to better align with the objectives of the circular and low emission economy.

The consultation is open for eight weeks and will be accessible via the Commission's 'Have your Say' portal. Stakeholders, including business federations, SMEs, trade associations, national tax authorities, academics, and the general public, are encouraged to participate and share their views.

This initiative is a crucial step towards creating a more coherent VAT framework that supports the circular economy and contributes to the EU's environmental sustainability objectives.

Businesses, tax experts & sustainability advocates – share your views by 4 November 2026.

Have your say!

They asked for a Circular Economy Act that goes beyond waste management to focus on using resources more efficiently, among other things. European Commissioner Jessica Roswall met on Monday (31 Aug) with 16 young people who helped shape the European Commission's Youth Check on the upcoming Circular Economy Act (CEA).

The meeting with the Commissioner for Environment, Water Resilience and a Competitive Circular Economy was part of the participatory process launched earlier this year to ensure that young people's views help guide the Commission's flagship initiative for Europe's circular economy. 

It followed her first exchange with young participants at the annual conference of the European Circular Economy Stakeholder Platform (ECESP) in April. Since then, a team of youth representatives has worked to develop a Youth Position Paper setting out their recommendations. 

At the meeting, the group presented their main messages and discussed with Commissioner Roswall the opportunities and challenges of Europe's circular transition. They called for a Circular Economy Act that goes beyond waste management to focus on using resources more efficiently, making products easier to repair and reuse, ensuring safe, high-quality secondary materials, keeping the transition affordable and fair, investing in circular skills, and maintaining meaningful youth involvement throughout implementation.

The discussion also allowed the Commissioner to respond to the youth recommendations, reflect on the contribution of the Youth Check to the policy-making process and reaffirm the Commission's commitment to effective youth involvement. 

“Young people are not only stakeholders in Europe’s circular transition; they are essential partners in shaping it. We need young people to voice their ideas and be part of the change that will make Europe’s circular economy a reality. I am happy to receive their ambitious recommendations today, which will help inform our work as we prepare the Circular Economy Act.”

Environment, Water Resilience and a Competitive Circular Economy Commissioner Jessika Roswall

"In the last few months we have seen what effective and tangible youth input can look like in policy-making. We appreciate the opportunity to openly share our recommendations with Commissioner Roswall and DG Environment to shape the Circular Economy Act. This is a significant step forward for meaningful youth participation in environmental policy. The Act will set the framework for a future that we, as young people, will feel the effect of, and we are ready to continue contributing to it with our ideas."

Representatives of Generation Climate Europe and Academics for a Circular Economy

Background

The CEA, due to be adopted before the end of 2026, aims to accelerate the transition to a more circular economy, increasing the EU’s economic security, resilience, competitiveness and decarbonisation.

It is intended to improve the business case for circularity by facilitating the cross-border movement of recycled products, materials, and waste across Europe. It will also increase the supply of high-quality recycled materials and stimulate demand for these materials in the EU. 

The Youth Position Paper on the CEA was coordinated by the youth organisations Academics for Circular Economy (ACE) and Generation Climate Europe (GCE).  

The CEA Youth Check combined a targeted online consultation of young people aged 15 to 29, a dedicated youth session during the ECESP Annual Conference, and additional exchanges with youth stakeholders. It will also inform the Impact Assessment prepared for the Circular Economy Act in line with the Commission's Better Regulation Guidelines.  

More information 

Youth Perspectives on the EU Circular Economy Act: A Youth Assessment of Ambitious, Gaps and Implementation Conditions | European Circular Economy Stakeholder Platform

Summary of the online Youth Consultation | European Commission

Summary of the ECESP Conference | European Circular Economy Stakeholder Platform

Youth Check | European Youth Portal

Circular Economy Act | European Commission