On 5 October 2026, the European Parliament’s Environment Committee approved a proposal to temporarily suspend a specific extended producer responsibility (EPR) obligation for EU-based SMEs. The measure could simplify cross-border sales of packaged seafood, subject to final legislative approval.
Selling packaged products in several European Union countries can involve different national packaging compliance requirements. In its position adopted on 5 October, the European Parliament’s Committee on the Environment, Climate and Food Safety (ENVI) proposed a targeted simplification: temporarily suspending the obligation for eligible EU-based SMEs to appoint an authorised EPR representative in other Member States.
What would change for EU-based SMEs
Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), generally applicable since 12 August 2026, also sets out requirements concerning extended producer responsibility.
The European Commission initially proposed suspending the authorised-representative requirement until 1 January 2035. ENVI members instead want to limit the measure to SMEs established within the EU and end the suspension automatically once comprehensive European circular economy rules enter into force.
Which businesses could benefit
The proposed suspension would cover companies employing fewer than 250 people and having an annual turnover below €50 million or an annual balance sheet total below €43 million.
Producers established outside the EU would remain subject to the authorised-representative requirement.
The simplification would concern only the appointment of the representative. Other applicable EPR obligations, including registration, reporting and financial contributions, would remain in place.
Potential implications for the seafood industry
The EU packaging simplification proposal could benefit seafood SMEs marketing packaged products in other EU Member States, where their role in the supply chain and sales arrangements make the appointment of an authorised representative necessary.
For example, an Italian company selling packaged canned seafood directly to consumers in another Member State could potentially benefit from the suspension.
However, eligibility would depend on the company’s circumstances and the final legislative text. The proposal should not be interpreted as a general exemption for seafood exports or for all business-to-business transactions.
The European vote and next steps
ENVI adopted its position on the legislative proposal covering packaging and batteries with 74 votes in favour, none against and four abstentions.
The text is expected to be examined during the European Parliament’s plenary session of 19–22 October 2026. Negotiations with the Council of the EU would follow, with reservations already raised over the suspension of representative obligations.
For seafood businesses operating across European markets, the next step will be to monitor the legislative process and assess which EPR requirements will continue to apply in each destination country if the proposal becomes law.
