SMEunited, the European association of small and medium-sized enterprises, has formally urged the European Union to suspend the authorized representative requirement contained in the bloc's packaging regulation, arguing the rule imposes disproportionate compliance costs on smaller operators.

The demand targets a provision that obliges companies without a physical presence in the EU to designate an authorized representative responsible for their conformity obligations under the packaging framework. SMEunited contends that this administrative layer falls hardest on SMEs, which lack the legal and regulatory departments that large packaging producers and brand owners can deploy.

What is the authorized representative rule?

Under the EU packaging regime, economic operators that place packaged goods on the single market must be answerable to national authorities for compliance with labeling, recyclability and data-reporting duties. Where a company is established outside the EU, the regulation requires it to appoint an authorized representative inside the bloc to carry that liability.

SMEunited's position is that for small importers, distance sellers and micro-manufacturers, the cost of retaining such a representative — in legal fees, ongoing mandates and liability exposure — is out of scale with the compliance risk the rule is designed to capture.

What does the lobby group want?

The association is asking the European Commission to suspend the requirement for SMEs rather than amend the regulation through the full legislative cycle. A suspension would relieve small firms of the obligation while the Commission reviews the burden, according to SMEunited.

The call lands as EU institutions continue shaping the secondary legislation and implementing acts that will determine how the packaging rules operate in practice for member-state markets and the recyclers who depend on collected material flows.

Why does this matter for the recycling chain?

The packaging regulation is the legal backbone of the EU's push to make all packaging recyclable and to lift recycled-content rates across plastic and other material streams. Compliance architecture — who is legally on the hook for declarations — directly affects the quality of the data that underpins extended producer responsibility fees and recycling targets.

If smaller operators exit the formal compliance system because the representative mandate is too costly, the reporting base narrows. Conversely, if the EU suspends the rule, enforcement authorities lose a named legal counterparty for a segment of the market.

What happens next?

The ball sits with the European Commission, which must decide whether to act on SMEunited's request for a suspension or let the provision stand and address SME concerns through guidance and implementing measures. The association's campaign will run alongside the transposition and application timeline of the packaging rules.

The decisive milestone is the Commission's response: whether it grants a formal suspension of the authorized representative obligation for SMEs, defers it through implementing acts, or rejects the request outright. Each outcome sets a different compliance path for thousands of small packaging placers — and a different enforcement picture for the regulators tracking them.