Joint statement on Authorised Representative for Extended Producer Responsibility (EPR)

Toy Industries of Europe, together with 8 European business associations, has co-signed a Joint Statement calling on the EU
Parliament and Council to maintain the temporary suspension of the AR until 1 January 2035 and focus on developing harmonised, EU-level compliance and enforcement mechanisms that are fit for purpose.

The undersigned associations express serious concern regarding the opposition to the proposed suspension of national AR requirements for EPR. While supporting the objective of combating free-riding and ensuring effective EPR enforcement, the associations believe that opposing the suspension risks entrenching a patchwork of national requirements at a time when the Commission and EU leaders have called for a more harmonised Single Market. This should be reflected through the upcoming Circular Economy Act, the ambition of which must be preserved ahead of its formal proposal. Consequently, the undersigned associations believe that maintaining fragmented national AR obligations is the wrong instrument to deliver this objective. Such requirements risk undermining the core principles of the Single Market.

Efficient enforcement and EPR fee collection can be achieved by prioritising EU-wide, digital, and interoperable compliance tools. The proposed suspension is a pragmatic bridge towards building a more effective EPR compliance and enforcement model. It creates the political space needed to design an EU-wide system that is enforceable and proportionate, in line with the Commission’s simplification and Single Market agenda.

Read the full statement here.