The problem
National EPR authorisation and PRO rules
Producers must be registered and, where they fulfil EPR individually or through a producer responsibility organisation, authorised. Chapter VIII applies from 18 August 2025. Member States may add further requirements to the Art. 58(7) guarantee. Authorisation practice, appointed PROs and national waste authorities differ.
Regulation (EU) 2023/1542, Arts. 54–58; Member State measures
Union EPR still needs a national counterparty. Authorisation, supervision and additional guarantee conditions are Member State paths.
What to read
- Arts. 54–58 EPR, registration and authorisation
- Art. 58(7) — Member States may add further guarantee requirements
- Chapter VIII from 18 August 2025; Directive 2006/66/EC repealed from that date
Where LOOBA sits
LOOBA administers EPR participation so the manufacturer, authorised representative or PRO remains the regulatory counterparty while the reserve, network and reporting are executed as one programme.
Orientation for professional counterparties. Not legal advice.