Since 12 August 2026, a non-EU seller must appoint an authorised representative (AR) in every EU country where it sells. Now a proposal in Brussels wants to suspend that duty until 2035. Here's what is actually happening — and why it changes nothing for a US, UK or other non-EU seller.
TL;DR — The Council vetoed the proposed suspension of the PPWR authorised representative duty in June 2026 — and non-EU sellers were never exempt in the first place.
The proposal
In December 2025, the European Commission proposed COM(2025)982, which would suspend Article 45(3) of the PPWR — the clause that makes an authorised representative mandatory — until 1 January 2035.
The Council already said no
On 24 June 2026, the Council of the EU decided not to proceed with the suspension, opposed by a large majority of member states. The idea is not dead — but it has already been knocked back once.
Next: the ENVI committee vote on 1 October
The European Parliament's ENVI committee votes on the amendments around 1 October 2026. That is the date to watch. But here is the part most coverage misses:
Why it changes nothing for non-EU sellers
Every version of the "suspension" — including the Parliament's narrower approach — applies only to EU-based producers, mostly micro-enterprises. Producers established in third countries, including the US, UK and China, are explicitly excluded from any exemption.
In plain terms: Article 45(3) applies as written today, and for a non-EU seller it will continue to apply no matter how the 1 October vote goes.
The practical takeaway: don't wait for a suspension that will never cover you. If you sell into the EU without a local establishment, you need an authorised representative today — and you'll still need one after the vote.
Sources: the Commission proposal COM(2025)982 and independent PPWR tracking (e.g. PAQR, Tarafex Belgium desk).
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