Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL suspending the application of the rules on the appointment of an authorised representative for extended producer responsibility for batteries and waste batteries and packaging and packaging waste
Date: 2025-12-10
Institutions: Directorate-General for Environment, European Commission
Subjects: EU Member State, application of EU law, electricity storage device, extended producer responsibility, market approval, packaging, third country, traceability, waste

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   EUROPEAN COMMISSION  Brussels, 10.12.2025  COM(2025) 982 final 2025/0395 (COD)  Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL suspending the application of the rules on the appointment of an authorised representative for extended producer responsibility for batteries and waste batteries and packaging and packaging waste (Text with EEA relevance)  
 
EXPLANATORY MEMORANDUM 

1. 

• 

CONTEXT OF THE PROPOSAL 

Reasons for and objectives of the proposal 

Union legislation should deliver its policy objectives efficiently, effectively and transparently. 
These longstanding principles can be traced back to the 2001 White paper on Governance (1) 
which  put  better  regulation  and  stakeholder  engagement  at  the  heart  of  European 
policymaking. The Competitiveness Compass (2) continues the promotion of responsible law-
making.  It  announced  unprecedented  efforts  to  simplify  legislation  to  reignite  the 
competitiveness  of  European  business.  Moreover,  the  Commission  has  since  strengthened 
targets to reduce administrative costs for business (together with public authorities) and Small 
and Medium sized Entreprises by 25% and 35% respectively (3). 

A mature body of Union environmental law now exists. The Commission takes seriously its 
duty to manage these laws effectively and invests heavily in reviewing (4) their application to 
ensure that they deliver as intended and that problematic issues are tackled early.  Moreover, 
the Commission is committed to ‘stress-test’ all EU laws under its current term of office. The 
content of this proposal (and others in the ‘omnibus’ package) represents the initial fruits of 
the  Commission’s  ongoing  ‘stress-testing’  in  the  environment  area (5)  built  on  extensive 
dialogue and inputs from civil society. The omnibus package addresses legislation related to 
the circular economy, the operation of industrial installations, the management of geospatial 
data, and environmental permitting. 

The above legislation are crucial parts of delivering the Union’s commitment to a fair green, 
and  digital  transition  and  the  shift  towards  a  circular  economy  in  particular.  It  is  important 
that this legislation works well, mobilises the Union’s assets like the single market and avoids 
imposing unnecessary costs on business, public authorities and citizens.  

This  specific  proposed  Directive  aims  to  reduce  the  administrative  burden  for  producers 
established in one Member State of the Union selling their products in other Member States, 
in  relation  to  the  participation  of  these  producers  in  the  extended  producer  responsibility 
schemes in those other Member States, set up under Regulation (EU) 2023/1542 on batteries 
and  waste  batteries (the  Batteries Regulation)(6)  and  under  Regulation  (EU)  2025/40  on 
packaging and packaging waste (the Packaging Regulation)(7) . 

The producer of a product placed on the market  of a Member State has the responsibility to 
cover  the  costs  of  managing  the  product  at  its  end  of  life  (so  called  ‘Extended  Producer 
Responsibility  or  EPR).  The  Waste  Framework  Directive sets  out  the  minimum  general 

1  COM(2001) 428 final of 12 October 2001, European governance - A white paper. 
2  COM(2025) 30 final of 29 January 2025, A Competitiveness Compass for the EU. 
3  COM(2025) 47 final of 11 February 2025, A simpler and faster Europe: Communication on implementation 

and simplification. 

4  COM(2025)  420  final  of  7  July  2025,  2025  Environmental  Implementation  Review  -  Environmental 

implementation for prosperity and security. 

5  Announced by President von der Leyen in her political guidelines 2024-2029 ‘Europe’s Choice’. 
6 

Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning 
batteries  and  waste  batteries,  amending  Directive  2008/98/EC  and  Regulation  (EU)  2019/1020  and 
repealing Directive 2006/66/EC; OJ L 191 28.7.2023, p.1. 
Regulation  (EU)  2025/40  of  the  European  Parliament  and  of  the  Council  of  19  December  2024  on 
packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, 
and repealing Directive 94/62/EC; OJ L, 2025/40, 22.1.2025, p.1. 

7 

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requirements  for  extended  producer  responsibility  while  specific  rules  for  different  product 
groups  exist  in  other  legislation  such  as  the  Regulation  on  packaging  and  packaging  waste, 
the  Regulation  on  batteries  and  waste  batteries,  the  Directive  on  electronic  and  electrical 
waste,  and  the  Single  Use  Plastics  Directive,  as  well  the  Directive  on  end-of-life  vehicles 
(currently  subject  to  revision  under  an  ongoing  ordinary  legislative  procedure) (8).  Member 
States  may  also  establish  national  rules  on  extended  producer  responsibility  for  other 
products, provided these rules comply with the minimum requirements set out in Article 8 and 
8a of the Waste Framework Directive.  

An  authorised  representative  for  EPR  acts  on  behalf  of  an  economic  operator  (producer) 
selling products in a Member State where the producer is not established or if it is established 
in a third country. The purpose is to ensure that producers making available products on the 
territory of a Member State comply with the rules on EPR so that the costs of the management 
of waste generated in that Member State are covered.  

In  the  May  2025  Communication  on  a  strategy for  the  single  market(9),  the  Commission 
highlighted the complexity of EPR rules as a major barrier in the internal market, in particular 
as regards the possibility or obligation for a producer to have an authorised representative for 
EPR in each Member State where the producer makes its products available.  

This  proposal  would  provide  additional  flexibility  by  allowing  producers  established  in  the 
Union  and  selling  products  in  another  Member  State  to  choose  whether  they  appoint  an 
authorised  representative  for  EPR.  Provisions  regarding  the  appointment  of  authorised 
representatives for EPR for producers based in third countries should remain as they currently 
are contained in sectoral legislation. 

This  proposal  suspends  certain  provisions  of  two  Regulations  in  the  area  of  environment, 
waste  management.  Further  possible  modifications  of  those  Regulations  or  further 
suspensions  of  their  provisions  are  entirely  outside  of  the  scope  and  aims  of  the  present 
proposal. The need for such modifications may be assessed, as appropriate, in the context of 
further  stress-testing  of  EU  environmental 
the  [Chapeau 
Communication]  and  in  Commission  work  programme  2026.  The  Commission  will 
constructively engage with the co-legislators, in order to ensure that the legislative process on 
the present proposal fully preserves its essential object and does not distort it. 

legislation  announced 

in 

• 

Consistency with existing policy provisions in the policy area 

The current proposal promotes a similar approach across circular economy/waste legislation 
regarding the operation  of schemes for extended producer  responsibility. This  will facilitate 
the functioning of the internal market while aiding business operations. 

• 

Consistency with other Union policies 

This  proposal  is  part  of  a  package  of  measures  aimed  primarily  at  cutting  red  tape  for 
economic  operators.  It  is  entirely  consistent  with  the  Commission’s  policies  on  better 

8  Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of life 

vehicles; OJ L 269, 21.10.2000, p. 34. 

9  COM(2025)  500  final  of  21  May  2025,  The  Single  Market:  our  European  home  market  in  an  uncertain 

world - A Strategy for making the Single Market simple, seamless and strong. 

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regulation,  and  the  objectives  of  the  Competitiveness  compass  to  promote  greater 
competitiveness and economic resilience in the Union. The rationalisation introduced by these 
measures will not affect the achievement of the objectives in the concerned policy area nor the 
rationale of the legislative acts. 

2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

The  legal  base  of  the  proposal  is  192(1)  TFEU  in  relation  to  batteries  and  114  TFEU  in 
relation  to  packaging.  This  reflects  the  underlying  legal  base  of  the  Regulations  containing 
provisions on authorised representatives for extended producer responsibility that the proposal 
suspends.  

• 

Subsidiarity (for non-exclusive competence)  

The Batteries Regulation was adopted in recognition of the expected demand for batteries in 
the coming years, the strategic role of batteries in the global transition towards decarbonised 
economies  and  the  need  to establish a  functioning  internal  market  and  to  avoid  market 
distortions.  As  such  the  Batteries  Regulation  sets out  common  rules  on  the  sustainability, 
performance,  safety,  collection,  recycling  and  second  life  of  batteries  as  well  as  on 
information  about  batteries  for  end-users  and  economic  operators.  For  these  reasons, 
the suspension of provisions of the Regulation is similarly justified on subsidiarity grounds.  

Products  need  appropriate  packaging  to  be  protected  and  easy  to  transport  from  where  they 
are  produced  to  where  they  are  used  or  consumed.  Prevention  of  barriers  on  the  internal 
market  for  packaging  is  key  to  promote  the  efficient  functioning  of  the  internal  market  for 
products. Fragmented rules and vague requirements cause uncertainty and additional cost to 
economic  operators.  For  these  reasons,  the  suspension  of  provisions  of  the  Regulation  is 
similarly justified on subsidiarity grounds. 

• 

Proportionality 

In  the  case  of  the  circular  economy  legislation,  the  proposal  would  introduce  alternative 
means to deliver the policy objectives of ensuring that waste products, batteries or packaging 
are  appropriately  managed  at  the  end  of  their  useful  life.  These  respond  to  the  concerns  of 
producers operating across Member States. 

• 

Choice of the instrument 

A  proposal  for  Regulation  is  the  appropriate  choice  of  instrument  given  that  the  underlying 
legislation that the proposal suspends are Regulations. 

3. 

• 

RESULTS 
CONSULTATIONS AND IMPACT ASSESSMENTS 

EX-POST 

EVALUATIONS, 

OF 

STAKEHOLDER 

Ex-post evaluations/fitness checks of existing legislation 

Revisions of the Batteries Regulation and the Packaging Regulation were recently adopted by 
the Legislator based on Commission’s proposals that were supported by impact assessments.  
An evaluation  cannot  be carried out  at  this stage as too little time has  passed, and too  little 
practical experience was gained for a standard evaluation to be useful at this point in time. 

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• 

Stakeholder consultations 

The  staff  working  document  accompanying  this  proposal  provides  more  information  on  the 
various  consultation  activities  that  have  been  undertaken  to  support  the  preparation  of  this 
proposal. The key consultation activities are summarised below. 

The following consultation activities have been carried out to prepare this omnibus proposal: 

– 

– 

A call for evidence10 for the environmental omnibus open for feedback from 22 
July 2025 to 10 September 2025. 

A high-level roundtable on simplifying environmental laws on 2 October 2025. 

The  call  for  evidence  on  environmental  simplification  drew  a  lot  of  attention.  The 
Commission published a call for evidence on the environmental simplification package on the 
Have-Your-Say  website:  Simplification  of  administrative  burdens 
in  environmental 
legislation. The feedback period was from 22 July 2025 till 10 September 2025. All feedback 
is published on the Have-Your-Say website. 

There were 190 998 contributions to the call for evidence, of which 189  751 (99.3%) came 
from  citizens.  1  247  (0.7%)  contributions  came  from  organisations  other  than  citizens, 
including  businesses 
associations,  non-governmental  organisations 
(environmental and other), public authorities and academics. 622 attachments, mainly position 
papers, were attached to these submissions, which often included specific suggestions. 

and  business 

From  a  business  perspective,  there  is  support  for  less  burdensome  regulation  that  leaves 
business  with  flexibility  to  deliver  both  growth  and  sustainable  production.  There  is  a 
perception  of  administrative  obligations  that  are  too  prescriptive,  and  do  not  provide  value 
added. 

On the side of civil society, there is support for a simplification that makes it easier to protect 
the  environment  and  social  standards  and  avoid  deregulation,  for  example  by  removing 
redundancies  and  avoiding  excessively  detailed  regulations.  There  is  however  concern  that 
efforts to simplify regulations could undermine environmental protections. Citizens urged the 
EU to focus on enforcing existing laws rather than creating new simplifications. 

The Commission is currently preparing an impact assessment to support the preparation of the 
Circular  Economy  Act  in  2026.  This  assessment  will  utilise  ongoing  consultation  activities 
that will also cover simplification of existing (waste and circular economy-related) legislation, 
and particularly EPR related legislation. 

• 

Collection and use of expertise 

The Commission  contracted an external  service  provider to  provide  expertise related to  this 
proposal. In particular, the contractor has screened the known body of environmental laws to 
identify  reporting  and  other  administrative  obligations  together  with  potential  to  simplify 
these  obligations.  In  addition,  the  contractor  has  provided  assistance  in  quantifying  the 
reductions in  costs of possible measures to  simplify provisions in the omnibus package. All 
information provided by the contractor will be published. 

• 

Impact assessment 

An impact assessment has not been prepared primarily because the proposal is highly specific 
with little choice available to remedy the underlying issues. A staff working document does 

10 

Simplification of administrative burdens in environmental legislation 

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however  accompany  this  proposal.  It  justifies  the  content  of  the  proposal  and  presents 
quantitative information about the expected impacts. It also presents the views and inputs of 
stakeholders which the Commission has received. 

• 

Regulatory fitness and simplification 

Under the regulatory fitness and performance programme (REFIT), the Commission ensures 
that  its  legislation  is  fit  for  purpose,  targeted  to  the  needs  of  stakeholders,  and  minimises 
burdens while achieving its objectives. This proposal is therefore part of, and fully coherent 
with,  the  REFIT  programme  in  so  far  as  it  attempts  to  simplify  administrative  procedures 
related to the appointment of authorised representatives for extended producer responsibility 
and reduce unnecessary costs for producers.  

• 

Fundamental rights 

The proposal has no adverse impact on fundamental rights as enshrined in the EU Charter of 
Fundamental Rights as it solely impacts the appointment of an authorised representative for 
extended producer responsibility. 

4. 

BUDGETARY IMPLICATIONS 

Not applicable. 

5. 

• 

OTHER ELEMENTS 

Implementation plans and monitoring, evaluation and reporting arrangements 

Given the very specific nature of the proposal, there is no need for implementation plans to 
guide the application of the new provisions. Existing monitoring and reporting provisions in 
the affected Regulation will continue. 

• 

Explanatory documents (for directives) 

Not applicable. 

• 

Detailed explanation of the specific provisions of the proposal 

Article  1  suspends  the  application  of  Article  56(3) of  Regulation  (EU)  2023/1542  until 
January 2035. 

Article 2 suspends the application of Article 45(3) of Regulation (EU)2025/40 until January 
2035. 

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2025/0395 (COD) 

Proposal for a 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

suspending the application of the rules on the appointment of an authorised 
representative for extended producer responsibility for batteries and waste batteries and 
packaging and packaging waste 

(Text with EEA relevance) 

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION, 

Having  regard  to  the  Treaty  on  the  Functioning  of  the  European  Union,  and  in  particular 
Articles 192(1) and 114 thereof, 

Having regard to the proposal from the European Commission, 

After transmission of the draft legislative act to the national parliaments, 
Having regard to the opinion of the European Economic and Social Committee1,  
Having regard to the opinion of the Committee of the Regions2,  

Acting in accordance with the ordinary legislative procedure, 

Whereas: 

(1) 

(2) 

The  political  guidelines  for  the  Commission’s  2024-2029  term3  point  to  the  goal  of 
simplifying,  consolidating  and  codifying  legislation  to  eliminate  any  overlaps  and 
contradictions while maintaining high standards and staying the course on the goals set 
out in the European Green Deal. 

In  its  Communication  entitled  ‘A  simpler  and  faster  Europe:  Communication  on 
implementation and simplification’,4 the European Commission set out a vision for an 
implementation and simplification agenda that delivers fast and visible improvements 
for  people  and  business  on  the  ground.  That  requires  more  than  an  incremental 
approach  and  the  Union  is  to  take  bold  action  to  achieve  that  goal.  The  European 
Parliament, the Council, the Commission, the Member States’ authorities at all levels 
and stakeholders need to work together to streamline and simplify Union, national and 
regional rules and implement policies more effectively. 

1 
2 
3 

4 

OJ C , , p. . 
OJ C , , p. . 
Europe’s Choice, Political Guidelines for the next European Commission  2024−2029, Ursula von der 
Leyen. 
Communication from the Commission to the European Parliament, the Council, the European Economic and Social 
Committee and the Committee of the Regions of 11 February 2025, ‘A simpler and faster Europe: Communication 
on implementation and simplification’, COM/2025/47 final. 

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(3) 

(4) 

In its Communication on a Strategy for the Single Market5, the Commission identified 
as a barrier to the internal market that businesses face inconsistent national regulations 
which  make  it  harder  to  sell,  scale  or  move  goods  and  services  across  borders.  The 
Commission  committed  to  focus  on  the  ten  most  harmful  barriers  as  a  priority.  The 
Communication  identified  certain  features  of  extended  producer  responsibility 
schemes as one of the barriers most frequently reported by companies operating cross-
border in the Union. While extended producer responsibility schemes are derived from 
Union  legislation,  a  lack  of  uniformity  of  principles  and  requirements  has  led  to  a 
large diversity of extended producer responsibility schemes set up in Member States as 
well as to regulatory complexity and high administrative burden for companies. This 
Regulation  is  a  first  stepping  stone  to  more  profound  simplification  of  the  extended 
producer  responsibility  schemes  in  the  area  of  waste,  while  the  upcoming  Circular 
Economy act should provide for further simplification. 

the  obligation 

In  particular,  due  to  that  lack  of  harmonisation,  in  particular  regarding  the  current 
provisions  in  sectoral  legislation  for  the  appointment  of  an  authorised  representative 
for  extended  producer  responsibility,  the  fulfilment  of  the  obligations  related  to  the 
appointment  may  result  in  an  unnecessary  administrative  burden  on  producers 
operating  in  multiple  Member  States  where  they  are  not  established.  Particularly  for 
small  and  medium-sized  enterprises, 
to  appoint  authorised 
representatives separately in every Member State where the producer places products 
on the market poses a significant challenge in terms of costs. With a view to ensuring 
equal conditions for producers established in the Union, it is important that producers 
are  subject  to  the  same  rules  in  all  Member  States  for  appointing  an  authorised 
representative  for  extended  producer  responsibility.  The  currently  fragmented  legal 
framework  for  different  products  and  the  administrative  burden  associated  with 
fulfilling  the  requirement  to  appoint  an  authorised  representative  for  extended 
producer responsibility in up to 26 Member States is hampering the competitiveness of 
producers  established  in  the  Union.  It  is  thus  crucial  to  harmonise  the  existing  rules 
effectively and promptly, reducing the associated burdens on such producers. To this 
effect,  the  Commission  is  currently  reviewing  the  effectiveness,  the  administrative 
burden and the unintended barriers for the internal market, of the obligation to appoint 
authorised  representatives  as  a  safeguard  for  the  producers’  compliance  with  the 
‘polluter pays‘ principle. This review is likely to lead to alternative solutions which are 
more effective and less burdensome. 

(5)  With a view to simplifying requirements on producers, and reducing the administrative 
burden,  battery  producers  and  producers  of  packaging  or  packaged  products 
(‘packaging producers’) should be able to choose whether they appoint an authorised 
representative for extended producer responsibility when making available products on 
the  market  of  another  Member  State  where  they  are  not  established,  but  the 
appointment should not be mandatory. This allows those producers who have already 
appointed  an  authorised  representative  for  extended  producer  responsibility  to  retain 
their existing arrangements, while immediately alleviating the costs and administrative 
burden  for  producers  who  wish  to  not  appoint  an  authorised  representative  for 
extended producer responsibility. 

5 

Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic and Social Committee and the Committee of the Regions ‘The Single Market: our European 
home  market  in  an  uncertain  world  A  Strategy  for  making  the  Single  Market  simple,  seamless  and 
strong’, COM(2025) 500 final. 

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(6) 

(7) 

(8) 

(9) 

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7 

Ensuring traceability and enforcement with regard to battery producers and packaging 
producers  established  in  third  countries  is  more  challenging  compared  to  those 
operating  within  the  Union,  as  such  producers  fall  outside  the  territorial  scope  of 
Member States’ enforcement powers and are not covered by the Union administrative 
and  judicial  cooperation  mechanisms  that  enable  the  enforcement  of  obligations  and 
judgments  within the internal  market.  The existing provisions on the  appointment of 
an  authorised  representative  for  extended  producer  responsibility  for  producers 
established  in  third  countries  should  therefore  be  maintained  in  their  current  form. 
Thus, the provision in Regulation (EU) 2025/40 of the European Parliament and of the 
Council6 which sets out that Member States may provide that producers established in 
third  countries  are  to  appoint  an  authorised  representative  for  extended  producer 
responsibility  when  making  packaging  or  packaged  products  available  on  their 
territory for the first time should remain applicable. However, Member States should 
be allowed to ensure traceability and enforcement with regard to packaging producers 
established  in  third  countries  through  alternative  means.  Similarly,  the  provision 
in Regulation (EU) 2023/1542 of the European Parliament and of the Council7 which 
sets  out that  battery  producers  that  are  established  in  the  Union  or  in  third  countries 
and  that  are  making  available  batteries  within  the  territory  of  a  Member  State by 
means  of  distance 
representative 
should remain applicable  to  the  extent  that  it  covers producers  established  in  third 
countries.  However,  Member  States  should  be  required  to  ensure  traceability  and 
enforcement  with  regard  to  battery  producers  established  in  third  countries  through 
alternative means. 

contracts are 

authorised 

to appoint 

an 

representative 

The  provision in  Regulation  (EU)  2023/1542 that  makes  the appointment  of an 
authorised 
for 
extended 
producers established in the Union and selling batteries by means of distance contracts 
directly to end-users in another Member State mandatory should be suspended until 1 
January 2035.  

responsibility 

producer 

for 

The  provision  in  Regulation  (EU)  2025/40  that  makes  the  appointment  of  an 
authorised  representative  for  extended  producer  responsibility  for  producers 
established in the Union and making packaging or packaged products available for the 
first  time  on  the  territory  of  another  Member  State,  directly  to  end  users,  mandatory 
should be suspended until 1 January 2035.  

The Commission is preparing a legislative proposal for a comprehensive reform of the 
extended producer responsibility system. The proposal is expected to be tabled by the 
Commission,  in  accordance  with  its  Work  Programme,  in  2026.  The  legislative 
proposal  will  be  subject  to  the  ordinary  legislative  procedure  and,  if  adopted  by  the 
European  Parliament  and  by  the  Council,  the  Member  States  and  the  producers  will 
have  to  take  the  necessary  measures  to  align  their  regulatory  and  organisational 
measures with regard to the extended producer responsibility, as well as their conduct 
to the new rules.  

repealing 

Directive 

Regulation  (EU)  2025/40  of  the  European  Parliament  and  of  the  Council  of  19  December  2024  on 
packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, 
ELI: 
and 
http://data.europa.eu/eli/reg/2025/40/oj).  
Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning 
batteries  and  waste  batteries,  amending  Directive  2008/98/EC  and  Regulation  (EU)  2019/1020  and 
ELI: 
repealing 
http://data.europa.eu/eli/reg/2023/1542/oj). 

2006/66/EC 

28.7.2023, 

22.1.2025, 

94/62/EC 

Directive 

2025/40, 

191, 

(OJ 

OJ 

L, 

1, 

p. 

L 

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in  one  of 

(10)  Suspending  the  application  of  the  requirement  for  battery  producers  and  packaging 
to  appoint  authorised 
producers  established 
representatives  for  extended  producer  responsibility  when  making  batteries  or 
packaging  or  packaged  products  available  in  another  Member  State  serves  as  a 
preliminary  measure  to  immediately  alleviate  burdens  for  producers,  paving  the  way 
for  the  implementation  of  a  comprehensive  reform  of  the  extended  producer 
responsibility system. 

the  Member  States 

(11)  Since  the  objectives  of  this  Regulation,  namely  to  provide  flexibility  to  producers 
established  in  the  Union  as  to  whether  they  appoint  an  authorised  representative  for 
extended  producer  responsibility,  cannot  be  sufficiently  achieved  by  the  Member 
States  but  can  rather,  by  reason  of  the  scale  and  effects  of  the  action,  be  better 
achieved  at  Union  level,  the  Union  may  adopt  measures,  in  accordance  with  the 
principle  of  subsidiarity  as  set  out  in  Article  5  of  the  Treaty  on  European  Union.  In 
accordance  with  the  principle  of  proportionality  as  set  out  in  that  Article,  this 
Regulation does not go beyond what is necessary in order to achieve those objectives, 

HAVE ADOPTED THIS REGULATION: 

Suspension of Article 56(3) of Regulation (EU) 2023/1542 

Article 1 

The  application  of  Article  56(3) of  Regulation  (EU)  2023/1542  shall  be  suspended  until  1 
January 2035.  

As  regards  battery  producers  established  in  third  countries,  where  Member  States  do  not 
require the appointment of an authorised representative for extended producer responsibility, 
they shall ensure traceability and enforcement with regard to battery producers established in 
third countries through alternative means. 

Article 2 

Suspension of Article 45(3) of Regulation (EU) 2025/40 

The  application  of  Article  45(3)  of  Regulation  (EU)  2025/40  shall  be  suspended  until  1 
January 2035. 

Member States may either provide that producers established in third countries shall appoint, 
by  written  mandate,  an  authorised  representative  for  the  extended  producer  responsibility 
when making packaging or packaged products available on their territory for the first time or 
ensure  traceability  and  enforcement  with  regard  to  packaging  producers  established  in  third 
countries through alternative means. 

Article 3 

Entry into force 

This Regulation shall enter into force on the twentieth day following that of its publication in 
the Official Journal of the European Union. 

EN 

9 

  EN 

This Regulation shall be binding in its entirety and directly applicable in all Member States. 

Done at Brussels, 

For the European Parliament 
The President 

For the Council 
The President 

EN 

10 

  EN 

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT 

1. 

1.1. 

1.2. 

1.3. 

FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3 

Title of the proposal/initiative ...................................................................................... 3 

Policy area(s) concerned .............................................................................................. 3 

Objective(s) .................................................................................................................. 3 

1.3.1.  General objective(s) ..................................................................................................... 3 

1.3.2.  Specific objective(s) ..................................................................................................... 3 

1.3.3.  Expected result(s) and impact ...................................................................................... 3 

1.3.4. 

Indicators of performance ............................................................................................ 3 

1.4. 

1.5. 

The proposal/initiative relates to: ................................................................................. 4 

Grounds for the proposal/initiative .............................................................................. 4 

1.5.1.  Requirement(s) to be met in the short or long term including a detailed timeline for 

roll-out of the implementation of the initiative ............................................................ 4 

1.5.2.  Added value of EU involvement (it may result from different factors, e.g. 

coordination gains, legal certainty, greater effectiveness or complementarities). For 
the purposes of this section 'added value of EU involvement' is the value resulting 
from EU action, that is additional to the value that would have been otherwise 
created by Member States alone. ................................................................................. 4 

1.5.3.  Lessons learned from similar experiences in the past .................................................. 4 

1.5.4.  Compatibility with the multiannual financial framework and possible synergies with 
other appropriate instruments ....................................................................................... 5 

1.5.5.  Assessment of the different available financing options, including scope for 

redeployment ................................................................................................................ 5 

1.6. 

1.7. 

2. 

2.1. 

2.2. 

2.2.1. 

2.2.2. 

Duration of the proposal/initiative and of its financial impact .................................... 6 

Method(s) of budget implementation planned ............................................................. 6 

MANAGEMENT MEASURES................................................................................... 8 

Monitoring and reporting rules .................................................................................... 8 

Management and control system(s) ............................................................................. 8 

Justification of the budget implementation method(s), the funding implementation 
mechanism(s), the payment modalities and the control strategy proposed .................. 8 

Information concerning the risks identified and the internal control system(s) set up 
to mitigate them............................................................................................................ 8 

2.2.3.  Estimation and justification of the cost-effectiveness of the controls (ratio between 

the control costs  and the value of the related funds managed), and assessment of the 
expected levels of risk of error (at payment & at closure) ........................................... 8 

2.3. 

3. 

3.1. 

Measures to prevent fraud and irregularities ................................................................ 9 

ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 10 

Heading(s) of the multiannual financial framework and expenditure budget line(s) 
affected ....................................................................................................................... 10 

EN 

1 

  EN 

3.2. 

Estimated financial impact of the proposal on appropriations ................................... 12 

3.2.1.  Summary of estimated impact on operational appropriations.................................... 12 

3.2.1.1.  Appropriations from voted budget ............................................................................. 12 

3.2.1.2.  Appropriations from external assigned revenues ....................................................... 17 

3.2.2.  Estimated output funded from operational appropriations......................................... 22 

3.2.3.  Summary of estimated impact on administrative appropriations ............................... 24 

3.2.3.1. Appropriations from voted budget .............................................................................. 24 

3.2.3.2.  Appropriations from external assigned revenues ....................................................... 24 

3.2.3.3.  Total appropriations ................................................................................................... 24 

3.2.4.  Estimated requirements of human resources.............................................................. 25 

3.2.4.1.  Financed from voted budget....................................................................................... 25 

3.2.4.2.  Financed from external assigned revenues ................................................................ 26 

3.2.4.3.  Total requirements of human resources ..................................................................... 26 

3.2.5.  Overview of estimated impact on digital technology-related investments ................ 28 

3.2.6.  Compatibility with the current multiannual financial framework.............................. 28 

3.2.7.  Third-party contributions ........................................................................................... 28 

3.3. 

4. 

4.1. 

4.2. 

4.3. 

4.4. 

4.5. 

Estimated impact on revenue ..................................................................................... 29 

DIGITAL DIMENSIONS .......................................................................................... 29 

Requirements of digital relevance .............................................................................. 30 

Data ............................................................................................................................ 30 

Digital solutions ......................................................................................................... 31 

Interoperability assessment ........................................................................................ 31 

Measures to support digital implementation .............................................................. 32 

EN 

2 

  EN 

1. 

FRAMEWORK OF THE PROPOSAL/INITIATIVE  

1.1. 

Title of the proposal/initiative 

Proposal for a Regulation of the European Parliament and of the Council suspending 
the  application  of  the  rules  on  the  appointment  of  an  authorised  representative  for 
extended producer responsibility for batteries and waste batteries and packaging and 
packaging waste  

1.2. 

Policy area(s) concerned  

Environment  

European Green Deal  

1.3. 

Objective(s) 

1.3.1.  General objective(s) 

The general objective pursued by this legislative proposal is to simplify elements of 
Regulations (EU) 2023/1542 and (EU) 2025/40 with regard to the appointment of an 
authorised representative for extended producer responsibility. 

1.3.2. 

Specific objective(s) 

By suspending the application of the provisions in  Regulation (EU) 2023/1542  and 
(EU)  2025/40  that  mandate  the  appointment  of  an  authorised  representative  for 
extended  producer  responsibility  for  producers  established  in  the  Union,  packaging 
and  battery  producers  will  be  able  to  choose  whether  they  appoint  an  authorised 
representative for extended producer responsibility when making available products 
on  the  market  of  another  Member  State  where  they  are  not  established,  but  the 
appointment  will  not  be  mandatory.  This  allows  those  producers  who  have  already 
appointed an authorised representative for extended producer responsibility to retain 
their  existing  arrangements,  while 
the  costs  and 
administrative  burden  for  producers  who  wish  to  not  appoint  an  authorised 
representative for extended producer responsibility.  1.3.3. Expected 
and 
impact 

immediately  alleviating 

result(s) 

Specify the effects which the proposal/initiative should have on the beneficiaries/groups targeted.The 
proposed  suspension  of  the  application  of  the  mandatory  appointment  of  an 
authorised  representative  for  extended  producer  responsibility  for  producers 
established  in  the  Union  will  alleviate  administrative  burden  and  costs  from  the 
producers of packaging and batteries. Especially SMEs will benefit from not having 
to appoint an authorised representative. 

1.3.4. 

Indicators of performance 

Specify the indicators for monitoring progress and achievements. 

To  monitor  progress  towards  achieving  the  proposal’s  specific  objectives,  the 
Commission  will  explore  the  possibility  of  organising  exchanges  with  Member 
States in different formats, including by using the existing fora. 

1.4. 

The proposal/initiative relates to:  

 a new action  

EN 

3 

  EN 

 a new action following a pilot project / preparatory action18  

 the extension of an existing action  

 a merger or redirection of one or more actions towards another/a new action 

1.5. 

Grounds for the proposal/initiative  

1.5.1.  Requirement(s) to be met in the short or long term including a detailed timeline for 

roll-out of the implementation of the initiative 

The suspension should apply until 1 January 2035. 

1.5.2.  Added  value  of  EU  involvement  (it  may  result  from  different  factors,  e.g. 
coordination gains, legal certainty, greater effectiveness or complementarities). For 
the  purposes  of  this  section  'added  value  of  EU  involvement'  is  the  value  resulting 
from  EU  action,  that  is  additional  to  the  value  that  would  have  been  otherwise 
created by Member States alone. 

The proposal will create a harmonised approach across sectoral legislation. To ensure 
uniform  conditions  for  producers  within  the  Union,  it  is  essential  that  the  same 
provisions  are  applied  across  Member  States  for  appointing  an  authorised 
representative  for  extended  producer  responsibility.  The  existing  fragmented  legal 
framework  for  various  products  and  the  administrative  challenges  linked  with 
appointing an authorised representative in up to 26 Member States are hindering the 
competitiveness of Union-based producers. It is necessary to efficiently and swiftly 
harmonise the current rules, thereby alleviating the burdens faced by these producers. 

1.5.3.  Lessons learned from similar experiences in the past 

N/A 

1.5.4.  Compatibility with the multiannual financial framework and possible synergies with 

other appropriate instruments 

N/A 

1.5.5.  Assessment  of  the  different  available  financing  options,  including  scope  for 

redeployment 

N/A 

18 

As referred to in Article 58(2), point (a) or (b) of the Financial Regulation. 

EN 

4 

  EN 

 
1.6. 

Duration of the proposal/initiative and of its financial impact 

 limited duration  

–    in effect from date of application to 1 January 2035  

–    financial  impact  from  YYYY  to  YYYY  for  commitment  appropriations  and 

from YYYY to YYYY for payment appropriations.  

 unlimited duration 

–  Implementation with a start-up period from YYYY to YYYY, 

–  followed by full-scale operation. 

1.7.  Method(s) of budget implementation planned  

 Direct management by the Commission 

–   by its departments, including by its staff in the Union delegations;  

–    by the executive agencies  

 Shared management with the Member States  

 Indirect management by entrusting budget implementation tasks to: 

–   third countries or the bodies they have designated 

–   international organisations and their agencies (to be specified) 

–   the European Investment Bank and the European Investment Fund 

–   bodies referred to in Articles 70 and 71 of the Financial Regulation 

–   public law bodies 

–   bodies governed by private law with a public service mission to the extent that 

they are provided with adequate financial guarantees 

–   bodies governed by the private law of a Member State that are entrusted with 
the  implementation  of  a  public-private  partnership  and  that  are  provided  with 
adequate financial guarantees 

–   bodies or persons entrusted with the implementation of specific actions in the 
common  foreign  and  security  policy  pursuant  to  Title  V  of  the  Treaty  on 
European Union, and identified in the relevant basic act 

–  bodies  established  in  a  Member  State,  governed  by  the  private  law  of  a 
Member  State  or  Union  law  and  eligible  to  be  entrusted,  in  accordance  with 
sector-specific  rules,  with  the  implementation  of  Union  funds  or  budgetary 
guarantees,  to  the extent that such bodies are controlled by public law bodies or 
by bodies governed by private law with a public service mission, and are provided 
with adequate financial guarantees in the form of joint and several liability by the 
controlling bodies or equivalent financial guarantees and which may be, for each 
action, limited to the maximum amount of the Union support. 

Comments  

N/A 

EN 

5 

  EN 

2. 

MANAGEMENT MEASURES  

2.1.  Monitoring and reporting rules  

N/A 

2.2.  Management and control system(s)  

2.2.1. 

Justification  of  the  budget  implementation  method(s),  the  funding  implementation 
mechanism(s), the payment modalities and the control strategy proposed 

N/A 

2.2.2. 

Information concerning the risks identified and the internal control system(s) set up 
to mitigate them 

N/A 

2.2.3.  Estimation  and  justification  of  the  cost-effectiveness  of  the  controls  (ratio  between 
the control costs  and the value of the related funds managed), and assessment of the 
expected levels of risk of error (at payment & at closure)  

N/A 

2.3.  Measures to prevent fraud and irregularities  

N/A 

EN 

6 

  EN 

3. 

3.1. 

ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE  

Heading(s)  of  the  multiannual  financial  framework  and  expenditure  budget 
line(s) affected  

•  Existing budget lines  

In order of multiannual financial framework headings and budget lines. 

Budget line 

Type of 
expenditure 

Contribution  

Heading of 
multiannual 
financial 
framework 

Number  

N/A 

Diff./Non-
diff.19 

from 
EFTA 
countries
20 

from 
candidate 
countries 
and 
potential 
candidates
21 

From 
other 
third 
countries 

other assigned 
revenue 

Diff./Non
-diff. 

YES/NO  YES/NO  YES/NO 

YES/NO 

•  New budget lines requested  

In order of multiannual financial framework headings and budget lines. 

Heading of 
multiannual 
financial 
framework 

Number  

N/A 

Budget line 

Type of 
expenditure 

Diff./Non-
diff. 

from 
EFTA 
countries 

Contribution  

from 
candidate 
countries 
and 
potential 
candidates 

from 
other 
third 
countries 

other assigned 
revenue  

Diff./Non
-diff. 

YES/NO  YES/NO  YES/NO 

YES/NO 

19 
20 
21 

Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 
EFTA: European Free Trade Association.  
Candidate countries and, where applicable, potential candidates from the Western Balkans. 

EN 

7 

  EN 

 
 
 
 
 
 
 
3.2. 

Estimated financial impact of the proposal on appropriations  

3.2.1. 

Summary of estimated impact on operational appropriations  

–   The proposal/initiative does not require the use of operational appropriations  

–    The proposal/initiative requires the use of operational appropriations, as explained below 

3.2.1.1.  Appropriations from voted budget 

Heading of multiannual financial framework  

Number 

EUR million (to three decimal places) 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  

Budget line 

Budget line 

Commitments 

Payments 

Commitments 

Payments 

(1a) 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes  
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b+3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  

Budget line 

Budget line 

Commitments 

Payments 

Commitments 

(1a) 

(2a) 

(1b) 

EN 

8 

0.000 

0.000 

0.000 

EN 

 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Appropriations of an administrative nature financed from the envelope of specific programmes  
Budget line 

(3) 

Payments 

(2b) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b+3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

operational 

appropriations  

Commitments 

Payments 

TOTAL  appropriations  of  an  administrative  nature  financed 
from the envelope for specific programmes  

TOTAL appropriations under 
HEADING <….> 

Commitments 

of the multiannual financial framework 

Payments 

(4) 

(5) 

(6) 

=4+6 

=5+6 

Heading of multiannual financial  
framework  

Number 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  

Budget line 

Budget line 

Commitments 

Payments 

Commitments 

(1a) 

(2a) 

(1b) 

EN 

9 

0.000 

0.000 

0.000 

EN 

 
 
  
  
  
  
  
  
  
  
  
  
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Appropriations of an administrative nature financed from the envelope of specific programmes  
Budget line 

(3) 

Payments 

(2b) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b +3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  

Budget line 

Budget line 

Commitments 

Payments 

Commitments 

Payments 

(1a) 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes  
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b +3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

operational 

appropriations  

Commitments 

Payments 

TOTAL  appropriations  of  an  administrative  nature  financed 
from the envelope for specific programmes  

(4) 

(5) 

(6) 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

EN 

10 

EN 

 
 
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
 
TOTAL appropriations under 
HEADING <….> 

Commitments 

of the multiannual financial framework 

Payments 

=4+6 

=5+6 

•  TOTAL  operational  appropriations 
operational headings) 

(all 

Commitments 

Payments 

•  TOTAL  appropriations  of  an  administrative  nature  financed 
from  the  envelope  for  specific  programmes  (all  operational 
headings) 

TOTAL appropriations Under          

Heading 1 to 6 

Commitments 

of the multiannual financial framework 
(Reference amount) 

Payments 

(4) 

(5) 

(6) 

=4+6 

=5+6 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

2024 

Year 

2025 

0.000 

Year 

2026 

0.000 

Year 

2027 

0.000 

0.000 

TOTAL MFF 
2021-2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Heading of multiannual financial  framework  

7 

‘Administrative expenditure’  

DG: <…….> 

Appropriations  

DG: <…….> 

 Human resources  
 Other administrative expenditure  
TOTAL DG <…….> 

 Human resources  
 Other administrative expenditure  

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL 
MFF 2021-
2027 

0.000 

0.000 

0.000 

TOTAL 
MFF 2021-
2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

EN 

11 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TOTAL DG <…….> 

Appropriations  

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL appropriations under HEADING 7 of the multiannual financial 
framework  

(Total 
commitments 
= Total 
payments) 

0.000 

0.000 

0.000 

0.000 

0.000 

EUR million (to three decimal places) 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

TOTAL appropriations under HEADINGS 1 to 7 

Commitments 

0.000 

0.000 

0.000 

0.000 

of the multiannual financial framework  

Payments 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

3.2.1.2.  Appropriations from external assigned revenues 

Heading of multiannual financial framework  

Number 

EUR million (to three decimal places) 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  

Budget line 

Budget line 

Commitments 

Payments 

Commitments 

Payments 

(1a) 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes  
Budget line 

(3) 

TOTAL appropriations 

Commitments 

=1a+1b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

EN 

12 

EN 

 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
for DG <…….> 

Payments 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  

Budget line 

Budget line 

Commitments 

Payments 

Commitments 

Payments 

(1a) 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes  
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b+3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

operational 

appropriations  

Commitments 

Payments 

TOTAL  appropriations  of  an  administrative  nature  financed 
from the envelope for specific programmes  

TOTAL appropriations under 
HEADING <….> 

Commitments 

of the multiannual financial framework 

Payments 

Heading of multiannual financial framework  

Number 

(4) 

(5) 

(6) 

=4+6 

=5+6 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

Year 

Year 

Year 

Year 

TOTAL MFF 

EN 

13 

EN 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
2024 

2025 

2026 

2027 

2021-2027 

Operational appropriations  

Budget line 

Budget line 

Commitments 

Payments 

Commitments 

Payments 

(1a) 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes  
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b+3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

DG: <…….> 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

Operational appropriations  

Budget line 

Budget line 

Commitments 

Payments 

Commitments 

Payments 

(1a) 

(2a) 

(1b) 

(2b) 

Appropriations of an administrative nature financed from the envelope of specific programmes  
Budget line 

(3) 

TOTAL appropriations 
for DG <…….> 

Commitments 

Payments 

=1a+1b+3 

=2a+2b+3 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

operational 

appropriations  

Commitments 

Payments 

(4) 

(5) 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

EN 

14 

EN 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
TOTAL  appropriations  of  an  administrative  nature  financed 
from the envelope for specific programmes  

TOTAL appropriations under 
HEADING <….> 

Commitments 

of the multiannual financial framework 

Payments 

(6) 

=4+6 

=5+6 

•  TOTAL  operational  appropriations 
operational headings) 

(all 

Commitments 

Payments 

•  TOTAL  appropriations  of  an  administrative  nature  financed 
from  the  envelope  for  specific  programmes  (all  operational 
headings) 

TOTAL appropriations under Headings 1 
to 6 

Commitments 

of the multiannual financial framework (Reference 
amount) 

Payments 

(4) 

(5) 

(6) 

=4+6 

=5+6 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Heading of multiannual financial framework  

7 

‘Administrative expenditure’  

DG: <…….> 

 Human resources  
 Other administrative expenditure  

TOTAL DG <…….> 

Appropriations  

EUR million (to three decimal places) 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 
MFF 2021-
2027 

0.000 

0.000 

0.000 

EN 

15 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DG: <…….> 

 Human resources  
 Other administrative expenditure  

TOTAL DG <…….> 

Appropriations  

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 
MFF 2021-
2027 

0.000 

0.000 

0.000 

TOTAL appropriations under HEADING 7 of the multiannual 
financial framework  

(Total 
commitments 
= Total 
payments) 

0.000 

0.000 

0.000 

0.000 

0.000 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL MFF 
2021-2027 

EUR million (to three decimal places) 

TOTAL appropriations under HEADINGS 1 to 7 

Commitments 

0.000 

0.000 

0.000 

0.000 

0.000 

of the multiannual financial framework  

Payments 

0.000 

0.000 

0.000 

0.000 

0.000 

3.2.2.  Estimated output funded from operational appropriations (not to be completed for decentralised agencies) 

Indicate 
objectives and 
outputs  

 

Type22 

Avera
ge 
cost 

Year  
2024 

Year  
2025 

Year  
2026 

Year  
2027 

OUTPUTS 

Commitment appropriations in EUR million (to three decimal places) 

Enter as many years as necessary to show the 
duration of the impact (see Section1.6) 

TOTAL 

o
N

Cost 

o
N

Cost 

o
N

Cost 

o
N

Cost 

o
N

Cost  N

o

Cost 

o
N

Cost 

Total 
No 

Total 
cost 

22 

Outputs are products and services to be supplied (e.g. number of student exchanges financed, number of km of roads built, etc.). 

EN 

16 

EN 

 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
SPECIFIC OBJECTIVE No 123… 

- Output 

- Output 

- Output 

Subtotal for specific objective No 1 

SPECIFIC OBJECTIVE No 2 ... 

- Output 

Subtotal for specific objective No 2 

TOTALS 

23 

As described in Section 1.3.2. ‘Specific objective(s)’  

EN 

17 

EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.2.3. 

Summary of estimated impact on administrative appropriations  

–   The  proposal/initiative  does  not  require  the  use  of  appropriations  of  an 

administrative nature  

–    The proposal/initiative requires the use of appropriations of an administrative 

nature, as explained below 

3.2.3.1. Appropriations from voted budget 

VOTED APPROPRIATIONS 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL 
2021 - 2027 

HEADING 7 

Human resources  

Other administrative expenditure  

Subtotal HEADING 7 

Outside HEADING 7 

Human resources  

Other expenditure of an administrative nature 

Subtotal outside HEADING 7 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

0.000 

0.000 

0.000 

0.000 

0.000 

3.2.3.2.  Appropriations from external assigned revenues 

EXTERNAL ASSIGNED REVENUES 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

TOTAL 
2021 - 2027 

HEADING 7 

Human resources  

Other administrative expenditure  

Subtotal HEADING 7 

Outside HEADING 7 

Human resources  

Other expenditure of an administrative nature 

Subtotal outside HEADING 7 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

0.000 

0.000 

0.000 

0.000 

0.000 

VOTED APPROPRIATIONS                            

+                                                               

Year 

2024 

Year 

Year 

Year 

2025 

2026 

2027 

TOTAL 
2021 - 
2027 

3.2.3.3.  Total appropriations 

TOTAL 

EXTERNAL ASSIGNED REVENUES 

HEADING 7 

Human resources  

Other administrative expenditure  

Subtotal HEADING 7 

Outside HEADING 7 

Human resources  

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

EN 

18 

  EN 

 
  
  
Other expenditure of an administrative nature 

Subtotal outside HEADING 7 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

0.000 

0.000 

0.000 

0.000 

0.000 

The  appropriations  required  for  human  resources  and  other  expenditure  of  an  administrative  nature 
will  be  met  by  appropriations  from  the  DG  that  are  already  assigned  to  management  of  the  action 
and/or  have  been  redeployed  within  the  DG,  together,  if  necessary,  with  any  additional  allocation 
which may be granted to the managing DG under the annual allocation procedure and in the light of 
budgetary constraints. 

3.2.4.  Estimated requirements of human resources  

–   The proposal/initiative does not require the use of human resources  

–    The  proposal/initiative  requires  the  use  of  human  resources,  as  explained 

below 

3.2.4.1.  Financed from voted budget 

Estimate to be expressed in full-time equivalent units (FTEs) 

VOTED APPROPRIATIONS 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

 Establishment plan posts (officials and temporary staff) 

20 01 02 01 (Headquarters and Commission’s Representation Offices) 

20 01 02 03 (EU Delegations) 

01 01 01 01 (Indirect research) 

01 01 01 11 (Direct research) 

Other budget lines (specify) 

• External staff (inFTEs) 

20 02 01 (AC, END from the ‘global envelope’) 

20 02 03 (AC, AL, END and JPD in the EU Delegations) 

Admin. Support 
line 
[XX.01.YY.YY] 

- at Headquarters 

- in EU Delegations  

01 01 01 02 (AC, END - Indirect research) 

 01 01 01 12 (AC, END - Direct research) 

Other budget lines (specify) - Heading 7 

Other budget lines (specify) - Outside Heading 7 

TOTAL 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

3.2.4.2.  Financed from external assigned revenues 

EXTERNAL ASSIGNED REVENUES 

 Establishment plan posts (officials and temporary staff) 

20 01 02 01 (Headquarters and Commission’s Representation Offices) 

20 01 02 03 (EU Delegations) 

01 01 01 01 (Indirect research) 

01 01 01 11 (Direct research) 

Year 

2024 

Year 

2025 

Year 

2026 

Year 

2027 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

EN 

19 

  EN 

 
  
 
Other budget lines (specify) 

• External staff (in full time equivalent units) 

20 02 01 (AC, END from the ‘global envelope’) 

20 02 03 (AC, AL, END and JPD in the EU Delegations) 

Admin. Support 
line  
[XX.01.YY.YY] 

- at Headquarters 

- in EU Delegations  

01 01 01 02 (AC, END - Indirect research) 

 01 01 01 12 (AC, END - Direct research) 

Other budget lines (specify) - Heading 7 

Other budget lines (specify) - Outside Heading 7 

TOTAL 

3.2.4.3.  Total requirements of human resources 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

TOTAL VOTED APPROPRIATIONS                                                   

Year 
+                                                                                               
2025 

2024 

Year 

EXTERNAL ASSIGNED REVENUES 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

Year 

Year 

2026 

2027 

 Establishment plan posts (officials and temporary staff) 

20 01 02 01 (Headquarters and Commission’s Representation Offices) 

20 01 02 03 (EU Delegations) 

01 01 01 01 (Indirect research) 

01 01 01 11 (Direct research) 

Other budget lines (specify) 

• External staff (in full time equivalent units) 

20 02 01 (AC, END from the ‘global envelope’) 

20 02 03 (AC, AL, END and JPD in the EU Delegations) 

Admin. Support 
line  
[XX.01.YY.YY] 

- at Headquarters 

- in EU Delegations  

01 01 01 02 (AC, END - Indirect research) 

 01 01 01 12 (AC, END - Direct research) 

Other budget lines (specify) - Heading 7 

Other budget lines (specify) - Outside Heading 7 

TOTAL 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

The staff required to implement the proposal (in FTEs): N/A  

To be covered by 
current staff 
available in the 
Commission 
services  

Exceptional additional staff* 

To be financed 
under Heading 7 
or Research 

To be financed 
from BA line 

To be financed 
from fees 

Establishment 
plan posts 

EN 

N/A 

20 

  EN 

 
 
 
 
 
 
 
External 
staff 
(CA, SNEs, INT) 

Description of tasks to be carried out by: 

Officials and temporary staff 

External staff 

3.2.5.  Overview of estimated impact on digital technology-related investments 

Compulsory: the best estimate of the digital technology-related investments entailed 
by the proposal/initiative should be included in the table below.  

Exceptionally,  when  required  for  the  implementation  of  the  proposal/initiative,  the 
appropriations under Heading 7 should be presented in the designated line.  

The appropriations under Headings 1-6 should be reflected as “Policy IT expenditure 
on operational programmes”. This expenditure refers to the operational budget to be 
used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation 
of the initiative and their associated investments (e.g. licences, studies, data storage 
etc).  The  information  provided  in  this  table  should  be  consistent  with  details 
presented under Section 4 “Digital dimensions”. 

TOTAL Digital and IT appropriations 

Year 

Year 

Year 

Year 

2024 

2025 

2026 

2027 

TOTAL 
MFF 
2021 - 
2027 

HEADING 7 

IT expenditure (corporate)  

Subtotal HEADING 7 

Outside HEADING 7 

Policy IT expenditure on operational 
programmes 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

Subtotal outside HEADING 7 

0.000 

0.000 

0.000 

0.000 

0.000 

TOTAL 

0.000 

0.000 

0.000 

0.000 

0.000 

3.2.6.  Compatibility with the current multiannual financial framework  

The proposal/initiative: 

–    can be fully financed through redeployment within the relevant heading of the 

multiannual financial framework (MFF) 

–    requires use of the unallocated margin under the relevant heading of the MFF 

and/or use of the special instruments as defined in the MFF Regulation 

–    requires a revision of the MFF 

3.2.7.  Third-party contributions  

The proposal/initiative: 

–    does not provide for co-financing by third parties 

–    provides for the co-financing by third parties estimated below: 

EN 

21 

  EN 

 
 
 
 
 
 
 
  
Appropriations in EUR million (to three decimal places) 

Year  
2024 

Year  
2025 

Year  
2026 

Year  
2027 

Total 

Specify the co-financing body  

TOTAL appropriations co-
financed  

3.3. 

Estimated impact on revenue  

–   The proposal/initiative has no financial impact on revenue. 

–    The proposal/initiative has the following financial impact: 

– 

– 

– 

Budget revenue line: 

Article …………. 

 

 

on own resources  

on other revenue 

  please indicate, if the revenue is assigned to expenditure lines 

Appropriations 
available for the 
current financial 
year 

     EUR million (to three decimal places) 

Impact of the proposal/initiative24 

Year 2024 

Year 2025  Year 2026 

Year 2027 

For assigned revenue, specify the budget expenditure line(s) affected. 

Other  remarks  (e.g.  method/formula  used  for  calculating  the  impact  on  revenue  or 
any other information). 

N/A 

4. 

DIGITAL DIMENSIONS 

4.1. 

Requirements of digital relevance 

[Requirement 1 (R1): …] 

[Requirement 2 (R2): …] 

Please insert as many requirement lines as needed and identify each requirement distinctly 
(like R1, R2, etc.) to ease cross-referencing in the following sections. 

4.2. 

Data 

24 

As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net 
amounts, i.e. gross amounts after deduction of 20% for collection costs. 

EN 

22 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4.3. 

Digital solutions 

4.4. 

Interoperability assessment 

4.5.  Measures to support digital implementation 

EN 

23 

  EN