The Environmental Omnibus and PPWR: What It Means for Businesses Selling into Romania

The expression “Environmental Omnibus” is increasingly used in discussions about packaging compliance, extended producer responsibility (EPR) and cross-border sales. It is important not to treat it as a new, automatic exemption.

The Environmental Omnibus is a package of European Commission proposals intended to simplify selected environmental rules. For packaging, one relevant document is COM(2025) 982 final, a proposal concerning the appointment of authorised representatives for EPR obligations under the Packaging and Packaging Waste Regulation (PPWR).

For a business established in another EU country and selling packaged products into Romania, the practical question is simple: does this proposal change what we must do today? A proposal does not itself change the law. Current EU and Romanian requirements remain the starting point while the legislative process continues.

What is the Environmental Omnibus?

An omnibus package groups proposals that address several related EU rules. In December 2025, the European Commission presented its Environmental Omnibus package, including proposals on environmental reporting, industrial-emissions requirements, assessments and certain EPR arrangements.

It is not one regulation that has already replaced all existing environmental obligations. Each proposal follows its own legislative route through the European Parliament and the Council. A company should distinguish between:

a Commission proposal;
an adopted EU legal act;
national legislation that continues to apply; and
guidance that helps interpret an existing rule.

This distinction matters especially for PPWR because the regulation itself generally applies from 12 August 2026, while several technical and registration-related elements are phased or subject to later EU measures.

The proposal relevant to packaging EPR

In its original proposal, COM(2025) 982 final would suspend the application of Article 45(3) of PPWR until 1 January 2035. That article concerns, among other cases, producers established in one Member State who first make packaging or packaged products available directly to end users in another Member State. The proposal also addresses batteries, and distinguishes producers established outside the EU.

The proposed measure is narrow. It does not create a general EPR exemption for every company selling across borders, and it does not remove all national requirements relating to packaging, registration, evidence or reporting.

As of 18 October 2026, procedure 2025/0395/COD is awaiting the European Parliament’s position at first reading. Its environment committee voted on the file and a report was tabled, but the final scope and dates are not settled. Follow the European Parliament procedure file for subsequent developments.

A business should not reorganise its Romanian compliance route solely because a proposal or committee position exists.

What still applies in Romania?

Romanian packaging and waste responsibilities need to be assessed under the applicable national framework, including Law no. 249/2015 on packaging and packaging waste and the EPR framework in Government Emergency Ordinance no. 92/2021 on the waste regime, as amended, together with directly applicable EU law.

Article 12(12) of OUG no. 92/2021 provides that product producers established in another Member State or a third country that introduce products in Romania must appoint a legal entity established in Romania as an authorised representative for their producer and EPR obligations. Whether and how that provision and PPWR Article 45(3) apply in a particular supply chain depends on the product, packaging, route to market and the company’s legal role.

The existence of the Omnibus proposal does not, by itself, disapply Romanian or EU legislation. If an EU act is adopted, its final text, date of application and interaction with national requirements will need to be assessed.

PPWR itself has not been paused

The PPWR, Regulation (EU) 2025/40, generally applies across the EU from 12 August 2026. It creates a harmonised framework for packaging over its life cycle, but it does not turn packaging compliance into one single EU filing.

National EPR systems, national registers and national reporting arrangements remain relevant while harmonised EU registration and reporting measures are developed. The European Commission has made the same point in its guidance for businesses: cross-border operators should check the rules in each Member State in which they sell.

For Romania, this means a company should separately assess:

whether it is the relevant producer for the packaging or packaged products it places on the Romanian market;
what packaging data and supporting evidence it must keep;
which registration, reporting or contractual arrangements apply;
whether an authorised representative is currently required; and
which PPWR requirements are applicable now, and which are relevant to future packaging design or procurement.

For more background, read our guide to PPWR in Romania and our packaging data file checklist.

A practical approach while the Omnibus proposal is pending

1. Keep the current compliance route in place

Do not terminate an existing Romanian EPR, reporting or representative arrangement merely because a simplification proposal has been announced. First verify the current legal position for the company’s exact route to market.

2. Map the actual commercial role

The answer can differ between a manufacturer, brand owner, importer, distributor, marketplace seller and a business selling directly to Romanian end users. The contract chain and the point at which goods are first placed on the Romanian market matter.

3. Maintain a packaging evidence file

Keep a clear record of packaging materials, weights, packaging levels, suppliers, invoices, contractual roles and any data used for EPR or PPWR assessment. A well-organised file is useful regardless of future Omnibus changes.

4. Treat proposed simplification as a monitoring point

Add procedure 2025/0395/COD to your regulatory watchlist. The relevant question is not only whether the proposal is adopted, but also its final wording, application date and interaction with Romanian requirements.

5. Build flexibility into contracts

Where a business appoints a Romanian representative or engages an EPR compliance provider, contract terms should define the scope of service, data responsibilities, reporting support, fees, change-control process and what happens if the law changes.

What the proposal does not mean

The Environmental Omnibus should not be used as a shortcut for compliance claims. It does not currently mean that:

all EU sellers are exempt from Romanian packaging responsibilities;
an online marketplace automatically assumes the seller’s EPR duties;
a business can stop maintaining packaging data or evidence;
PPWR is postponed; or
a future simplification removes the need for a country-by-country analysis today.

How we can help

We help businesses organise a practical Romania entry file: packaging mapping, document collection, role analysis, supplier data questions and a checklist for Romania-specific EPR and PPWR questions. Where a matter requires a formal legal interpretation, it should be confirmed with an appropriately qualified legal adviser.

Learn about EPR & PPWR compliance support in Romania

This article is general information, not legal, tax or regulatory advice for a particular business. The status of legislative proposals should always be reconfirmed before a compliance decision is made.