Implementing rules on registering in and reporting to the register of producers

We sincerely thank the European Commission for the opportunity to provide feedback on the implementation of the PPWR. In the attached document, we outline our concerns regarding the disproportionate administrative and financial burden placed on small European manufacturers, the resulting barriers within the Single Market, and the urgent need for a more harmonised and proportionate approach.

FINAT welcomes the objective of establishing a harmonised and material-specific reporting format. The current wording of Recital (8) and Article 2(3) may be interpreted as requiring reporting of all constituent elements of packaging, irrespective of their significance for the material-specific reporting categories of Annex II.

EPAL welcomes the harmonization of registration and reporting under Article 44 of the Packaging and Packaging Waste Regulation, but calls for a single EU-wide producer register based on the once-only principle instead of 27 national systems. Until such a EU-wide producer register is available, the registration and reporting requirements should not be binding.

I am an artist based and registered in Ireland running a micro-business with just two employees (myself and my partner), focused on sharing their art online, but also with occasional physical sales both in person and through our online platform.

The German Chemical Distribution Association (Verband Chemiehandel e.V.-VCH) would like to express its gratitude for the opportunity to submit a statement on the regulations concerning national producer registers with regard to Article 44 of the Packaging and Packaging Waste Regulation (PPWR) on behalf of the chemical trade sector.

I support packaging waste reduction, circular economy and extended producer responsibility (EPR). However, these objectives do not justify the need for a micro-enterprise sending a few parcels to increase the number of formalities, memberships and authorised representatives abroad.

Filed in French · English published by the European Commission

The objectives of the European Packaging Regulation of preventing packaging, improving recyclability and making the circular economy work are in principle to be welcomed. However, the specific nature of the obligations imposes a disproportionate administrative and cost burden on small manufacturers who distribute their products in several EU Member States.

Filed in German · English published by the European Commission

AS ČR represents antique traders, private galleries, antiquariates, art auction halls and private collectors, experts and restaurateurs. The vast majority of AS CR members are micro-enterprises with one or more employees.

Filed in Czech · English published by the European Commission

Dear Sir/Madam, please find attached a brief overview of our experience with the implementation of the PPWR: (see file) When implementing the PPWR, we have seen from the outset that the information on the implementation of the PPWR is very difficult to access for companies and very bureaucratic.

Filed in German · English published by the European Commission

Sonae welcomes the Commissions proposal to harmonise the registration and reporting formats for national producer registers under the PPWR, in particular the provisions aimed at enabling automated data processing and bulk verification of producer registration numbers and digital certificates.

I have a small online business selling Videogames and Anime/Manga Merchandise. Since Corona there were constantly hurdles to overcome, hard decisions to be made made and to reinvent "doing business" again and again. Lake many other small businesses i managed to adapt, to cut costs wherever possible and to stay afloat - somehow. With PPWR taking into effect i lose a significant amount of my income.

1. The Thessaloniki Chamber of Professionals (Επαγγελματικό Επιμελητήριο Θεσσαλονίκης) is a self-governed public body representing more than 60,000 businesses in Thessaloniki, Greece. Our members work in services, retail and wholesale trade, and small-scale manufacturing. Most are micro and small businesses, and many are sole traders. Our Chamber has represented this business community for more than a hundred years.

As the owner of a small online business selling football shirts, scarves and memorabilia to collectors across the EU and beyond, I have no objection to sensible environmental rules. What I cannot accept is a system that makes legitimate cross-border trade economically impossible for micro-businesses.

We support the European Commission’s objective to harmonise EPR registration and reporting through the implementing act referred to in Article 44(14) of Regulation (EU) 2025/40. However, the draft falls short of European standardisation. National registers, different reporting channels, additional requirements and the obligation to appoint authorised representatives remain largely in place.

Filed in German · English published by the European Commission

Estonian PRO supports the objectives of the PPWR but considers that its implementation should be more proportionate, harmonised and practical for businesses. Estonia PRO proposes the following improvements: Establish alternative mechanisms for cross-border EPR compliance, including a PRO-to-PRO mechanism or an EU-wide one-stop-shop, to avoid unnecessary country-by-country administrative requirements.

DHL Group Call for Evidence Submission: Packaging and Packaging Waste – Rules on National Registers of Producers DHL Group welcomes the opportunity to contribute to the Call for Evidence exercise on the draft implementing regulation aiming to harmonise rules on national registers of producers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Semiconductor Industry Association (ESIA), representing the European leadership in semiconductor research, design, and manufacturing, would like to make recommendations regarding the finalisation of the implementing act laying out the format. Semiconductors (or chips) are at the core of Europes clean and digital transitions.

European Commission Have your say Public consultation Stockholm 2026-09-10 Ref Regulation (EU) 2025/40 Consultation on Packaging and Packaging Waste – rules on national registers of producers The European Commission has published a draft Implementing Regulation laying down rules for the application of Regulation (EU) 2025/40 as regards the format for registration in and reporting to national registers of producers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Polish Confederation Lewiatan is a national business federation representing more than 4,100 companies employing over 1.5 million people. We support the Packaging and Packaging Waste Regulation (PPWR) as an important instrument for accelerating the transition towards a circular economy, harmonising packaging requirements and strengthening the EU Single Market.

On behalf of Moda Sostenible Barcelona, an association representing brands and micro-enterprises in the textile and fashion sector committed to sustainability, we support the objective of this initiative to harmonise national producer registers.

Unclear treatment of paper/non-woven/cotton carrier bags with or without printing, in this case ‘Customer Logo’ (individual printing for companies as promotional items). Who takes on what role for the notification/fees. Very contradictory information or statements. For example: Individual production of laminated non-woven XXL bags for customers. As a distributor, we obtain these via a German importer.

Filed in German · English published by the European Commission

As a small independent maker this new legislation has forced me out of the single market. The cost and administrative burden prohibits me from shipping any of my work outside of my own EU country now. The EU Think Small First policy has utterly failed me, and all the small business owners I know.

We fundamentally support the PPWR’s objectives to reduce packaging waste. However, for small and medium-sized enterprises, implementation requires considerable organisational and financial effort. Our company delivered products in 10 EU Member States in 2025. The lack of uniform European implementation means that national registration, reporting and proof obligations must be fulfilled separately.

Filed in German · English published by the European Commission

Je soutiens la réduction des déchets demballages, léconomie circulaire et la responsabilité élargie des producteurs (REP). Mais ces objectifs ne justifient pas quune microentreprise expédiant quelques colis doive multiplier les formalités, adhésions et représentants autorisés à létranger. Il faut distinguer la conformité environnementale des emballages, de lorganisation administrative et financière de la REP.

The Polish Union of the Cosmetics Industry welcomes the Commissions efforts to harmonise producer registration and EPR reporting under the PPWR. At the same time, the draft raises a number of practical concerns regarding the proportionality, usability and administrative impact of the proposed reporting framework, especially for companies operating in several Member States and using complex distribution, logistics…

Perstorp welcomes the opportunity to give input to this implementing legislation for the Packaging and Packaging Waste Regulation. We support the environmental aims of the PPWR and the principle of Extended Producer Responsibility (EPR). However, there are a couple of suggested solutions that we believe should be reviewed.

I am a micro-business and independent artisan based in Portugal, selling my own handmade products online. Requiring a business of my size to register and comply with separate EPR systems in every EU country where I make even one or two sales (or zero) creates a completely disproportionate administrative and financial burden. It will make cross-border sales within the EU simply unviable for me.

We are a network of toy manufacturers and recognise our responsibility as micro-enterprises. A functioning circular economy is essential for our children to have a liveable future. At the same time, many small parcel shippers together generate large amounts of waste. To fulfil our extended producer responsibility, micro-enterprises need simple and workable solutions. Possible solutions: 1.

Filed in German · English published by the European Commission

I have a wool shop in Crete and online trading. In my view, the rules of the PPWR, which have been in force since 12.8.2026, do not save on packaging material. Unless shipping to other EU countries, which many companies (like me) have stopped, is an intended measure to avoid packaging.

Filed in German · English published by the European Commission

MOL Group welcomes the European Commission's efforts to establish a harmonised EU framework for packaging producer registration and reporting, with the aim of reducing administrative burdens on producers. A common reporting structure can significantly improve consistency, transparency, and comparability across Member States.

Sociedade Ponto Verde (SPV), the management body licensed to manage the Integrated Packaging Waste Management System in Portugal, as part of the Extended Producer Responsibility (EPR) (i.e. the producer responsibility organisation under Article 46 of the PPWR) supports the harmonisation that the PPWR intends to bring to the Information to be submitted when registering, as well as the Information to be communicated…

Filed in Portuguese · English published by the European Commission

Many small, independent micro businesses, are calling on EU policymakers to make Extended Producer Responsibility (EPR) and packaging compliance requirements simpler, proportionate, and workable for microbusinesses like ours.

As a small business selling across the EU (among others via the Catawiki marketplace), I want to raise several practical concerns about how the PPWR's Extended Producer Responsibility (EPR) obligations will affect micro and small enterprises like mine. Im specilised in old and vintage beads. 100% of my suppliers are abroad and 99% of my clients. 1.

Starch Europe welcomes the European Commissions call for feedback on the draft Implementing Regulation laying down rules for the application of Regulation (EU) 2025/40. Starch Europe supports the objective of establishing harmonised registration and reporting formats across Member States.

ASD is the voice of the European aerospace, security and defence Industries the industry that connects and protects. With 28 major European companies and 24 national associations, the overall representation adds up to more than 4,000 companies across 22 European countries.

Als grootste landbouworganisatie in Vlaanderen en Oost-België vertegenwoordigt Boerenbond duizenden landbouwers. Binnen de PPWR-verordening zijn voor de landbouwsector weliswaar enkele uitzonderingen voorzien, maar onder meer de sierteeltsector blijft sterk getroffen.

As shared in previous feedback rounds for PPWR, we see huge problems for SME's and the EU single market with PPWR. The following measures should be taken to minimize these issues: 1) Any business should be able to register directly with procuder registers and be able to submit their declarations directly, without an Authorized Representative in between. 2) Excemptions for SMEs, e.g.

The European Crafts Alliance (ECA) welcomes the PPWRs environmental ambition and its recognition that micro-enterprises require proportionate treatment. Our concern is that this principle has not yet been sufficiently reflected in the way cross-border Extended Producer Responsibility (EPR) works for occasional, low-volume sales.

Protocollo n. 243/2S/2026 Pistoia, 10 settembre 2026 Alla cortese attenzione di ENA European Nurserystock Association npo Kortrijksesteenweg 1144 J 9051 Sint-Denijs-Westrem Belgium Oggetto: Contribution regarding the harmonisation of registration and reporting under Regulation (EU) 2025/40 Dear Sirs, The European Nurserystock Association (ENA) welcomes the Commission's effort to harmonise registration and reporting…

Vannucci Piante welcomes the Commission's effort to harmonise registration and reporting under Regulation (EU) 2025/40, but stresses that the system must be proportionate to the structure of the nursery sector. Across 17 European countries, the sector comprises more than 33,000 businesses, 113,689 ha of production and an estimated production value of EUR 8.0 billion.

ES Reutiliza welcomes the European Commissions Draft Implementing Regulation establishing the harmonised format for the registration and reporting of packaging producers. A unified EU framework is essential to reduce administrative burdens and ensure a level playing field.

TIE supports the adoption of the draft Implementing Regulation but opposes the inclusion of Recital 6, which undermines the core purpose of the regulation by allowing future national measures to be introduced. TIE further advocates for the modification of the wording in Article 2(4) from "shall be based on" to "in accordance with" to ensure all data is aligned with the technical documentation but without being based…

The requirements for national representations and registrations are unreasonable for manufacturers who only sell a product to some countries every few years, even for a large company, in terms of effort and costs. Since the preparation of an offer requires the payment of a registration and the commissioning of a national representation, without which a sale/dispatch may take place.

Filed in German · English published by the European Commission

The European Nurserystock Association (ENA) welcomes the Commissions effort to harmonise registration and reporting under Regulation (EU) 2025/40, but stresses that the system must be proportionate to the structure of the nursery sector. Across 17 European countries, the sector comprises more than 33,000 businesses, 113,689 ha of production and an estimated production value of EUR 8.0 billion.

EuPC supports the Commission's objective of a harmonised, digital registration and reporting system under Article 44 PPWR, which can meaningfully reduce administrative burden for companies operating across the internal market.

In the context of the consultation on the draft implementing regulation of the PPWR on the format for entry in the register of producers and for the communication of data, Confindustria agrees with the objective of ensuring a harmonised framework at European level, considering it essential that its implementation result in effective simplification of the requirements for businesses.

Filed in Italian · English published by the European Commission

Coldiretti, the largest farmers’ representative organisation in Italy and Europe, with its 1.6 million members, welcomes the European Commission’s initiative to gather views on packaging, packaging waste and rules on national producer registers.

Filed in Italian · English published by the European Commission

EuMBC Position We support the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR) and the Commission's efforts to improve the functioning of Extended Producer Responsibility (EPR) schemes across the European Union.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the consultation on the rules on national registers for producers under the PPWR. We would like to highlight several points that should be taken into account for the final implementing act to ensure that the act achieves simplification and harmonisation of rules for national PPWR producer registers.

Supply chain Italy, the association that supports and values the agri-food chain 100 % in Italy, welcomes the European Commission’s initiative to collect opinions on packaging, packaging waste and rules on national registers of producers.

Filed in Italian · English published by the European Commission

EU Verpackungsverordnung Sehr geehrte Damen und Herren, wir sind ein mittelständischer Baumschulbetrieb mit 18 Mitarbeiterinnen und Mitarbeitern und liefern unsere Jungflanzen in fast alle Mitgliedstaaten der Europäischen Union. Die derzeit vorgesehenen Anforderungen an die Registrierung, Erfassung und Meldung von Verpackungen stellen für unseren Betrieb eine nicht leistbare Belastung dar.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Opinion of the dual systems of Germany within the meaning of § 3(8) VerpackDG and the Gemeinsame Stelle dualer Systeme Deutschland GmbH in their function as joint bodies within the meaning of § 24 VerpackDG: We welcome the aim of the draft to harmonise registration and reporting obligations for manufacturers across the EU and to reduce the administrative burden.

Filed in German · English published by the European Commission

Brussels, 10 September 2026 Position on the PPWR Draft Implementing Regulation Establishing Rules on National Registers of Producers INTRODUCTION In response to the public consultation on the draft Implementing Regulation under Article 44(14) of the Packaging and Packaging Waste Regulation (PPWR), this document sets out Plastics Recyclers Europe’s (PRE) priorities on the technical specifications for national…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Członek Europejskiej Rady Przemysłu Chemicznego CEFIC Warszawa, 10.09.2026 r. PIPC/113/2026 Uwagi Polskiej Izby Przemysłu Chemicznego do projektu rozporządzenia wykonawczego Komisji w sprawie krajowych rejestrów producentów na podstawie rozporządzenia (UE) 2025/40 w sprawie opakowań i odpadów opakowaniowych (PPWR) Polska Izba Przemysłu Chemicznego pozytywnie ocenia cel projektu polegający na harmonizacji formatów…

Filed in Polish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The current regulation unreasonably discriminates against small businesses and creative individuals who are responsible for a tiny fraction of sales and packaging circling within the EU. The current requirements place a disproportionate financial and bureaucratic burden on small businesses and individuals which effectively excludes them from the market.

Bentley InnoMed GmbH develops and manufactures implants and catheters for the endovascular treatment of peripheral and aortic vascular diseases. With the attached position paper, Bentley seeks to contribute to the public consultation on the Packaging and Packaging Waste Regulation (PPWR) and to highlight concerns from the medical device sector.

The Packaging and Packaging Waste Regulation (PPWR) aims to reduce packaging waste, increase recyclability and reuse, and strengthen the circular economy across the EU. These objectives are widely supported by Swedish business, as is the use of EPR fees to finance and further improve the collection, sorting and recycling of packaging waste.

As the VGMS, we welcome the fact that the European Commission is making it possible to consult on the implementing regulation establishing a register of producers and the obligation for producers to report to their respective national systems. The implementation of the PPWR has created great uncertainty for companies in the cereals, mills and starch sectors.

Filed in German · English published by the European Commission

The Bundesverband Druck und Medien (BVDM) supports the aim of the PPWR to create a uniform and reliable framework for greater sustainability, resource conservation and environmental protection throughout Europe. However, implementation must not result in businesses being burdened with ever-increasing bureaucratic requirements as a result of additional national and European procedures.

Filed in German · English published by the European Commission

As a small and medium-sized enterprise (SME), we fundamentally support the EU’s environmental and resource protection objectives. However, the practical implementation of the Packaging and Packaging Waste Regulation (PPWR) poses almost insurmountable administrative hurdles for small businesses. 1. Disproportionate resource commitment SMEs do not have their own legal, tracking or compliance departments.

Filed in German · English published by the European Commission

Good afternoon, I provide our comments: QR code identifying the undertaking: — The marking obligation depends on the packaging being reusable or single-use, but the qualification criteria are not safely applied in practice especially in corrugated cardboard boxes, which can withstand several rotations without having been designed for re-use.

Filed in Portuguese · English published by the European Commission

The successful implementation of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) depends crucially on the appropriate and practical design of the implementing acts still to be adopted. In the trade mark association’s view, it is of particular importance that clear, workable and uniform EU-wide framework conditions be established in this regard.

Filed in German · English published by the European Commission

IMPALA is the European association of independent music companies, with over 6,000 members across 33 European territories. We represent SME record labels and self-releasing artists, a part of the sector which accounts for over 80% of all music releases and investment in new music. They are the main innovators and discoverers of new talents, thus contributing strongly to Europes cultural and musical diversity.

The Packaging and Packaging Waste Regulation is a source of enormous costs and bureaucratic hurdles for German craft businesses. The attached opinion sets out our demands in order to make the Regulation manageable and reduce the burden on micro and small businesses in the craft sector.

Filed in German · English published by the European Commission

Ladies and gentlemen, I very much welcome the fundamental efforts to reduce and avoid packaging materials, as well as re-use and maximum recycling rates to minimise environmental pressures. The current PPWR since 12.8.2026 is a major obstacle to the idea of a free EU economy.

Filed in German · English published by the European Commission

EDANA, the voice of the nonwovens and related industries, welcome the European Commissions objective of establishing a harmonised format for registration in, and reporting to, national registers of producers for packaging under Article 44(14) of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR).

By requiring an agent to pay for each supplier country in the EU, I am likely to go bankrupt. They discriminate against small and micro-enterprises through this requirement, which is not justified. Withdraw this requirement if you don't want Europe’s merchants to get involved. In the end, you will be financed by the business community, which will remove the ground under the feet with this requirement.

Filed in German · English published by the European Commission

Packaging and packaging waste – rules on national registers of producers: Positioning from the handicrafts of Hessen: On 12 August, the Packaging and Packaging Waste Regulation (PPWR) entered into force. With it, the European Union has set new requirements for the production and processing of packaging and introduced measures to ensure the best possible recycling of packaging materials.

Filed in German · English published by the European Commission

MOL Group’s key comments on the rules on national registers of producers under Regulation (EU) 2025/40 MOL Group welcomes the European Commission's efforts to establish a harmonised EU framework for packaging producer registration and reporting, with the aim of reducing administrative burdens on producers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Pharma Deutschland welcomes the European Commissions initiative to make the application of the PPWR more practical through delegated acts and to simplify existing implementation requirements. Since many member companies operate across Europe, a harmonized application of the requirements across member states is of particular importance.

Confapi welcomes the general principle underpinning the European Commissions implementing act, which aims to standardize and digitize information flows related to extended producer responsibility (EPR) under Regulation (EU) 2025/40 (PPWR). Harmonization is an essential prerequisite to prevent the fragmentation of the internal market and reduce compliance costs for businesses.

Consultation response – PPWR reporting and registration Position Paper: Comments on Harmonized Registration and Reporting Requirements The Norwegian Packaging Association is Norway's only interest organization for packaging and wrapping.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

1. Excessive level of detail in proposed reporting requirements Annex II, Part A of the proposed Implementing Regulation introduces a substantial expansion of reporting obligations compared to Annex II, Table 1.

COMMISSION IMPLEMENTING REGULATION LAYING DOWN RULES FOR THE APPLICATION OF REGULATION (EU) 2025/40 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL AS REGARDS THE FORMAT FOR REGISTRATION IN AND REPORTING TO THE REGISTER OF PRODUCERS AND THE INFORMATION TO BE PROVIDED IN THAT CONTEXT Comments of the Czech Trade and Tourism Association (SOCR ČR) GENERAL COMMENTS 1) Harmonized PPWR data reporting through producer…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Federation of German Industries (BDI) supports harmonised, digital and proportionate registration and reporting under Article 44 PPWR. The implementing regulation should establish a genuine once-only approach, use a common EU-wide core dataset, distinguish clearly between the responsibilities of the different reporting entities, harmonise reporting periods and avoid requirements that depend on unavailable…

We welcome the opportunity to provide input on the draft Implementing act on article 44 of PPWR. Please find enclosed COSMED contribution to reduce unnecessary administrative duplication and costs while maintaining the environmental objectives of the PPWR.

I-Tech AB welcomes the opportunity to provide feedback on the draft Implementing Regulation. The attached document highlights the importance of maintaining a proportionate and operationally feasible registration framework, especially for low-volume activities, including the cross-border shipment of R&D samples.

FoodDrinkEurope welcomes the opportunity to comment on the draft implementing act establishing a harmonised format for national producer registers under Article 44 of Regulation (EU) 2025/40 (PPWR). FoodDrinkEurope believes that the implementing act on rules on national registers of producers under PPWR should contribute to reducing administrative burdens, improving legal certainty, and enabling efficient…

Subject: Feedback on the implementation of PPWR and EPR registration costs for micro-enterprises I am writing as the owner of a micro-cosmetics company based in Athens, Greece, which I have built from scratch with hard work and dedication. Environmental responsibility is a core value for my brand.

Federation of the Food and Drink Industries of the Czech Republic (FFDI) supports such provisions that will harmonize to a maximum extent the rules for the whole of the EU so that it supports the EU free market. Therefore the FFDI supports maximum harmonization of the data required in producer registers according to Article 44 of the PPWR.

The Deutsche Fleischer-Verband e.V. (DFV) represents the interests of the approximately 10.000 butchers’ trades. These companies represent an important part of the regional chain of meat and charcuterie. They traditionally represent quality and responsible handling of animals.

Filed in German · English published by the European Commission

Landbell Group company European Recycling Platform (ERP) is pleased to provide the attached feedback. ERP operates seven packaging Producer Responsibility Organisations (PROs) across Europe, and our feedback presented here is based on our direct experience in this field. ERP is generally in support of the draft articles and annexes, however, we provide feedback and proposals for consideration on specific aspects.

The PPWR’s country-by-country registration system will harm Europe’s music ecosystem European Music Managers Alliance submission on packaging and packaging waste rules concerning national registers of producers Submitted by: European Music Managers Alliance (EMMA) Representing: Our members represent more than 3,000 music managers working with over 12,000 artists across Europe Date: 10 September 2026 Europe’s music…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Furniture Industries Confederation (EFIC) welcomes the European Commission consultation on the draft Implementing Regulation establishing common formats and data requirements for registration in and reporting to national registers of packaging producers.

FEFCO (the European Corrugated Board Industry) supports Extended Producer Responsibility (EPR) schemes as valuable tools to ensure the proper collection and recycling of packaging waste. However, fragmented national EPR schemes, unclear definitions, and a lack of transparency result in a costly and, in some cases, ineffective framework for managing packaging waste.

These regulations seem completely illogical and I see it as harming small businesses and the self-employed. One of the main EU open market bonuses was easier trading between Member States, especially as a self-employed person, but such regulations eliminate this possibility.

Filed in Latvian · English published by the European Commission

Affordable Medicines Europe welcomes the opportunity to contribute to the implementing rules on registration and reporting under Regulation (EU) 2025/40. We represent the independent distribution of medicines across the EEA, encompassing both the parallel import and export of medicines between EU Member States.

ORLEN welcomes the objective of harmonising national producer registers and reporting requirements. However, the Implementing Regulation should remain within the scope of Article 44(14) PPWR and focus on harmonised formats and efficient data exchange.

We are a French SME, a manufacturer and importer of custom-made advertising items, which supplies its customers in several Member States. We share the objectives of the PPWR. Our reservations relate to its implementation. 1. Single European registration. One authorised representative and one procedure per country multiply the costs and formalities without any benefit for the environment.

Filed in French · English published by the European Commission

Bundesverband E-Commerce und Versandhandel Deutschland e.V. (bevh) - Durchführungsverordnung Verpackungsregister und Lösungsvorschläge für grenzüberschreitende EPR-Pflichten Berlin, den 10.09.2026 Der Bundesverband E-Commerce und Versandhandel Deutschland e.V.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

t+m supports the Commissions objective of creating a harmonised framework for the registration and reporting of packaging producers across the EU. However, harmonisation should not simply mean introducing similar requirements in 27 different national systems. It should lead to a genuinely European approach that makes compliance simpler, more efficient and less burdensome for companies operating across borders.

Medicines for Europe, representing generic, biosimilar and value added medicines manufacturers across Europe, welcomes the opportunity to contribute to the call for feedback on the rules on national register of producers (PPWR). Please find our submission attached.

CEPE has provided its input to the European Commissions initiative on national registers of producers under the Packaging and Packaging Waste Regulation. The submission sets out the sectors views on how producer registration requirements should be implemented in a consistent, efficient and proportionate way across the EU, while minimising unnecessary administrative burdens for companies.

Invito a presentare contributi della Commissione europea sui registri nazionali dei produttori nell’ambito del Regolamento (UE) 2025/40 sugli imballaggi e i rifiuti di imballaggio 10 settembre 2026 Confcommercio esprime le proprie osservazioni nell’ambito delle quattro consultazioni avviate dalla Commissione europea in relazione all’attuazione del Regolamento (UE) 2025/40 sugli imballaggi e i rifiuti di imballaggio…

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Feedback to Commission public consultation on the draft implementing act establishing rules on national registers for producers (Article 44 PPWR) (Last updated: 10. September 2026) The Food Industries Association of Austria (FIAA) welcomes the opportunity to comment on the draft implementing act establishing a harmonised format for national producer registers under Article 44 (1) and (14) of the Packaging and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Brussels, September 2026 EUROPEN’s inputs on Article 44(14) of the Packaging and Packaging Waste Regulation, establishing a register of producers for packaging and the obligation on producers to report to their national schemes.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

I am a one person creative business and I am asking for a simplification or exemption for micro businesses with regards to EPR. I have started my business in 2026 and I started selling to Belgian and Dutch customers. I have had very few sales and I have put a very small amount of packaging on the market. However I am now being asked to register in all the countries that I sell to and appoint an AR.

BIOREPACK, an Extended Producer Responsibility Organisation (PRO or EPR scheme) which is part of the CONAI system and specifically dedicated to organic recycling of biodegradable and compostable plastic packaging, broadly agrees with the objectives and clarity of the Initiative. At the same time, it proposes the following clarifications. 1.

Filed in Italian · English published by the European Commission

Freshfel Europe represents the fresh fruit and vegetable supply chain, bringing together producers, traders, importers, exporters, wholesalers, retailers, logistics operators and service providers. The sector ensures the daily availability of perishable and nutritious products across the EU while operating under strict food safety and quality requirements.

Obaly a odpady z nich – pravidla týkající se národních registrů výrobců Stanovisko HK ČR Hospodářská komora České republiky (HK ČR) vítá možnost vyjádřit se k návrhu pravidel týkajících se národních registrů výrobců obalů a souvisejících požadavků na evidenci a vykazování údajů.

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Feedback from De Nolf NV, nursery, Waregem (Belgium) We are a family-run nursery. We grow ornamental shrubs, perennials and trees in growing containers and sell exclusively to professional customers: garden centres, wholesalers, growers and landscapers, in Belgium and in some twenty other Member States.

Regulation (EU) 2025/40 provides that a distributor established in one Member State is to be considered a producer where he makes packaging or packaged products available for the first time to an end user in another Member State. To that end, it must register in the register of producers, appoint an authorised representative in that other Member State and comply with reporting obligations.

Filed in French · English published by the European Commission

Verpact thanks the European Commission for the public consultation. As PRO for packaging in the Netherlands, this draft Implementing Regulation is of importance for our activities. Our full reaction can be read in the attached document. A small summary is given below.

As part of the public consultation procedure for the draft Regulation implementing the rules on national producer registers (‘the draft Regulation’), GESTIÓN DE ENVASES COMERCIALES E INDUSTRIALES, S.L. (‘GENCI’), in its capacity as an extended producer responsibility organisation for commercial and industrial packaging, submits the attached document with comments in due form and by the deadline.

Filed in Spanish · English published by the European Commission

ICADA welcomes the Commissions initiative to harmonise registration and reporting formats for national producer registers under the PPWR. However, harmonised formats alone will not sufficiently reduce the administrative burden, particularly for SMEs operating in several Member States.

The VDMA welcomes the harmonisation of packaging reporting envisaged in the draft Implementing Regulation. A uniform, interoperable and machine-readable format across the EU can significantly facilitate the practical implementation of extended producer responsibility (EPR). However, harmonisation must result in genuine simplification and must not create additional data collection or documentation requirements.

The Department of Safety and Environment of Groz-Beckert supports the objective of harmonising producer registration and reporting requirements under the PPWR. Harmonised data formats and reporting structures can contribute to greater consistency and legal certainty across the EU.

as small manufacturing companies, we, ZURRPACK GmbH, would like to take the opportunity to draw attention to what we consider to be a particularly critical point in the planned implementation of the PPWR producer register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the owner of a small German sole trader, I operate, inter alia, the online shop Balkanroots.de and sell myself finished textiles and other products to end customers. In addition to Germany, I also supply customers in other European countries.

Filed in German · English published by the European Commission

With thanks for the opportunity to comment, the BDSI asks the Commission in particular for the following clarifications and adjustments: The publication of brand names should be limited to what is strictly required by law. It should be excluded that publication in the register discloses confidential or contractually protected private label, pay-manufacturing, supply or production relationships.

Filed in German · English published by the European Commission

ARMO (Romanian Association of Online Stores) submits the attached contribution to the public consultation on the draft Implementing Regulation on the register of producers under Regulation (EU) 2025/40. ARMO raises three observations: (1) the bulk verification mechanism referred to in Recital 11 and Article 1(3) does not yet appear to be reflected in the format structure set out in Annexes I and II; (2) the digital…

In the opinion of the National Chamber of Agriculture, it would be important that the uniform data content is taken into account by all Member States and that the national registration system does not request more data from economic operators than the absolutely necessary information.

Filed in Hungarian · English published by the European Commission

Dear Sir or Madam, My name is Federica, and I am an Italian artisan who creates handmade products. My business is still very small and could currently be described as a hobby business, but I would truly love to turn it into a full-time profession. Making a name for yourself in this field is already extremely difficult.

As an internationally active company, we fundamentally support the objectives of the PPWR, in particular the reduction of packaging waste and the promotion of the circular economy. However, it is crucial that the regulatory requirements are implementable and proportionate in operational practice.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a self-employed businessman in small online sales, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

I am based in Greece and I run a small handmade shop with jewelry and home decor both on Etsy and my official website. Under the new EPR regulation, I'm required to appoint an authorised representative in each of the 26 EU countries where I sell, at a cost of around 270 per year per country an amount I simply cannot cover, as it far exceeds any reasonable proportion for a one-person business like mine, where we ship…

Our comments are limited to the reporting obligations set out in the draft for businesses (Article 2, Annex II). In our view, it is particularly important that the reporting obligations for producers under Article 44(7), (8) and (10) PPWR are not regulated in isolation, but rather in conjunction with other, existing reporting obligations, e.g.

Please find attached EPRO's feedback regarding the Commission's Draft Act on rules on national registers of producers under the PPWR. We would be pleased to provide further information on the topic covered in this paper and thank the Commission for the opportunity to give feedback.

this new regulation is absolutely ridiculous. On top of the GDPR regulation of having to pay a representative in EACH european country, we now have to pay 27 european packaging regulators to sell to as if we were huge corporations?? I am a micro business. I sell maybe £4000 worth of goods to the EU per year. How did these law makers think us small businesses would survive having to pay all these fees???

Deutscher Konditorenbund Bundesinnungsverband für das Konditorenhandwerk Otto-Suhr-Allee 97/99 · 10585 Berlin Fehlallokation von Prüfpflichten und Haftungsrisiken der PPWR: Gefährdung regionaler Wertschöpfung, Aushöhlung kommunaler Finanzen und Beschleunigung des Strukturwandels im Lebensmittelgewerbe 1.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Cosmetics Europe's feedback on the draft Implementing Regulation under Article 44(14) PPWR regarding the register of producers Cosmetics Europe, the European trade association representing the cosmetics and personal care products industry, welcomes the opportunity to provide feedback on the draft Implementing Regulation laying down rules for the application of Regulation (EU) 2025/40 as regards the format for…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ESSNA welcomes the Commissions objective of harmonising registration and reporting requirements for EPR schemes across Member States. However, harmonisation alone will not sufficiently reduce the administrative burden for businesses operating across the EU.

PORTUGAL'S COMMENTS ON THE DRAFT IMPLEMENTING REGULATION AND THE DRAFT ANNEX TO THE REGULATION ARTICLE 44(14) PPWR 10 september 2026 • Part C for proving a certificate issued by the producer responsibility organisation In Portugal, this type of certificate is issued by the National Producers Registry, not by the PRO.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SPECTARIS-Stellungnahme Packaging and packaging waste – rules on national registers of producers Berlin, 10. September 2026 Ansprechpartnerin [name removed] Referentin für Kreislaufwirtschaft und Umweltrecht / Regulatory Affairs Fon [phone removed] [email removed] www.spectaris.de SPECTARIS ist der Deutsche Industrieverband für Optik, Photonik, Analysen- und Medizintechnik und vertritt 400 überwiegend…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The draft implementing act specifies the registration and reporting obligations under Article 44 of the EU Packaging Regulation (PPWR) and will thus determine decisively which data must in future be reported to the national producer registers. The impact goes far beyond a mere technical adaptation of existing registers. The HDE opinion is attached.

Filed in German · English published by the European Commission

EDP welcomes this initiative by the European Commission. The Implementing Regulation draft appears to be primarily designed around individual operators and does not specifically address common situations in large corporate groups operating across several Member States, carrying out centralised procurement, or managing compliance obligations through shared corporate services.

Our activities involve purchasing and importing a wide range of construction materials and products, which may arrive in plastic wrapping, cardboard boxes, bags, buckets, containers, pallets and other forms of packaging. Registration and reporting requirements are kept simple and proportionate, particularly for companies whose main activity is construction rather than the production or sale of packaging.

Dear Sir, Madam, The Austrian Federal Economic Chamber (WKO) would like to thank you for the possibility of submitting a draft implementing regulation on Article 44(2) of Regulation (EU) 2025/40 (PPWR) regarding the format for registration and notifications in the register of producers and the information to be provided in this context, and requests that the comments set out in the Annex be taken into account.

Filed in German · English published by the European Commission

A harmonised, automatable register format is welcomed. However, relief only arises if concepts, categories, calculation methods, deadlines and validation rules are also consistent across the Union. Additional national fields may be provided only where they are strictly necessary. The register must remain a minimum solution. 1.

Filed in German · English published by the European Commission

The Federation of European Publishers (FEP) is the umbrella association of book publishers in the European Union and the voice of the great majority of publishers in Europe. FEP represents 31 national associations of publishers of books, learned journals and educational materials of the European Union, the European Economic Area and other European countries.

Cabot supports the objective of harmonizing producer registration requirements across the European Union. However, harmonization should go beyond aligning data fields and reporting formats. To deliver meaningful simplification and support the proper functioning of the EU Single Market, producers placing packaging on the market in several Member States should be able to submit registration information only once…

The desire to reduce packaging and waste is understandable and understandable throughout. The current system of registering for each individual country and, if necessary, appointing an authorised representative makes it more difficult for small traders to send and sell goods widely across the EU.

Filed in German · English published by the European Commission

The PPWR raises economic, administrative and operational issues and hurdles for our small family-run nursery that we cannot address. The rules introduced are far too complex for us as a small nursery. The enormous amount of time it takes to understand what exactly the new obligations mean, let alone to obtain and process the information, is definitely too great and unaffordable.

Filed in German · English published by the European Commission

Requiring businesses to register and report packaging separately in every EU Member State into which they sell goods creates a significant administrative and non-tariff barrier to cross-border e-commerce and undermines the practical functioning of the Single Market. Harmonised reporting formats are a welcome step, but they do not solve the fundamental problem.

Stanowisko w sprawie inicjatywy „Packaging and packaging waste – rules on national registers of producers” Niniejsze stanowisko przedstawiam z perspektywy małego, rodzinnego gospodarstwa szkółkarskiego prowadzącego produkcję roślin w Polsce. Nasza szkółka jest rodzinnym przedsiębiorstwem.

Filed in Polish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Sehr geehrte Damen und Herren, als kleiner produzierender Handwerksbetrieb des Feinwerkmechanikerhandwerks mit 15 Mitarbeitern möchten wir auf einen für uns besonders kritischen Punkt bei der Umsetzung der PPWR hinweisen: Die Pflicht zur Bestellung eines Bevollmächtigten für die erweiterte Herstellerverantwortung bei grenzüberschreitenden Lieferungen innerhalb der EU.

At the moment, these rules prevent me from sending to the EU and, as a result, from inadvertently losing a lot of income. The rules are too expensive for small entrepreneurs, and getting all these documents right and fully complying with the rules would take so little time for a self-employed person to do your real job.

Filed in Dutch · English published by the European Commission

In our paper (attached), we comment on the draft implementing act, focusing in particular on the following points: 1. European single data set | 2. Clear and uniform definitions | 3. Change and version logic | 4. Avoidance of divergent national rules | 5. Mandatory EU mapping of national EPR requirement | 6. Brands/own brands/wage production | 7. Ecomodulation/Data Architecture | 8.

Filed in German · English published by the European Commission

Policy Hub Circularity for Apparel & Footwear welcomes the Commission's draft Implementing Regulation establishing the format for registration in and reporting to national packaging producer registers under Article 44(14) of Regulation (EU) 2025/40 (PPWR).

The planned introduction of standardised reporting formats and the planned material-specific coverage of composite and multi-material packaging will lead to considerable additional burdens, particularly for fruit, vegetable, meat, milk, wine and product cooperatives and producer organisations.

Filed in German · English published by the European Commission

Through this paper, Reusable Packaging Europe (RPE) seeks to contribute to the European Commissions draft implementing regulation under Article 44(14) of the Packaging and Packaging Waste Regulation (PPWR), establishing harmonised formats for registration in and reporting to national producer registers.

Ladies and gentlemen, as a small and medium-sized enterprise with its own online shop, we would like to draw your attention to a particularly problematic aspect of the planned implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border distribution in each relevant EU Member State.

Filed in German · English published by the European Commission

Established in 1969, Faerch is a leading provider of circular, rigid food packaging with integrated recycling capabilities, and leads the market with the post-consumer recycled content in our polyethylene terephthalate (PET) plastic trays. Headquartered in Holstebro, Denmark, we employ around 5,000 people across 25 plants in Europe.

As a medium-sized company with a small webshop, we are very concerned about the increasing requirements in the field of packaging registration, system participation and volume reporting. In principle, we support the objective of reducing packaging waste and ensuring that companies contribute adequately to the costs of collection and recovery.

Filed in German · English published by the European Commission

The ‘Deutsche Vernetzungsstelle Ländliche Räume – für die Gemeinsame Landwirtschaft der EU’ (DVS – German Networking Agency for Rural Areas – for the Common Agricultural Policy of the EU) is located as a unit in the Federal Office for Agriculture and Food. The DVS has a networking mandate within the framework of the CAP National Strategic Plan.

Filed in German · English published by the European Commission

FEVE, the European Container Glass Federation, welcomes the opportunity to comment on the draft Implementing Regulation establishing the format for registration in and reporting to national registers of producers under Article 44(14) of Regulation (EU) 2025/40. FEVE supports the objective of establishing harmonised and workable reporting requirements across Member States.

The circular economy and the reduction of packaging waste are of great importance to the German economy. At the same time, the PPWR currently results in a high level of red tape and uncertainty for businesses. Reliable data can make a meaningful contribution to enforcement and to improving packaging policy. To this end, reporting requirements should be proportionate and practically implementable.

Filed in German · English published by the European Commission

the lack of a de minimus here is likely to add unreasonable costs associated with D2C sales into EU territories. This is on top of other costs associated with doing business when importing products into the EU. Although we support the intent of the regulation more provisions need to be available to SMEs and low volume sales to comply with them intent without incurring unreasonable fees

The Czech Traditional Trade Association brings together traditional Czech retail networks, defends the interests of Czech traders, protects and develops the tradition of Czech shops, supports Czech producers as well as regional products.

Filed in Czech · English published by the European Commission

EXPRA is the European Association of Extended Producer Responsibility Organisations (PROs), representing 25 organisations within 21 EU Member States and the European Economic Area which ensure that producers contribute to the costs associated with the life cycle and end-of-life management of their products, including collection, sorting, reuse, recycling.

Made in Germany Ref. Ares(2026)8603645 - 10/09/2026 since 1889 Filling Machines Packaging Machines Automation Gustav Obermeyer GmbH & Co. KG • Mühlstraße 18-20 • D-08527 Plauen PPWR-Verantwortlicher Plauen, 10. September 2026 Sehr geehrte Damen und Herren, als Betreiber eines kleinen Maschinenbauunternehmens für Speziallösungen möchte ich die Gelegenheit nutzen, auf einen aus meiner Sicht besonders kritischen Punkt…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Associazione Nazionale Vivaisti Esportori considers it important to regulate the use of packaging and the resulting waste and considers the proposed Regulation to be a good starting point. At the same time, it is not easy for the live plants and flowers sector to understand who should actually be subject to the required registrations.

Filed in Italian · English published by the European Commission

The rationale of the PPWR is fully supported and hopefully serves as a stimulus for innovation also outside the EU. However, as a medium-sized company established exclusively in Germany (and also for many micro and small enterprises), what proves to be uneconomic and disproportionately burdensome for us is the obligation to appoint an authorised representative and to register in the respective national producer…

Filed in German · English published by the European Commission

I am craftswoman and a micro business owner based in Athens Greece. I design and construct costume accessories and sell them on-line. I had the chance to create my business, which is my sole source of income, 13 years ago when I was funded by the EU through a Womens Entrepreneurship Program.

We are an association of 4 dozens of small, medium and large consumer cooperatives in the Czech Republic. We recommend that the Commission, when preparing an implementing act: extend the scope of harmonised data items to cover all accounting and reporting obligations stemming from the PPWR; ensure the alignment of registration, registration and reporting obligations within one system; include in the register data…

Filed in Czech · English published by the European Commission

Comments of the Czech Republic on the Draft Implementing Regulation on Producer Registration and Reporting under Article 44(14) PPWR: General comments concerning clarity and consistency data consistency 1.) What does separate systems for the management of packaging waste referred to in Article 1(2) mean?

I firmly believe that all businesses should pay their way when it comes to recycling the waste they produce. I am more than happy ro pay for what I produce. But this new legislation doesnt make any sense. It's a silly, ill considered law that won't affect those creating most of the waste. In the meantime small businesses such as mine will have to pay way more than our fair share.

Ladies and gentlemen, I run a small nursery without employees and have occasionally sent out orders to some EU countries, depending on the country from which one or more orders were received. It is not about 100 parcels per country per year, but about one to ten parcels per country per year.

Filed in German · English published by the European Commission

The PPWR in its current form is undoubtedly the most devastating legal and bureaucratic disaster the EU has implemented to date, the fallout of which is still incomprehensible at this point. A regulation that is formulated in such a way that even legal professionals are hard-pressed to interpret it, and that leaves so much leeway for legal and bureaucratic arbitrariness that any monitoring body can interpret it…

This initiative aims to harmonise parts of extended producer responsibility schemes for packaging in EU countries. Lays down rules on the obligation for EU countries to set up a register of producers and on the obligation for producers to report to their national recycling schemes Organised GUARANTEE mandatory at 100 %

Filed in Italian · English published by the European Commission

As an operator of a small online shop with only 2 employees, I would like to highlight the following points on the PPWR: 1. Scale of companies affected by adverse impacts 2. Disproportionality for small and micro-enterprises, including by removing de minimis thresholds – what are the benefits? 3. excessive bureaucracy 4.

Filed in German · English published by the European Commission

QuestPair operates a B2B marketplace for used and refurbished laboratory equipment, with buyers and sellers across the EU. Reuse is an important part of our business model. We strongly support waste reduction and the reuse of packaging materials. At the same time, the current rules create disproportionate administrative costs and unnecessary barriers to cross-border trade within the EU Single Market.

I am a micro business owner from France, and half my income comes from designing and producing accessories to sell online. Until now, I have been able to support myself this way, but with this new regulation passed as is, I fear I might have to close my business. I send a couple packages out a week to fellow EU countries.

Ladies and gentlemen, I operate a very small craftsmanship company with 1-2 deliveries per year within the EU. The requirement to appoint authorised representatives for each country, regardless of the quantities of packaging imported into each country, is not feasible for micro-enterprises.

Filed in German · English published by the European Commission

As a matter of principle, we agree – I agree with our micro-enterprise here – that it is high time to deal with the general flood of packaging waste. We therefore welcome the attempt to lay down rules on packaging. However, implementation is so complicated and burdensome for micro-entrepreneurs that with this law we can only send our goods (around 400 parcels per year to EU countries) to one neighbouring country.

Filed in German · English published by the European Commission

Ladies and gentlemen, we are a small family-run company and supply our products to a restricted group of users throughout the EU. However, the volume of our exports varies greatly from one EU country to another, sometimes in very small quantities.

Filed in German · English published by the European Commission

Proportionate registration and reporting obligations for micro-enterprises We welcome the aim of the PPWR to reduce packaging waste and harmonise extended producer responsibility schemes across the EU. However, the design of the national registers of producers should take greater account of the proportionality of the administrative burden, in particular for micro-enterprises.

Filed in German · English published by the European Commission

From what I have understood so far it is not quite clear what we are supposed to do and the steps to follow, depending our position. My suggestion is that, if the information required can be obtained once from the source, the starting point, that is the supplier in case of import of goods, this data should be recorded once and not requested from all wholesale customers to collect all data again from the beginning.

— The French fresh fruit and vegetable sector represented by Interfel shares the objective of European harmonisation of the rules on national producer registers, in order to ensure a clear, consistent and uniformly applicable framework in all Member States.

Filed in French · English published by the European Commission

We welcome the European Commission’s recommendation to establish a common format for listing in the register of producers and for reporting data pursuant to Article 44 of Regulation (EU) 2025/40 on packaging and packaging waste. A common, digital and automated process-oriented framework is essential to reduce regulatory fragmentation and ease the administrative burden for businesses operating in the Single Market.

Filed in Italian · English published by the European Commission

The German Aerospace Industries Association (BDLI) represents more than 300 member companies across the German Aerospace Industry. Directly employing more than 130,000 people and generating annual revenues of approximately EUR 62 billion (2025), the industry contributes significantly to innovation, technological leadership, economic growth and Europe's strategic resilience.

Fibre Packaging Europe (FPE), a coalition comprising seven trade associations spanning the fibre packaging value chain in Europe, recognises EPR schemes as valuable tools to ensure the proper collection and recycling of packaging waste. However, fragmented national EPR schemes, unclear definitions and a lack of transparency result in a costly and, in some cases, ineffective framework for managing packaging waste.

We run a second retail shop focusing on organically produced products from the raw material hemp and other natural textiles. Sustainability, environmental protection and waste prevention play an important role in our company and we therefore support the PPWR’s objective of reducing packaging waste and making distance selling more resource- and environment-friendly.

Filed in German · English published by the European Commission

I am a one-person small artist business. I send prints and strickers and other handmade items in flat cardstock envelopes, but I'm under the same responsibilities as gigantic corporations with many employees. I have no means of knowing if I will send one two, five or any packages to one of the countries that require additional fees and paperwork due to those EU directives. What is this money even being spent on??

The draft aims to reduce administrative burden by harmonising data and simplifying procedures for smaller producers. However, simplified reporting below 10 tonnes does not solve the main issue for micro- and small businesses. The main burden is not the amount of information reported, but separate national representation and reporting.

We support the objectives of producer registers and extended producer responsibility (EPR) as important tools for achieving the circular economy. However, in practice, companies within our group face a number of challenges that make clear and efficient compliance difficult. Lack of clarity on the role definition: The main challenge is to identify the producer’s role in international supply chains.

Filed in Dutch · English published by the European Commission

To enable effective and consistent implementation of the PPWR across the EU, the regulation should be harmonised to the greatest extent possible and avoid creating unnecessary fragmentation between Member States.

The Malta Sociological Association (MSA) supports effective and harmonised national registers of packaging producers as an important mechanism for strengthening Extended Producer Responsibility (EPR). Producer responsibility should remain central to EU packaging policy.

To the competent EU Commission Services, My name is Andrea Pietrini, Production and Sustainability Manager of a small enterprise operating in the sustainable and circular fashion sector. We welcome the opportunity to provide our feedback on the Packaging and Packaging Waste Regulation (PPWR).

Our contribution provides comments on the draft implementing act under Regulation (EU) 2025/40 concerning data from the register of producers and reporting obligations on packaging and packaging waste. We propose several adjustments to improve consistency, operational feasibility and alignment with PPWR reporting requirements, including on liquid food bricks, reusable packaging, collected quantities and packaging…

Filed in French · English published by the European Commission

Dear Sir or Madam The European National Registers network (EUNR) brings together competent national authorities and organisations from currently 16 EU Member States that represent producer register/packaging data.

Central position: the simplification of the format is necessary, but it will not be sufficient if the EPR framework maintains disproportionate fixed costs and national obligations for micro-enterprises engaged in cross-border trade.

Filed in French · English published by the European Commission

The BMW Group welcomes the European Commissions draft implementing regulation and the opportunity to provide feedback. We support the efforts to establish a harmonised and robust framework for the implementation of Extended Producer Responsibility (EPR) obligations while ensuring effective producer registration and reporting systems under the Packaging and Packaging Waste Regulation (PPWR).

Response on behalf of Fairplant BV, trade and production of fruit tree rootstocks and soft fruit plant material, Emmeloord (NL). As a small company with 5 employees, we already have the necessary administrative burden in terms of origin, certification, traceability, inspections, plant health requirements and export documents. This is compounded by a separate detailed packaging registration.

Filed in Dutch · English published by the European Commission

Welcome the opportunity to provide our input on the further implementation of Regulation (EU) 2025/40 on packaging and packaging waste. Our comments reflect practical challenges and concerns raised by companies operating in the cosmetics and detergents sectors following the start of application of the PPWR.

Filed in Polish · English published by the European Commission

Kick And Rush (K&R) is a Belgian B2B branded merchandise company operating in Belgium, France and Mauritius, registered as a packaging producer under national EPR schemes in Belgium and France. We support the aim of this Implementing Regulation a harmonised format for registration and reporting but ask the Commission to address the following before finalising the text: 1. Multi-country duplication.

Federation of the European Cookware, Cutlery and Housewares Industries Fédération de l´Industrie Européenne des Articles de Cuisine, de Coutellerie et de Ménage Federation of the European Cookware, Cutlery and Housewares Industries (FEC) Feedback on the Draft Implementing Regulation on National Producer Registers under the PPWR Harmonised formats are not enough FEC supports the environmental objectives of the PPWR…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FESI, the Federation of the European Sporting Goods Industry, welcomes the Commissions objective of establishing a harmonised registration and reporting format for packaging producers. A uniform EU approach is essential to prevent fragmentation and reduce administrative burden for companies operating across several Member States. FESI supports weight-based reporting for packaging, as reflected in Annex II.

I've spent the past few years preparing to open a small one-person webshop, selling specialty products produced in Europe, and sold currently by only a couple of shops globally. I have the stock, the VAT number, the web domain, but if this legislation is enforced, I won't be able to start selling.

The following demands are made from the perspective of the small family nursery farm I represent. Such farms represent the majority of the Polish nursery sector, and therefore the provisions of the PPWR should take into account their specificity, scale of activity and limited administrative and technical capacity. 1.

Filed in Polish · English published by the European Commission

As a medium-sized enterprise, we expressly welcome the currently discussed reductions in the implementation of the PPWR. Our practical work on the requirements in different EU Member States shows that there is an urgent need for simplification. The current design of Extended Producer Responsibility (EPR) places significant administrative and financial burdens on cross-border EU trade.

Filed in German · English published by the European Commission

Representation in each country: a structural barrier to intra-European trade For a company of our size, operating in several European countries, the obligation to appoint a tax or legal representative in each Member State is in practice unmanageable.

Filed in Dutch · English published by the European Commission

Independent Retail Europe represents the interests of the independent retail sector. Our membership consists of over 479.000 independent retailers, who manage more than 708.000 sales outlets and employ more than 6.306.000 persons.

We represent a case of a middle-sized business deeply affected by this regulation. Kunst-Auktionshaus WENDL is one of the largest regional auction houses in Germany, located in Thuringia, with 35 years in the business of arts, antiques and collectables within the middle to lower art market sector.

As a retailer established in Austria, I supply customers in several EU Member States. The quantities of packaging I place on the market in each of the target countries are minimal and, in total, well below 10 tonnes per year. In principle, I welcome the aim of the Packaging and Packaging Waste Regulation (PPWR) to transparently record packaging waste across Europe and reduce it in a sustainable manner.

Filed in German · English published by the European Commission

The proposed rules on registration and reporting formats to national packaging registers do not address the significant barriers to cross-border trade within the EU caused by the PPWR as requiring businesses to register and report separately in every Member State would impose substantial administrative and financial burdens, particularly on small and micro-enterprises.

The requirements relating to: Plenipotentiaries in all Member States are hardly represented, even for a medium-sized enterprise, from an administrative and financial point of view. The exemptions should not only apply to micro-enterprises! The added value of requiring both technical documentation and a declaration of conformity should also be questioned. Both have almost identical content.

Filed in German · English published by the European Commission

The proposed rules on registration and reporting formats to national packaging registers do not address the significant barriers to cross-border trade within the EU caused by the PPWR as requiring businesses to register and report separately in every Member State would impose substantial administrative and financial burdens, particularly on small and micro-enterprises.

Dear managing director of a small and medium-sized company in Germany, I am writing to you today with a strong request. With the planned application of the Packaging and Packaging Waste Regulation (PPWR) from 12.8.2026, we are facing considerable additional burdens that threaten our company’s viability. There is an urgent need to adapt the PPWR.

Filed in German · English published by the European Commission

EFPIA and its members support the EUs ambition to advance a circular economy for packaging while safeguarding public health and resilient global supply chains. EFPIA welcomes the timely adoption of the Implementing Act (IA) on national registers of producers under the Packaging and Packaging Waste Regulation (PPWR), but calls for realistic, coherent and sector-specific implementation, particularly regarding Article…

The obligation to draw up a certificate of conformity should be abolished without replacement. This is work for the drawer and does not support the idea of sustainability at all. National proxies must be abolished, instead national systems should be pooled at EU level. This means that only registration in the home country is required.

Filed in German · English published by the European Commission

Danske Kunsthåndværkere & Designere (DKoD) Danish Crafts & Design Association Danske Kunsthåndværkere & Designere welcomes the European Commission's efforts to harmonise registration and reporting requirements for packaging producers across EU Member States. DKoD represents professional craftspeople and designers in Denmark.

The proposed implementation will kill small businesses. For large enterprises the administrative burden of these rules is probably negligible, but for a small business to have to pay hundreds of euro's per country just to register is crippling. That is, if you can even manage to figure out all the different rules in all the different EU countries without killing your business on advisors fees.

The requirement to appoint (and pay for!) a representative in each EU Member State to which packaged products are delivered, who must register with the respective national take-back systems, who reports the quantities of packaging and is generally responsible for compliance with all the rules, represents a disproportionate financial burden for many SMEs, which make intra-Community supplies only occasionally or in…

Filed in German · English published by the European Commission

The Japan Business Council in Europe (JBCE) welcomes the European Commissions initiative to establish harmonised requirements for producer registration and reporting under Article 44 of the Packaging and Packaging Waste Regulation (PPWR). A harmonised framework has the potential to reduce administrative burdens, improve consistency across Member States and strengthen the functioning of the EU Single Market.

DEAR Sir/Madame We understand the need to report the quantities of materials introduced to the market; however, the system should account for the differences between a large enterpriseequipped with administrative and environmental departments as well as specialised IT systemsand a small nursery Employing 11 people.

Filed in Polish · English published by the European Commission

Contribution to the consultation: Packaging and packaging waste Rules on national registers of producers The Zentralverband des Deutschen Bäckerhandwerks e.V. represents around 8700 bakeries with around 232.000 employees in Germany. The predominantly small and medium-sized, often family-run holdings ensure the daily supply of fresh, high-quality and regional bakery products.

Filed in German · English published by the European Commission

Dear Sir/Madam, as a small neighbour of wedding and suite clothing, I would like to express my concern about the potential impact of the new European regulations on textiles, packaging and producers’ responsibility. Let me first stress that I support the objective behind this legislation. The fashion industry needs change and measures that reduce production, throwaway fashion and fast fashion’s huge waste heap.

Filed in Dutch · English published by the European Commission

The Finnish Chemical Industry Federation (Kemianteollisuus KT ry) represents chemical industry companies operating in Finland, from large multinational enterprises to micro-enterprises. Our member companies place on the market a wide range of packaging, e.g. consumer, industrial and transport packaging.

In principle, we support the PPWR’s objectives of preventing waste, conserving resources and promoting sustainable economies. However, in terms of practical implementation, we see room for improvement in the following areas: Clear demarcation of roles, obligations and responsibilities along the supply chain Proportional requirements taking into account the respective size of the company, since the rules are…

Filed in German · English published by the European Commission

Dear EU, I am appalled by the new regulation. This always means cutting red tape, and the new PPWR will create a bureaucratic monster! I fully understand the background of resource conservation and waste prevention.

Filed in German · English published by the European Commission

The Food and Beverage Carton Alliance (FBCA) welcome the opportunity to provide feedback on the draft Implementing Regulation establishing the registration and reporting formats under the Packaging and Packaging Waste Regulation (PPWR), as regards extended producer responsibility (EPR) registration and reporting obligations.

Packaging licensing in other EU countries imposes a significant administrative burden on small and medium-sized enterprises. Especially in the case of small quantities of packaging (e.g. transport packaging for concrete paving blocks), data preparation and registration + authorised representatives are a very heavy burden within the organisation of an SME.

Filed in German · English published by the European Commission

Hello, We have been understanding and supporting the EU’s ambitions on our own initiative for years. However, the implementation/regulation completely ignores a possible implementability for SMEs. We are an advertiser who buys from upstream suppliers. A large proportion of these suppliers source the product from the Far East as an importer.

Filed in German · English published by the European Commission

I have a small business and I would certainly be able to deliver my goods to various EU countries on a case-by-case basis. But the costs of processing (service fees, agent and then the royalties at the top) are disproportionate to the turnover I could make with it. As a small one-woman company, I look forward to receiving a few orders from abroad.

Filed in German · English published by the European Commission

Advisory Board for Finnish PROs appreciates the opportunity to provide a statement on the European Commission's proposal to harmonise parts of extended producer responsibility schemes for packaging in EU countries.

We are a micro-enterprise from North Rhine-Westphalia and sell light felt products to consumers and business customers through our own online shops. We only supply Germany. We have examined shipments to other EU Member States and deliberately decided not to do so.

Filed in German · English published by the European Commission

Ladies and gentlemen of the European Commission, I would like to submit to you a simple and concrete proposal that could provide immediate relief to a very large number of small businesses in the EU without having to change the basic objectives of the PPWR: Exempt mini-items in envelopes and shipping bags from the relevant packaging requirements.

Filed in German · English published by the European Commission

We fully understand the objective pursued by the European Union through the PPWR rules: reducing packaging waste, promoting recycling and making businesses more responsible. In principle, this is legitimate and necessary. However, its current implementation seems to us to be totally disconnected from the everyday reality of European SMEs, very small businesses and craftsmen.

Filed in French · English published by the European Commission

The proposal to use PPWR Technical Documentation (TD) for producer registration and reporting is not foreseen under the PPWR. It would also create an unnecessary and disproportionate administrative burden for businesses. Requiring companies to submit TDs for reporting purposes would create significant practical challenges, including new data flows, adaptations to reporting systems, and higher compliance costs.

Amazon welcomes the Commissions draft Implementing Regulation under PPWR Article 44(14) and its objective of harmonizing registration and reporting across Member States. A functioning Single Market for packaging depends on producers being able to register once, report consistently, and meet their EPR obligations without navigating 27 divergent national systems.

The European Paper Packaging Alliance (EPPA) is a non-profit association representing 12 European companies across the food and foodservice fibre-based packaging value chain, from material suppliers and converters to packaging users. EPPA promotes sustainable packaging solutions and supports Europes transition towards a circular and climate-neutral economy, grounded in scientific evidence.

As an artisanal company from Germany, I am writing to you today with a strong request. With the planned application of the Packaging and Packaging Waste Regulation (PPWR) from 12.8.2026, we are facing considerable additional burdens that pose major practical challenges for my company. There is an urgent need to make the PPWR more practical in key areas.

Filed in German · English published by the European Commission

MY OPINION: Joanna Moja nursery is a small family-owned enterprise where we produce ornamental plants on an area of approximately 7.5 ha together with our daughters and 7 employees. At the outset, I would point out that, in the case of plant production, the pot is not packaging, but part of production technology, often reusable.

Filed in Polish · English published by the European Commission

Free model letter Last chance for small traders: The EU intends to submit feedback on the PPWR 13.8.2026 13.8.2026 approx. 4 min. KI now complains to the European Commission. We provide a template free of charge. Table of contents The European Commission is currently collecting feedback on the planned requirements for the national producer registers under the PPWR.

Filed in German · English published by the European Commission

The PPWR must not create new administrative barriers within the European market. Media object companies work with several European countries on a daily basis. The obligation to appoint a representative and to carry out specific procedures in each Member State creates a significant administrative and financial burden, particularly for SMEs.

Filed in French · English published by the European Commission

I represent the nursery of Clematis rodło Dobrych nurse Sp. z o.o. Sp.k. Our company has existed for 38 years. We are a recognised producer of garden plant seedlings, and in particular: wardrobes, climbing, perennials, grasses, ornamental and fruit shrubs. We sell our cuttings to almost all EU countries. Our company employs 34 people and employs dozens more on a seasonal basis.

Filed in Polish · English published by the European Commission

I appreciate the effort towards more sustainable packaging solutions, less packaging and the idea that the responsibility of packaging is with the business who sends it along. BUT. The fact that there is no exception for small businesses, no threshold regarding the amount of packaging sent into eacht country or regarding yearly revenues is ruinous for the integrated European market and the network of small european…

Draft Consultation Response from DMF Consultation Response on the Draft Implementing Regulation Establishing Formats for Producer Registration and Reporting under PPWR About DMF The retailer Environmental Forum (DMF) is a cross-industry collaboration platform representing the Norwegian retailer sector and its value chain and are owned by the 3 retailers in Norway.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ladies and gentlemen, in principle, we support the European Union’s objective of reducing packaging waste, improving the recyclability of packaging and using resources more sustainably. However, we are very concerned about the practical implementation of the Packaging and Packaging Waste Regulation (PPWR).

Filed in German · English published by the European Commission

It is unacceptable to us that the bureaucratic burden will be significantly increased once and for all. Reporting the volume of imports in each individual EU country, and in addition via authorised representatives in the respective country, is far too burdensome and costly for small to medium-sized enterprises. Why is it not checked for practicability for small businesses? There is an EU rule for this.

Filed in German · English published by the European Commission

Stellungnahme des BHT zur Europäischen Verpackungsverordnung Ref. Ares(2026)8570836 - 09/09/2026 Verpackte Bürokratie Wie die PPWR das Verpackungsaufkommen (vermeintlich) reduziert und die Bürokratie vervielfacht Der Bayerische Handwerkstag e.V.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The VCI supports harmonised, digital and interoperable producer registers. However, the draft should be revised to ensure that the reporting framework is proportionate and workable. The VCIs key requests are: - Reduce and cluster the detailed plastic reporting categories to the level demonstrably necessary for PPWR monitoring.

Hello, as a micro-company, I understand the usefulness of these new rules on a large scale. But their application as it stands puts us, very small craftsmen and creators, in great difficulty, adding additional burdens to those already weighing heavily on our precarious activities. In order to take account of these issues, the rules need to be amended for the future of our activities.

Filed in French · English published by the European Commission

PHOENIX remains supportive of the overall objectives of PPWR and welcomes further dialogue on practical implementation requirements for the Extended Producer Responsibility (EPR) process. The proposed reporting requirements depend on the availability of detailed packaging data that is often held by suppliers and contract manufacturers.

We are a larger tree nursery within the tree nursery (± 80 FTE), but still have a limited number of employees, most of whom work in and on the nursery. In order to implement this scheme within the tree nursery in general and within our organisation, this requires additional work to be done. In the current economic climate, this is unaffordable for businesses.

Filed in Dutch · English published by the European Commission

We are a small German B2B company and import individually manufactured promotional items that we deliver to dealers and resellers in Germany and other EU Member States. In principle, we welcome the fact that the requirements for national producer registers are to be standardised and digitalised.

Filed in German · English published by the European Commission

Subject: Practical implications of the PPWR for small businesses in cross-border e-commerce Dear Sir/Madam, I strongly support the PPWR’s objectives of reducing packaging waste and promoting recycling. However, from the point of view of small online sales, I see significant challenges in implementing EPR.

Filed in German · English published by the European Commission

Dear Sir/Madam, Thank you for sharing the information regarding the public consultation on the proposed implementing rules for the registration and reporting of producers under the Packaging and Packaging Waste Regulation (PPWR).

Feedback on national producer registers: The impact on a micro-enterprise I am a self-employed craftsperson and shopowner based in Denmark. I sell my products in very small quantities directly to customers in other EU Member States. I fully support the environmental objectives of the Packaging and Packaging Waste Regulation.

Serving Europe is grateful for the opportunity to contribute to the European Commissions consultation on the draft Implementing Regulation establishing harmonised rules for producer registration and reporting under the Packaging and Packaging Waste Regulation (PPWR).

We fully support the goal of reducing plastic packaging and packaging waste. However, the current requirements place a disproportionate burden on small and micro-enterprises, particularly those already using environmentally friendly paper-based packaging.

I am a small Dutch trader who sells directly from the Netherlands to consumers in Belgium. This concerns a maximum of approximately 30 kg of packages per year. Since 12 August 2026, I have had to comply with the new PPWR/EPR obligations.

Filed in Dutch · English published by the European Commission

FEPEX shares the European Commission’s objective of harmonising registration and reporting requirements for packaging producers under PPWR for all Member States, contributing to greater transparency and the correct implementation of Extended Producer Responsibility (EPR).

Filed in Spanish · English published by the European Commission

The PPWR must not create new administrative barriers within the European market. Media object companies work with several European countries on a daily basis. The obligation to appoint a representative and to carry out specific procedures in each Member State creates a significant administrative and financial burden, particularly for SMEs.

Filed in French · English published by the European Commission

The PPWR must not lead to the creation of new administrative burdens in the European market. Media companies collaborate with many European countries every day. The obligation to appoint a representative and to carry out separate procedures in each Member State represents a significant administrative and financial burden, particularly for SMEs.

Filed in French · English published by the European Commission

As the Chamber of Crafts in Dresden, we represent the interests of some 21.000 Saxon craft businesses, which mainly operate as small and micro-enterprises. The core business for their products and services is mostly in the region. However, because of the individual nature of craft products and services, and not least because of our geographical proximity to two other EU Member States, there is also foreign demand.

Filed in German · English published by the European Commission

Hello, the usefulness of packaging does not have to be demonstrated: in the majority of cases, it is necessary to protect a product during storage, transport and delivery. I run a French SME of 25 people and also represents a central purchasing and import centre bringing together French media companies, i.e. around 260 employees.

Filed in French · English published by the European Commission

The European single market must remain accessible to small suppliers too! The objectives of the new EU Packaging Regulation are in principle to be welcomed: The aim is to reduce packaging waste, improve recycling and allow producers a fair share of the cost of disposal.

Filed in German · English published by the European Commission

We're just a couple artists selling stickers or an occasional bandana. We don't have the facilities to file paperwork in Europe and barely have enough sales currently to make doing business in Europe worth the effort. Adding on regulation will force us to stop selling to Europe. We don't have anyone in the EU to "represent" us and couldn't pay them if we did.