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EU consultation

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

2973 submissions from 2734 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.

The Commission received 7,133 submissions on this file. Shown here: the 2,973 from organizations. Not shown: 3,848 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 312 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →

Who showed up

2843 submissions from industry (companies and their trade associations) against 22 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 129.2 industry submissions for every one from civil society.

Industry 2843Civil society 22Public authorities, academia, other 97

Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations: a body that filed twice is counted twice. An identical text filed by several organizations counts once: 11 submissions here repeat 8 texts word for word and are folded into them.

What the room declares

109 of 2734
in the EU Register
341
full-time lobbying staff
€53.1M+
declared costs a year
204
EP accreditations declared

Self-declared to the EU Transparency Register (snapshot 14 Oct 2026). The cost figure sums band floors, so the true total is higher.

The file, right now

The consultation closed on 10 Sept 2026; it ran from 6 Aug 2026.

Policy area
Sustainability (DG ENV)
Where it stands
Awaiting adoption
Adoption expected
31 Mar 2026

How it got here

  1. Draft implementing regulation10 Sept 2026

Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.

Filed word for word by several organizations

2 blocks of text on this file were submitted, identically, by three or more organizations. Shared text is a fact about the filings; what it means is for the reader.

4 organizations: Adatele, Launil, Puru, UAB Sodo nuotaika

“The current packaging rules place a disproportionate burden on micro-businesses. Many of us are one-person businesses receiving only a few orders per year from each EU country. Requiring separate registrations, fees, reporting and potentially representatives in every Member State makes no financial or practical sense. In some countries, compliance may cost more than the total value of our annual sales there.”

3 organizations: AVENIR COMMUNICATION SAS, DELTA, GOODIE-D

“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.”

Showing 25 of 250 submissions on this page · page 10 of 12 · 2,973 across the file. Search the whole file

CP

Cherry Picking GmbH

· · filed 11 Aug 2026 · source

Ladies and gentlemen, I am writing to you as an artist and designer, as a solo self-employed person and as an operator of a small independent creative company. I do not work with bulk goods with limited editors and small print runs. My products are created with a lot of personal work. I am committed to sustainability, recycling and responsibility.

Filed in German · English published by the European Commission

LinkedInX
KC

Kaamos Company Oy

· · filed 11 Aug 2026 · source

Hi! As a small business owner and mother of young children, designing and producing products for a very niche audience, I greatly depend not only on my local market but also on customers across the EU. It is devastating to read about these new national registration requirements, as there is simply no way I have the time, resources or money to fulfil separate obligations in every EU country just to keep selling…

LinkedInX
F

Firma

· · filed 11 Aug 2026 · source

Ladies and gentlemen, I am writing to you today as co-owner of a German two-person family business selling online. We run our shop with a lot of personal effort, we routinely also work on Saturdays and Sundays, and we sacrifice all our family time.

Filed in German · English published by the European Commission

LinkedInX
TT

Tres Trilingües Tigres

· · filed 11 Aug 2026 · source

I operate a small handmade business in Germany and sell through an online marketplace. I am currently sending around 20 packages to 5 other EU countries each year. My turnover from these countries is currently below EUR 400. It is foreseeable that the number of EU countries from which orders are received will continue to increase in the future.

Filed in German · English published by the European Commission

LinkedInX
BM

Botter Manufacturing

· · filed 11 Aug 2026 · source

These regulations place a disproportionate burden on small businesses like mine that ship small quantities of packaging within EU member states. Small businesses like mine lack both the financial resources to pay several hundred euros per EU country for registration there and the time to manage the administrative burden of complying with these regulations.

LinkedInX
FA

Fox And Rabbit Art

· · filed 11 Aug 2026 · source

As a micro (one woman) business, the new regulations are a death blow to any business I have and could have outside of my own country, and I know a lot of small business owners who say the same. I do believe in the importance of a European community and making companies responsible for protecting our environment, and I already do my best to be sustainable with my products and packaging alike.

LinkedInX
G

girlstalkvintage

· · filed 11 Aug 2026 · source

I have been running an Etsy shop selling vintage Levis jeans for years and recently fulfilled my dream of launching my own online store. Due to the increasing bureaucratic burden of national EPR registrations, I have already had to stop shipping to several of my highest-revenue EU countries over the past few years. The unified EU-wide solution I had hoped for this August has failed to materialize.

LinkedInX
E

Einzelunternehmen

· · filed 11 Aug 2026 · source

I operate a small handmade business in Austria and sell my products through an online marketplace. To date, I have sent around 150 packages per year to six other EU Member States. The resulting turnover was approximately EUR 12.000 per year. For the required registrations and, depending on the country of destination, authorised representatives/representations, I expect to have to pay EUR 6000 per year.

Filed in German · English published by the European Commission

LinkedInX
HK

HanDok Kaufcenter GmbH

· · filed 11 Aug 2026 · source

To the European Commission / Members of the European Parliament, As a European e-commerce enterprise engaged in importing goods via container and selling them online across the European Union, we are writing to submit a formal objection and express our deep concern regarding the practical implementation and economic impact of the Packaging and Packaging Waste Regulation (PPWR).

LinkedInX
SE

self-employed

· · filed 11 Aug 2026 · source

As a self-employed person, I earn from performing at events and selling small amounts of merch online. For the latter, the order amounts are low, often sent to different EU- and non-EU countries maybe once or twice within a year.

LinkedInX
AT

ATD Trading Ltd.

· · filed 11 Aug 2026 · source

I run a small e-commerce business based in Bulgaria, selling packaged goods to customers across the EU through online marketplaces. I want to share a practical concern about how the proposed harmonisation of national producer registers and reporting obligations affects businesses of my size.

LinkedInX
EK

En Kruka Keramik

· · filed 11 Aug 2026 · source

I am a ceramicist, posting my work to a range of EU-countries. I am the sole and only person in my vompany. For each country my annual amount of orders is below 10. Your new rules means that my profit essentially dissappears, as administrative work (researching rules and reporting) and fees per market will exceed what I earn. I support reducing waste and recycling.

LinkedInX
B

Beposie

· · filed 11 Aug 2026 · source

Hi iam just starting my online shop. beposie! beposie is a one-woman brand creating limited-edition products and apperal in small quantities. As a small independent business, I build everything myself, from design to production and fulfilment. 15% of every purchase is donated to meaningful social causes, leaving only a small margin to cover operating costs and growth.

LinkedInX
SN

Selbstständiger Einzelunternehmen

· · filed 11 Aug 2026 · source

Ladies and gentlemen, I very much welcome the fact that the European Union is addressing the issue of packaging and wants to ensure greater sustainability and clear rules across Europe. At the same time, I would like to draw attention to a development which, in my view, is very politically problematic: Increasing bureaucracy can put small online traders at a significant competitive disadvantage.

Filed in German · English published by the European Commission

LinkedInX
O

Other

· · filed 11 Aug 2026 · source

This is disgraceful. We sell sustainable products that mostly derive from the EU we package them in compositible packaging. We have clients in the EU have spent up to six months specifying our products for their customers, taken their money and gone to place an order with us today for us to say Im so sorry we cannot ship to you now. All of the EU and Ireland.

LinkedInX
JL

Jaimy Louise Reisinger

· · filed 11 Aug 2026 · source

I strongly support the environmental objectives of the Packaging and Packaging Waste Regulation. However, I urge the European Commission to introduce a clear and meaningful exemption or substantially simplified regime for micro-enterprises and very small businesses. I am a self-employed small business owner in Austria and also operate a small jewellery business.

LinkedInX
VK

Vastaskalda Kiisk Oü

· · filed 11 Aug 2026 · source

Dear Members of the European Commission,I am writing to you as an independent sole trader running a small design and handicraft business, SolveCoagula design, based in Estonia. While I fully support the European Union's green transition, its circular economy goals, and the intent to curb mass-produced low-cost imports from outside the EU, the current execution of Extended Producer Responsibility (EPR) and the…

LinkedInX
SB

Small Business

· · filed 11 Aug 2026 · source

*exclude small & micro businesses from the A.R. rules or provide measurements that small businesses can afford! *harmonize the registration for PPWR/EPR in EU states for small& micro businesses! *the new law speaks against the free movement of goods within the EU and will have severe consequences for many businesses- especially small ones!

LinkedInX
QO

Quaintrelle of Sweden

· · filed 11 Aug 2026 · source

I run a production-on-demand lingerie business from my studio in Stockholm. I want to be part of a positive change of the fashion industry, but the current implementation of the PPWR and the EPR is making it impossible for me to sell across internal EU borders. This implementation is hurting small businesses disproportionately, and you should implement a de minimus immediately while working towards a One Stop Shop.

LinkedInX
I

ItsNato

· · filed 11 Aug 2026 · source

I am a self-employed artist and run a small business within the EU, through which I sell my own artworks and merchandise. I expressly support the environmental objectives behind these rules. Companies should take responsibility for the packaging waste they generate. Large companies in particular, which place huge amounts of packaging on the market, should be held responsible for this.

Filed in German · English published by the European Commission

LinkedInX
DF

Die freche Göre

· · filed 11 Aug 2026 · source

As a one-woman small business based in Germany, I am deeply concerned about the practical impact of the new PPWR and EPR requirements on micro-enterprises and small businesses selling products within the EU. The regulations are extremely difficult to understand and navigate, especially for businesses that do not have legal departments, compliance teams or the financial resources to hire consultants.

LinkedInX
MA

Makli ApS

· · filed 11 Aug 2026 · source

I am the founder of an EU marketplace for handmade goods. I write both as a producer subject to Article 45 and as an operator whose sellers are micro-producers across the EU. I support the overall harmonising of the producer registers and the objective of the PPWR.

LinkedInX
RL

Record Label

· · filed 11 Aug 2026 · source

Hello I have a small one Man Business for over 30 years. For me this regulation means that I have to stop all selling/shipping outside of Germany. I cannot pay the fees that will appear for this as it is more costs then I gain. Also the more work for me is something I cannot do as a One Man Business. This is killing my business. And as I read on social Media many mamy more have this problem. Please stop this now!

LinkedInX
MM

Mani macrame

· · filed 11 Aug 2026 · source

I am a one woman selfemployed artisan in Spain running a small online business selling my handmade macramé jewelry. I already use recycled and recyclable packaging materials and keep my packaging to a minimum. I support the environmental goals of the PPWR, but in its current form it will severely harm micro and small businesses like mine.

LinkedInX
EC

E commerce

· · filed 11 Aug 2026 · source

As a micro business owner this new regulations is absurd. This will hit all the small business hard and for meny to close down. I understand that the environment is important, but it is most the big companies that produce waste not the small micro business.

LinkedInX
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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed”. You read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.