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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 Also not shown: 312 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their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 11 of 12 · 2,973 across the file. Search the whole file

IA

Independent artist - business owner

· · filed 10 Aug 2026 · source

I am a French artist-author running a very small micro-business. I sell original paintings and art prints online to customers in different EU Member States and outside the EU. I fully support the objectives of the PPWR, including reducing unnecessary packaging, limiting empty space and improving recycling. My shipments already use packaging adapted to the size of the artwork, with very little or no empty space.

LinkedInX
PP

Prelo Prints

· · filed 10 Aug 2026 · source

These new rules risk placing a disproportionate administrative and financial burden on thousands of small businesses across Europe, particularly in the creative, artistic and handicraft sectors. Many of these businesses are microenterprises, often operated by a single person who is responsible for every aspect of the business: creating the products, production, marketing, sales, accounting, customer service…

LinkedInX
LP

Le Petit Apothicaire du JDR

· · filed 10 Aug 2026 · source

Hello, I am an artist/author and sometimes I sell my works with appropriate packaging, which I send all over Europe and sometimes outside Europe. For the time being, I have not generated any profit from these sales. I try to amortise the costs of setting up a “business”, knowing that they accumulate every year (need raw materials, repair my equipment, etc.).

Filed in French · English published by the European Commission

LinkedInX
A

artist

· · filed 10 Aug 2026 · source

Unfortunately, this new law on packaging is missing out on my goal! It disproportionately affects small businesses and makes it impossible for them to sell their products in the EU. As an artist, I bear the same costs as Amazon, OTTO, Zalando and CO, which are responsible for this huge package effort and free returns! My pictures are packed and sent 1x wisely, that’s what it was.

Filed in German · English published by the European Commission

LinkedInX
ES

ETSY Shop

· · filed 10 Aug 2026 · source

I totally understand the need of such a regulation as it is a lot of waste. However, the burden admin and cost for small business is just not possible. This will be killing any small business trying to have a living sending few item into Europe. Small business should be exempted of this regulation. They already try their best to be cost efficient, using smallest parcel as possible and with recycle material in mind.

LinkedInX
A

Anonymous

· · filed 10 Aug 2026 · source

I oppose the current approach to cross-border EPR compliance for small and medium-sized businesses. I run a small business that ships parcels across Europe. We fully accept that businesses should contribute to the costs of recycling and packaging waste. The problem is not the contribution itself, but the way it is being implemented.

LinkedInX
UT

Up the Wazoo Apparel

· · filed 10 Aug 2026 · source

This regulation risks turning the EU internal market into a market where millions of micro-businesses can realistically sell only in their own country. A one-person business might make 30,000 a year, pay all its expenses and barely pay itself a living wage.

LinkedInX
T

tjuub

· · filed 10 Aug 2026 · source

I operate pocket-manufacturing in Germany and sell through an online marketplace. I send 100 parcels per year to 10 other EU countries. My turnover from these countries is EUR 8900. I expect to pay EUR 3400 per year for registration and authorised representatives in these countries. Because the fixed costs exceed the profit from my foreign turnover, I have completely stopped shipping to other EU countries.

Filed in German · English published by the European Commission

LinkedInX
FS

Freyja's Faëries

· · filed 10 Aug 2026 · source

I am a micro-entrepreneur in France and I manufacture and sell homemade jewellery in very small quantities. I understand and share the objectives of the PPWR: reduce unnecessary packaging, improve its recyclability and empower businesses. But when I sought to understand my obligations, I was faced with regulation that was difficult for a very small business to understand.

Filed in French · English published by the European Commission

LinkedInX
HN

Händisch-Design

· · filed 10 Aug 2026 · source

I have been a sole trader since 2009 and I have been self-employed in online sales with my own productions in the sector of sewing accessories. The packaging laws of recent years had already prevented me from supplying many of the EU countries (e.g.

Filed in German · English published by the European Commission

LinkedInX
RS

Ruin Services

· · filed 10 Aug 2026 · source

I support the European Commissions objective of harmonising Extended Producer Responsibility (EPR) requirements across the EU. However, as a very small independent manufacturer selling products directly to customers across Europe, I am concerned that EPR compliance can still create a disproportionate administrative and financial burden for micro-enterprises.

LinkedInX
AF

Anna Falk (WAM)

· · filed 10 Aug 2026 · source

The regulation as it stands right now puts small and micro EU businesses at a significant disadvantage and is not compatible with the freedom of movement of goods within the EU. A minimum threshold for registration and AR obligations, as well as a harmonisation of fees and processes needs to be implemented ASAP. Ideally, registration would be harmonised at an EU level similar to the OSS-system for VAT.

LinkedInX
P

Pepino

· · filed 10 Aug 2026 · source

Hello, my name is Patricia and I run my own small business of handmade polymer clay art in Portugal. I've been building my online business over the past 4 years and it has become my full time job 3 years ago. My customer base is 100% EU based. I regularly ship to multiple EU countries. I work completely alone. The new regulations mean for me that I have to close my business completely.

LinkedInX
KG

Karlsson Grafiske

· · filed 10 Aug 2026 · source

I am a Swedish citizen with sole proprietorship in Norway. Though Norway is not technically part of the EU, they follow almost all regulations put in place. If Norway is considered a country outside of EU for this regulation, then this will negatively impact me regardless.

LinkedInX
N

nussmart

· · filed 10 Aug 2026 · source

As the owner of a small online shop, I am writing to draw your attention to the disproportionate impact of the EU Packaging Regulation (PPWR, Regulation (EU) 2025/40) on micro-entrepreneurs like me. 1. As a micro-enterprise without a legal department, I cannot afford an authorised representative required for distribution to other EU Member States.

Filed in German · English published by the European Commission

LinkedInX
IA

independent artist

· · filed 10 Aug 2026 · source

How are any micro/small businesses/organizations be able to work with all the legal obligations on reporting all of the required documents? The packaging waste limits are defined in above and below tons, and that is towards massive companies who can play by the rules for having enough money for it already. It's not a problem for them, but everyone who works in a lot smaller scale it becomes a full stop.

LinkedInX
CS

Carley S. illustration

· · filed 10 Aug 2026 · source

Making small businesses pay nearly 7k a year in processing fees for recycling is nonsensical and goes against what the EU is trying to do in regulating waste. Small businesses have been struggling since COVID to get back up on their feet. I propose having one unified fee for extremely small micro businesses and larger ones for larges businesses that can simply soak up that fee.

LinkedInX
OT

Only the Sun Knows Records

· · filed 10 Aug 2026 · source

Feedback on the rules on national producer registers (PPWR) Threat to the existence of micro-enterprises in cross-border cultural trade. As owner-run, independent record and merchandise dealers and concert organisers from Germany, I would like to express my urgent concerns about the current implementation of Extended Producer Responsibility (EPR) under the PPWR.

Filed in German · English published by the European Commission

LinkedInX
JM

Just Margo

· · filed 10 Aug 2026 · source

I am a one-woman independent fashion business based in Germany, and the EU is my main market. I do everything myself, I have no legal, compliance or logistics department to handle complex regulations in every Member State. The new PPWR/EPR requirements would not only mean registration fees in multiple countries, but having to appoint a representative in every EU country I sell to.

LinkedInX
NR

Not Regular Coffee (Stefanny Lizeth Ariza Effer)

· · filed 10 Aug 2026 · source

I recently founded a small coffee e-commerce business in Austria, and I would like to provide feedback on the implementation of Extended Producer Responsibility (EPR) requirements from the perspective of a new micro-enterprise. First, I would like to acknowledge the positive intention behind EPR legislation aiming to ensuring that environmental costs are accounted for.

LinkedInX
ZS

ZENAE,s.r.o.

· · filed 10 Aug 2026 · source

Feedback submitted on behalf of ZENAE s.r.o., a small ceramics studio in Bratislava, Slovakia (micro-enterprise, founder-run). I fully support the environmental objectives of the PPWR and of extended producer responsibility. My studio was founded on sustainability and responsible craftsmanship handmade ceramics, minimal packaging, local production.

LinkedInX
SB

Small Business

· · filed 10 Aug 2026 · source

As the operator of a passionately run small online shop for action figures, I must urgently warn against the devastating impact of the Packaging and Packaging Waste Regulation (PPWR). For small merchants who have built their customer base through years of hard work, this regulation is practically impossible to implement and threatens our very existence.

LinkedInX
LS

Liliana silva artist

· · filed 10 Aug 2026 · source

I am an independent artist and designer based in Portugal, running a small business producing handmade, limited-edition ceramic works. I sell my pieces both directly and through international platforms, including to customers in other EU countries. I fully support the EU's environmental objectives and the reduction of packaging waste.

LinkedInX
BE

Bleichstein & Entenfellner GbR - Künstlerduo sneallycool

· · filed 10 Aug 2026 · source

Dear European Commission, I am an independent artist running a small handcrafted business with low product quantities. I am writing to express my concern regarding the proposed rules for national registers of producers under Extended Producer Responsibility (EPR). Many of my friends and colleagues are in the process of closing their online shops, at least for the EU market.

LinkedInX
DD

deichrauch.de

· · filed 10 Aug 2026 · source

As a small undertaking in the secondary sector, it is organisationally and financially impossible for me to meet the requirements of the new Packaging Ordinance. Employing and appointing a packaging agent for each EU country would ruin me. I will therefore stop deliveries to other EU countries from 12.08.26.

Filed in German · English published by the European Commission

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.