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 Also not shown: 312 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their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
Draft implementing regulation10 Sept 2026
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.
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 223 submissions on this page · page 12 of 12 · 2,973 across the file. Search the whole file
I am the owner of a small handmade greeting card business in County Cork, Ireland, selling through Amazon and my own website. I want to share my direct experience with national producer registers to illustrate why the current system creates a disproportionate burden on very small producers. My business places under 200kg of packaging on the market annually, envelopes and protective sleeves for greeting cards.
I'm a small business owner, I'm just a single person trying to make a living, and these rules will entirely cripple my ability to ship to the EU at all. I absolutely understand the reasoning behind the rules, and for large enterprises with entire legal teams and millions of euros in revenue they can comply easily with little impact on their business, but I cannot.
As a Small/Micro business owner, these new regulations are putting all of us in a risky situation where we have to stop shipping within the EU until more is cleared up. This means for a lot of us that we lose 50% or more of our customers due to these new laws.
We strongly oppose the proposed packaging EPR requirements that would force small European businesses to appoint representatives and pay separate fees in every EU Member State where they sell. These requirements disproportionately burden small European businesses and punish small producers while favouring large companies, which have the resources to absorb such costs and administrative burdens.
I am an artist from the Netherlands creating original art, and the fact that I would have to register and pay in all 27 countries makes me stop sending my art to other EU countries. Looking at what other small businesses are deciding, pretty soon only big companies will be sending their products to the EU, small businesses won't.
Dear Sir / Madame I am writing as a small business owner to express serious concerns regarding the practical and financial impact of the current Extended Producer Responsibility (EPR) and packaging regulations. While I fully support environmental sustainability and the need to reduce overall waste, the current execution of these rules places an unsustainable weight on small businesses and directly threatens our…
When I first read the new PPWR, I had hoped that the new rules would bring improvements for small businesses like me. I am very much in favour of reducing and better regulating the packaging waste that the industry generates, because we all live on this planet, but the consequences of this new law are now hitting small businesses so harder and harder to send our goods abroad to the EU.
Filed in German · English published by the European Commission
I fully agree that we have to reduce our packaging and resort to eco friendly packaging. But the way it is now makes it very hard small businesses to ship a singular package to another EU member state. Harmonising the EPR administration is a good first step. But forcing the smaller businesses to have authorised representatives in each country is going to be the death of small businesses.
Its incredibly offensive that the same body approving shipments of weaponry that is being used for ecocide (among other things) is going after micro businesses under the guise of protecting the environment. Truly insidious.
Dear Sir or Madam, As a sole trader and the sole maker behind a small, handmade fashion label, I would like to submit feedback on the planned regulation of national producer registers under the PPWR (Regulation (EU) 2025/40). I make every piece myself, individually tailored for dancers Tribal Cholis for oriental dance, belly dance and tribal fusion.
The PPWR and EPR rules are prohibitive for micro businesses like mine that ship for each of the EU countries in an irregular and small basis, but still need those sales in order to survive. The financial and administrative costs of compliance are too high, and these businesses shouldn't be treated the same way as large corporations that are, themselves, the main responsible ones for most waste!
Hello I am the sole manager of a micro-business in France which is my family's sole income. I sell antique cloth and clothing, so already my business is extremely sustainable, and I only ever ship in cardboard boxed and never use excessive packaging. I am concerned that this bill will impose unfair and very heavy costs on small businesses like mine.
In addition to the enormous time required as a sole trader, the new rules also entail a number of additional costs. I cannot test packaging in laboratories to follow the necessary guidelines as soon as my packaging gets branding from me. I do not have the means to comply with all the provisions as a producer in these cases. I’m branding and don’t produce the packaging at all.
Filed in German · English published by the European Commission
This proposal will severely cripple micro and small businesses, while doing very little to control waste from big companies and polluters. As a small artist, it is already a struggle to compete with the shipping and product prices of big companies and mass-produced goods. A micro business that sends less than 20 packages each month can not justify paying extra fees, while a big company will not be hindered at all.
Dear European Union Committee, I run a small business based in the UK and was workinging towards becoming GPSR compliant, but with the new PPWR regulations, it is simply impossible for me to afford the fees per country to ship my products into the EU, even though my packaging is fully recyclable with no plastic and compliant.
Sorry, however, is absolutely untenable for small businesses! I’m lucky enough to win EUR 200-300 a year! And what you thought about goes beyond my profit! This is not only for me! Many small businesses are in the process of closing their webshops or stop shipping outside their country. Is that really the sense that she is pursuing? Destroying small self-employed people?
Filed in German · English published by the European Commission
Hi! Although the idea behind the regulation makes sense and I support the attempt to better regulate packaging waste, unfortunately I do not think that the idea is complete. While it will not be a major problem for large traders (Amazon and co.), it will be a major obstacle for small traders and sole proprietors to continue shipping within the EU.
Filed in German · English published by the European Commission
While I am highly in support of reducing unnecessary packaging, this new regulation is absurd. I send 1-4 packages a month and all of them are international. My combined total of annual packaging material sent to all destinations is, generously, 10kg. Under these proposed rules, it will simply not be worth my while to continue selling to EU customers.
I'm an artisan painter with a sole proprietorship in Italy. For us small artisans, it's becoming impossible and too expensive to comply with this new law. The packages aren't that numerous, and the cost is disproportionate. It seems like it was created for large companies and can't be suitable for everyone. You're forcing us to close because the costs would be too high.
Dear European Commission, I am writing to submit feedback on the proposed PPWR and EPR regulations, with particular concern for their impact on small and micro businesses across the EU. I would like to highlight the following points for consideration: 1. Exemptions for small and micro businesses The current A.R rule places a disproportionate burden on micro businesses.
Like many other micro business owners these laws will heavily impact my business and my ability to send packages to customers around Europe. As micro business owners we understand that ecological materials are important, we understand that climate change affects us all and recycling costs money.
In my opinion, this law is the death penalty for many small businesses, which cannot afford to have one authorised representative per EU Member State at around 300 and therefore have to stop shipping to the EU. From an economic point of view, this cannot make sense, especially after/in a time of crisis, when many are starting anew, trying out things or, in addition to the main job, wanting or having to provide…
Filed in German · English published by the European Commission
The new rules that force EVERY business to register as producer of waste in every country in EU separately is a death blow to micro, small and medium business. No one who has small business poses resources (time and money) to comply with these rules. Often the amount of goods sold would not cover the fees that some countries require to pay, not to mention having representation.
As the owner of a very small handmade business in the Netherlands, I am very concerned about the impact of the PPWR requirements on microbusinesses selling to customers across the EU. I fully support the goal of reducing packaging waste. I already minimise packaging by using appropriately sized boxes and only the protective materials necessary to ship my handmade products safely.
- please excempt small businesses from having an AR, because its a disproportionate measure towards us. We cannot justify the costs. - Please harmonise the registration or exempt us from registration, because its a disproportionate burden on small businesses. We cannot afford to hire someone to do it for us, so we would have to do it ourselves - this goes against the movement of goods.
That law seems to me to be quite complex to understand and set up as a quartite auto-entrepreneur and therefore does not have a dedicated service to occupy her. The requirements are very different in the different EU countries: — different fees for each country ranging from simple to quadruple – whether or not there is a need for a country with exorbitant costs for barely profitable micro enterprises – a platform…
Filed in French · English published by the European Commission
The current version of the regulation is completely ill-considered and only leads to the destruction of the internal market. The (extreme!) majority of the EU’s registered companies are small and medium-sized enterprises, followed by self-employed artists. None of these businesses can afford to pay thousands of euros per year just to be able to send 10 parcels per year to some countries.
Filed in German · English published by the European Commission
I am responding as the owner and sole maker behind Journey Through Jewellery, a one-person independent jewellery business in the UK. I strongly oppose regulations that place completely disproportionate administrative and financial burdens on microbusinesses simply for wanting to sell a small number of products to EU customers. Journey Through Jewellery is not a corporation.
Practical check not achieved: Disproportionate fixed costs stop small businesses and the internal market As the owner of a small online shop, I fully support the objectives of environmental protection. However, the current implementation of the EPR requirements is simply no longer financially and organisationally viable for small businesses.
Filed in German · English published by the European Commission
I run a small bookbinding workshop in Germany (Kleinunternehmen, founded in 2025). I sell handmade books and stationery directly to end consumers, mostly within Germany, with occasional orders (roughly one or two per month) to other EU member states. Under Article 45 PPWR, from 12 August 2026 I would need to appoint an authorised representative in every EU member state I ship to, regardless of order volume.
These rules will make cross-border trade impossible for micro-businesses. As a small independent creator, having to use 27 different EPR systems, registrations, and reporting requirements (on top of other national flat fees) is completely disproportionate. Large companies can maybe take this financial and administrative burden but micro-businesses cannot.
This will kill a LOT of small businesses (1-2 persons) since we dont have the resources and capital to have a representative in every country. I am all for circularity and recycling, Im a slow Fashion designer based in Stockholm Sweden and make all of my clothes and accessories using recycled materials so I think we should all recycled the packaging but this law is sending small businesses down the drain.
Ladies and gentlemen, as a smaller online trader, I am writing to you with urgent concerns. The current design of the packaging rules and the national producer registers (EPR) is completely damaging to small businesses and destroys intra-European trade.
Filed in German · English published by the European Commission
The new regulations massively harm small business owners and, in turn, the exchange of ideas, culture and unique products which the EU claims to value. The admin work and money needed to apply for licensing in every EU country are massive compared to the financial resources small businesses have available and countless owners are facing dips in sales which, although small compared to The Global Economy , make a big…
Small and micro businesses globally are urging you to adjust the new AR regulations, as the expectation to register in 27 different EU-states is an unrealistic bureaucratic and financial burden that will force independent businesses to leave the EU market.
As a small, independent web shop (House of Bones) sending to the whole EU, we consider the current PPWR/EPR requirements to be totally disproportionate to our size. The problem lies in the stack: for each EU country in which we do not have an establishment, we not only need to register separately (with LUCID, Verpact, Citeo, etc.), but in most cases also appoint a local authorised representative, a mandatory, paid…
Filed in Dutch · English published by the European Commission
This scheme is equivalent to the complete destruction of every small entrepreneur in Europe. And from that perspective, I provide feedback. I understand that, thanks to Chinese webshops, we need to do something in Europe, and I also understand that we need to do something about reducing waste in general, but this arrangement is not working. As a webshop, we send vinyl sheets to our customers in Europe.
Filed in Dutch · English published by the European Commission
I agree with recycling and the use of certain materials for shipping packages, but I strongly disagree with the registration system. As a freelancer who ships only a minimal number of packages per year, I find this regulation deeply troubling.
I operate a very small mail-order business in Germany. We are not a large retailer, we do not have a legal department, a compliance team or dedicated staff dealing with regulatory requirements. We ship fewer than 1,000 parcels per year.
The implementation of Extended Producer Responsibility (EPR) under the PPWR is a disaster and actively destroying micro and small enterprises across Europe for nothing. While cutting packaging waste is important, requiring a small business to appoint a costly Authorized Representative (AR) and register separately in 27 Member States is absurd.
There is an urgent need for you to adapt this new regulation for micro-enterprises and craftsmen! We are millions that you don't think about and that will be overwhelmed by new procedures that are too costly financially and administratively. No to these rules as they stand: micro-enterprises should be exempt! Personally, as a craftsman, jsend my creations to private individuals mainly in France.
Filed in French · English published by the European Commission
It's not feasible for micro businesses to pay the fees to register in each country, or handle the paperwork/admin. As a micro business of one person, it's not feasible. I'm based in the UK. 10% of my income is from sales to the EU. I already pay an annual fee for an authorised representative to comply with GPSR, and additional fees would not make it worthwhile to sell to the EU.
This law in its current form has created an unsolvable problem for micro-businesses and small businesses across the entire European Union. Because many small entrepreneurs rely on their income for survival this will cause people to seek out ways to evade the law or turn to other means of income, turning to potentially illicit means to solve the problem.
Feedback on the implementing act on national registers of producers (PPWR, Regulation (EU) 2025/40) Dear Commission, I write as a concerned EU citizen and product designer, trained at the Design Academy Eindhoven. I am about to launch an online shop for my own handmade design objects. My company is also building a European alternative to Squarespace.
I strongly support the objectives of reducing packaging waste, increasing recycling and making producers financially responsible for the packaging they place on the market. However, I am deeply concerned about the administrative and financial burden that the current system places on micro-businesses, independent artists, craftspeople and other very small businesses selling across EU borders.
I am writing as a small business owner to express serious concerns regarding the new obligations introduced by the draft Implementing Regulation related to producer registration, annual reporting, and extended producer responsibility for packaging.
I would like to express my great dissatisfaction with the increasing bureaucratic requirements imposed by the PPWR. In principle, I support the objective of reducing packaging waste and improving recycling. However, the way in which those objectives are implemented seems to me to be wholly disproportionate and unrealistic. Small and medium-sized online traders in particular face a huge additional burden.
Filed in German · English published by the European Commission
I support the environmental goals behind these rules. But the proposed national producer registers are a bureaucratic and disproportionate way of achieving them. For large corporations, the additional registration, reporting and compliance costs may be manageable. For small businesses, they can easily make selling to EU customers uneconomical. Many have already announced that they will simply stop selling to the EU.
I can completely understand the need for better rules and regulations regarding packaging and waste and am in full support of that, however, with these rules will have a negative effect on the small businesses, such as myself.
The current approach to the implementation of the Packaging and Packaging Waste Regulation (PPWR) creates a disproportionate administrative and financial burden for micro-businesses and very small producers. In my case, this is essentially a small hobby business. I generate approximately 1 kg of paper packaging per year.
I run a micro-enterprise in Germany. The PPWR is not feasible for me as a micro-enterprise and restricts me to selling only within Germany. It is disproportionate to organise an authorised representative for each country for even small quantities of orders in other EU countries; the costs are not to be borne (I am talking here about gains per year of a few thousand euros).
Filed in German · English published by the European Commission
DEAR Ladies and Gentlemen, We never received such a nonsense law coming from EU. Builds more bureaucracy, strengthens bigger companies and holds smaller companies from selling in the EU. And then we wonder why we get more and more Asian crap on the market and get destroyed. Small businesses will stop selling from 12.08. as it doesnt make any sense anymore. Thanks for nothing!
Filed in German · English published by the European Commission
It is always good to avoid packaging waste and give incentives to make packaging reusable. However, the problem this new regulation and old, already existing ones in that regard, is trying to solve, comes from big companies with thousands of packages. It is only right that they should pay for it. However, this new regulation is breaking the neck of every small business.
The original idea when the EU was founded was to simplify things like trade. The mere fact that almost every EU country deals with this packaging matter in completely different ways and that registration plus, in some cases immense, fees is therefore necessary in each individual country has nothing to do with simplification, but the exact opposite is the case.
Filed in German · English published by the European Commission
As an individual company, which is composed and managed by a single person and which must bear all the resulting costs, without any meaningful protection or right in our country; this law is yet another low blow to the detriment of small entrepreneurs who are trying to survive an environment that is already too hostile from an economic point of view.
Filed in Italian · English published by the European Commission
I support fair recycling contributions, but the current packaging EPR system is disproportionate for small cross-border businesses. A micro-enterprise may sell only a few hundred euros into one EU country while facing hundreds of euros in registration, reporting and compliance costs. The rational result is to stop selling there.
We support the European Unions objectives of reducing packaging waste, conserving resources and establishing a sustainable circular economy. Regulation (EU) 2025/40 (the Packaging and Packaging Waste Regulation PPWR) pursues important environmental objectives that are also supported by small businesses and self-employed entrepreneurs.
I am a micro-entrepreneur in France and I sell vintage clothes, especially to customers in different countries of the European Union. I have just become aware of the new PPWR regulation, not through an official communication, but through other micro-entrepreneurs via TikTok.
Filed in French · English published by the European Commission
I consider the objectives of the PPWR to be, in principle, good. It is important to reduce packaging waste, improve recyclability and ensure that packaging entering the EU market meets common environmental requirements. However, I am very concerned about the administrative and financial burden that Producer Responsibility can impose on small and newly internationalised online shops.
Filed in Finnish · English published by the European Commission
To the European Commission / Members of the European Parliament, I am a small business owner operating in the European Union. I fully support environmental sustainability, waste reduction, and the transition toward a circular economy.
The new Packaging Regulation (PPWR) aims to make packaging more sustainable and protect the environment. This objective has my full support. What I cannot support, however, is the way in which the related obligations are transferred to small businesses. For me as a small company, the PPWR means above all: even more bureaucracy, even more documentation requirements, even more time and extra costs!
Filed in German · English published by the European Commission
To the European Commission, I am writing to formally raise concerns regarding the upcoming Packaging and Packaging Waste Regulation (PPWR), entering into force on 12 August 2026, and specifically its registration and reporting requirements for producers. 1. Disproportionate burden on SMEs This new measure is yet another example of why the EU is losing the economic race and remains stagnant.
I support the EUs goal of reducing packaging waste and developing a circular economy. However, the proposed requirements for Extended Producer Responsibility (EPR) may create a disproportionately large administrative and financial burden for micro-enterprises and sole traders who sell small volumes of goods to other EU countries.
I am a small art business in the UK selling on Etsy if they were to continue these new laws will now mean that my entire business will be at jeopardy as many of my customers are located in Europe. Due to my size and income I cant financially afford to be compliant.
Think about micro-enterprises. This reform is completely disproportionate for the self-employed/micro-enterprises. Most of us do not even win 1000 or 200 per month of online sales. These reforms would simply push us all to stop our activities. It is very important to put an income threshold, for example, or something else that would adapt the reform to the income of each enterprise.
Filed in French · English published by the European Commission
Dear Sirs, The new law for packaging regulation will badly affect micro businesses and artist around Europe. As a self- employed wallpaper designer and artist this puts huge limitations to my ability to sell my physical products across EU countries - this means also my ability to expand my sales and income. Micro businesses will never be able to afford all this administrative work and additional costs.
These new regulations are hurting small businesses, although I assume the intention was completely different. If de minimis rules aren't introduced for creators and artists, we'll continue to be flooded with goods from China. For small brands, being part of the EU and the free market is often a dead end. Often (like mine), these are sole proprietorships whose annual revenue from member states doesn't exceed 20,000.
For small businesses, the requirements of the PPWR with local representatives mean an end to international trade, as the costs (administrative and costs) are not related to turnover. The same applies to WEEE, where the requirements are comparable and therefore only registration in the home country is affordable for small enterprises. In that case, however, international trade is prohibited.
Filed in German · English published by the European Commission
As a micro-business owner and independent artist, I find the current EPR requirements, particularly the obligation to appoint an Authorised Representative (AR) in multiple EU countries, financially and administratively impossible to sustain. My business is extremely small. I may send only a handful of parcels per year to any individual EU country.
I make handmade clothing and sell on Etsy. There is only myself and I make approx 20 k a year, with potentially 2 K coming from the EU. I can not afford a rep in each country. Also the amount of packaging (less than 500g) I am actually producing is never an option on any reporting site. (Lucid/reclay). So what do I do?
As a small creator with a micro business operating from Portugal to the EU only, I am asking the European Comission to consider exempting people like me, especially individual entrepeneurs from having to appoint an authorised representative in every member state, as it is a disporpotionate measure towards small business, as we cannot justify raising our prices to cover this expense.
The new Packaging Regulation is only good for big companies, we are losing sales to small companies because it is not worth sending small quantities of parcels abroad in the EU. We will send in 2026: 2 parcels to Finland, 3 parcels to Sweden, 4 parcels to Ireland, 2 parcels to Italy, 2 parcels to Spain and so on and so on. We now have an authorised representative for Austria, where we send around 50 packages a year.
Filed in German · English published by the European Commission
As a micro businesses in Spain that has been operational just a few months, the implementation of the PPWR regulation in it's current form means we have to shut down within the EU entirely as it is financially and operationally completely unviable.
I welcome the objective of reducing packaging waste and creating uniform rules within the EU. At the same time, the requirements for the registration and reporting of packaging should be more differentiated between large companies and micro/small enterprises.
Filed in German · English published by the European Commission
This responsibility should be on packaging companies! They can easily ensure conformity and mark packaging as appropriate. Putting this burden onto a small business in the UK or EU is ridiculous! Where is the guidance or support?? What about your people of the EU?! Where do they order from now? China only or massive corporate businesses!
I run a small online shop selling plants. I am a micro-seller in the sense of the Regulation: a very small one man business, with a limited number of parcels going abroad each year. Roughly half of my customers live in other EU member states. From 12 August 2026, any trader shipping to another EU country must appoint an authorised representative in each destination country.
As a business owner I find the new regulations to be catastrophic for all small businesses that have an EU clientele. These are my three main concerns: 1) Please exempt us from having an AR because it is a disproportionate burden towards small businesses and we cannot justify those costs.
I would like to start by saying that I think it is a great idea to reduce packaging waste and encourage companies to use more environmentally friendly packaging. However, the design of the law as it stands now is a death stumbling block for micro and small entrepreneurs whose business depends on being able to send consignments within the EU. First, the bureaucratic burden is completely unreasonable.
Filed in Swedish · English published by the European Commission
As the owner of my own micro business shipping out 300-400 boxes per year, I can safely say this ruling would almost be enough to make me stop selling. I make a monthly profit far below minimum wage in my country, I simply cannot afford to hire someone in every EU country I ship to. This would likely cost me almost as much as I make in a year. Please, make an exception for small and micro businesses.
That is completely the wrong approach. We should not be making it even harder for small retailers to ship abroad. Instead, we should focus on the major players such as Temu to ensure that they do not flood our EU countries with huge quantities of cheap goods.
I am a small entrepreneur with a low four-digit annual sales turnover. I send postcards, stickers and art prints, mostly within the EU. With the new rules, I have now stopped shipping to other countries outside Germany – I do not have the time and turnover to pay the costs to register for all countries in order to comply with the packaging rules.
Filed in German · English published by the European Commission
I am in the process of creating a small business here in The Netherlands and planned to have an Etsy shop that would sell my products across Europe and, eventually, North America. Unfortunately, as a nascent company, I cannot afford to register my business in every EU country and running an Etsy shop that only sells to Dutch residents severely limits my business potential.
I am the co-owner of a two-person artist-run business established in Poland. We specialise in hand-painting collectible character figurines and sell our work online to customers across the EU. I fully support Extended Producer Responsibility and believe businesses should pay for the recycling of the packaging they place on the market.
The proposed system of separate national producer registers risks turning environmental compliance into a significant administrative obstacle for European SMEs. Companies selling across the Single Market should not be required to navigate multiple registrations, reporting systems and national procedures for essentially the same obligation.
They kill all small companies! We are also stopping our EU shipping, which we, as a small company for our shop www.wildlifelove.de, have just set up with great effort – even though we are the owner of an internet agency. You do not know how much effort and money you are burning through your ideological requirements, which may only work in theory.
Filed in German · English published by the European Commission
To be very clear: I will have to shutter my 1-person-business as a consequence of these new regulations. Neither the administrative burden nor the cost nor the complexities are feasible for micro-enterprises who spend most of their time producing what they are selling. It is just not possible.
Threshold to Protect EU Single Market, Artisans, and European Manufacturing As an EU-based artisan and micro-business owner selling handcrafted/custom products across borders via e-commerce, I welcome the European Commissions efforts to harmonize national producer registers.
I am a small trader; my main sources of sales are via Etsy and eBay, though I have my own e-commerce shop. About 15-20% of my business is EU, still only about 30 shipments a year, and packaging is already fully recyclable. I managed to navigate GSPR and find a representative who didn't price me out.
Ladies and gentlemen, I design jewellery, manufacture it by hand and sell it via a platform. The same applies to home-made dolls’ miniatures. My annual turnover is only a few thousand euros and my packaging volume for the small recyclable cartons is minimal. So we are talking about a small individual company, without employees.
Filed in German · English published by the European Commission
As a small craft business outside of the EU (we're in the UK, and I *HATE* all the results of Brexit - it wasn't something I voted for), this new legislation is completely unworkable. I have a loyal customer based in the EU, and I have had no choice but to stop shipping altogether. We make small custom made cross stitch kits and sell associated accessories.
I joint the pledge to exempt the small business from this ruling it's disproportionately heavy on us, especially someone like me who is an artisan, works alone and is working in a very niche portion of the market. I process wool and spin and promote Portuguese wool. I also buy from known farmers elsewhere in the EU. Small businnes can't absorb this new legislation, not the costs but also not the administration.
I completely appreciate the sentiment of this legislation, but it's implementation goes against the principles of free trade across the EU. In addition, it's totally crippling for micro businesses, who generally tend to make the most efforts towards sustainability. All this does is eliminate those businesses from the market, and make more space for the big ones who are responsible for the issue in the first place.
I understand the need to regulate corporations and large-scale companies that flood the market with products manufactured outside the EU and create a surplus of packaging waste. What these regulations failed to achieve was establishing exceptions for small businesses who sell products made in the EU and already ship with recyclable shipping materials.
I have had a micro enterprise since 2010, I am a seamen. I do not have an employee. I usually deliver my customers directly, but I increasingly post orders. I have an AC of less than 10.000/an, more frequently between 3 and 5.000/an. How can I pay all the costs of my activity PLUS additional taxes and costs, and survive? Currently, I pay 150/mois.
Filed in French · English published by the European Commission
You will destroy my business. First there were tariff wars with USA. It decreased my sales the the US by 50%. Now you've came up with 3 euro tax for each article bought through Chinese marketplaces. It double the vist of my materials. Now this packaging nonsense. It's small business genocide. It is not how it is supposed to be. Every year makes me poorer and angrier.
I run a small one person webshop in the Netherlands. I post parcels to customers all over the EU, so I count as a producer in every one of those countries, for a few kilos of cardboard and paper each. I don't think it's fair to ask the same reporting from someone this small as from a big company. Reporting for small producers should be one number per material per year.
This new law is important for our bulky management, but the fact that there are no exceptions will kill all mini shops, all artists, small creators, new brands. It will even kill intra-European trade overall. No mini structure can register and pay fees for EACH country concerned. Jsends less than 100 packages per year in mini-envelopes. Why do I find myself at the same level as Amazon, which is flooding the market?
Filed in French · English published by the European Commission
Hello, the new regulation makes it difficult for me to send parcels to other EU countries from now on. I am prepared to pay for a licence, but not as it is. It is difficult, as a small enterprise, to obtain the relevant licences and, above all, agents in the other countries. I therefore have to hire a service (e.g. packaging licence24) which, of course, pays a regular surcharge.
Filed in German · English published by the European Commission
I am submitting this feedback as an independent miniature artist and sole proprietor operating in Germany, with an annual turnover of around 100,000. Under the Packaging and Packaging Waste Regulation (PPWR), cross-border sellers are required to appoint an Authorized Representative in every EU Member State where they sell physical goods.
I've been a small business for 10 years now. With many of my Customers coming from the EU Building relationships and providing wonderful connections through art art and crafting. I am part of the OSS system and I am happily paying taxes.
I am the owner of a small business in Saarland. I have a staff member (part-time). I sell small accessories for dredging to other Drechslers in Europe. My annual turnover last year was just over EUR 100.000. Half of this comes from EU countries, mainly France, Finland and Belgium, but I also occasionally sell to other countries.
Filed in German · English published by the European Commission
I'm Grete Vood, owner of a Dutch based small business called Moonlore. This new law coming into effect will severely impact my ability to run my business. I run a one man business, and I would only send a few packages per year to any of the member states countries. This law makes it so that businesses like me, with very few packages being sent, are treated the same way as large companies like coca cola or nestle.
Subject: Greens comments on the draft implementing regulation under Article 44(14) PPWR On behalf of VeriGreen sp. z o.o., we hereby submit our comments on the draft Commission Implementing Regulation establishing the format for registration in the register of producers and reporting to that register, Ref. Ares(2026)7688068 of 6 August 2026.
Filed in Polish · English published by the European Commission
I absolutely and 100% support the reduction of packaging and introducing a fee for excess waste. However this regulation currently implements a heavy base fee per country with its current requirements, which favors large companies with high revenue.
The new rules coming into force do not take micro businesses or even small businesses that are run by a couple of people into consideration at all. There should be a blanket rule for all countries specifically for small businesses so everyone knows what they need to do to be compliant and affordable options for small businesses who are only putting in a few kg of packaging waste in the entirety of the EU.
I own a micro business; my yearly sales are less than 15 items a year. If small business can not be exempt I will have to shut down due to the major gap in finances I can not cover which will be so for many small business owners. It is totally disproportionate for small business owners as we do not have the funds to simply hire someone. Many business including my own do not make any profit.
I run a small waterless, plastic-free cosmetics business launching in August 2026. There is no plastic anywhere in my packaging, down to the adhesive used to seal the boxes. I am not writing to be excused from reporting, or from paying above a sensible threshold. My packaging enters the waste system and I should finance its recovery. I am writing about what these rules do to the group of businesses I belong to.
I am submitting this feedback as an operator of a German small and medium-sized online shop that has so far also sold goods to consumers in other EU Member States. We expressly support the environmental objectives of the Packaging and Packaging Waste Regulation.
Filed in German · English published by the European Commission
This ruling is abusive on small businesses and favors only Big companies which can afford to pay them and that have their own legal teams to deal with. I though we were already playing reclycing taxes for cardboard and single-use packaging. This will suffocate small businesses and leave only the big fish to home the market.
Hello, I own a small label, DesignE, and cut my clothes here in Germany and sell them around the world through Etsy. In recent years, as a result, I have always grown a bit more and had a turnover of around 13.000 in 2025. As a result of the new directives, I have lost the entire EU market.
Filed in German · English published by the European Commission
Ladies and gentlemen, I am writing to you today as the owner of a micro-enterprise. I would like to draw your attention to the dramatic, unfair and disproportionate impact of the new PPWR Regulation and the increasing number of Extended Producer Responsibility (EPR) levies on micro-enterprises, which often have less than 12.000 annual turnover.
Filed in German · English published by the European Commission
I am a self-employed surface pattern designer in the EU currently researching the possibility of developing and selling small-scale physical products. I do not currently sell these products, and this proposal is making me question whether it is even worth trying. I fully support reducing packaging waste and improving recycling.
I am a sole trader, making and selling my ceramics for 14 years. I might have 5 - 10 European sales per year so this new proposal would not be financially viable. If there was one centralised way to sign up and pay a small fee, I would support the initiative. However, each individual country having separate forms, fees and regulations is too much. A large multinational can hire someone to navigate this.
I am submitting this feedback as an operator of a small German online shop. As a small business, I sell my own 3D-printed products via Etsy and eBay and have so far also supplied consumers in other EU Member States. I support the objective of preventing packaging waste and financing the actual disposal costs in a polluter-pays-friendly manner.
Filed in German · English published by the European Commission
With the new regulations, it will be overly difficult and expensive for small businesses to ship within the European union, while big sellers can cover the fees. It will decrease the market between countries, eliminate handmade products and benefit mass producers and sellers like amazon, shein or temu. Its killing crafts, arts and culture within the EU.
I understand the reason for the amendments and in principle support certain measures being taken here. However, these mostly affect micro and small enterprises very negatively. While for large firms the new costs are easy to bear, micro and small enterprises are excluded from the market. The new costs are so high that no company of this size can afford them.
Filed in German · English published by the European Commission
As a micro business located in Austria I strongly support the goal of reducing packaging waste and improving the sustainability of packaging. However, for us micro businesses, following the new rules is financially and administratively impossible.
A cap on representation fees for micro-enterprises, determined by turnover and/or waste volumes, needs to be added to the PPWR. In addition, a separate model for micro-enterprises is needed, with one registration and one representative covering all Member States. The new PPWR requirements hit small businesses, especially start-ups and solo self-employed, in an extremely unfair way.
Filed in Finnish · English published by the European Commission
the new rules being implemented by the EU, whilst understandable on some level , will simply destroy most small businesses. No small business that is currently living a meagre ad mostly hand to mouth existence has the fiancial capability to comply with these rules and it will simply force many business to either shut down completely or at the very least stop sellig to EU countries. This MUST be reconsidered ..
Dear Member of the European Parliament, I am contacting you today as an independent artist and micro-business owner. I would like to alert you to the dramatic, unfair, and disproportionate consequences of the new PPWR regulation and the multiplication of Extended Producer Responsibility (EPR) taxes on very small businesses (often making less than 12,000 in annual turnover).
This new rule will make it impossible for the smallest businesses to go ahead selling to EU countries. Some one-women businesses like mine live from selling only one piece to each country a year. We live from the possibility to sell to many countries as our offering is a niche offering. Please take out the smallest businesses out of this plan like us Goldsmiths. We will not survive this. Thank you so much
As a small- business (single-origin extra virgin olive oil, family-run, Greece) directly subject to national packaging producer registers under Article 44 of Regulation (EU) 2025/40, we wish to raise concerns about the disproportionate administrative burden this initiative places on very small producers.
Feedback on the PPWR from a one-person artisanal business We fully support the objectives of the Packaging and Packaging Waste Regulation (PPWR) and the need to reduce packaging waste and improve the circularity of packaging in Europe. However, the current regulatory framework places a disproportionate administrative and financial burden on very small businesses and one-person artisanal workshops.
The new rulings are too expensive and complicated for small businesses to comply with. Since hearing about the changes, Ive had to cease trading with the EU altogether which has negatively impacted my business. Because of the soft border with the EU Ive had to cease trading with Northen Ireland too recently (although the new rules there might be more to do with Brexit).
I'm an artist based in France, registered as an Individual Entrepreneur. I work solo, earn about 10k/year, with about 5-10% of my revenue coming from my online shop. Its already incredibly hard to manage a viable shop, with accessible prices, with the inflation and the insane rise of shipping prices. Sending a single letter in my own country often cost at least 2-4, in the EU ?
Hello, Im a micro business owner based in Spain. I dont have employees but my business sustains me and my little family with my husband and toddler. Ive been doing business for almost 6 years now and use only cardboard and paper to pack. Paper envelopes, cardboard little boxes, tissue paper and paper tape. My business is based of stationery productions that are made of paper and are not individually packed.
I am an owner on a one person run textile craft studio, with a very small volume output due to the type of business. While my business experience may be limited, I would expect the EU Commission to run some sort of consultation across the EU block with SMEs to see how the regulation would affect them. I dont believe this has been done and the consequences for many micro and small businesses will be disastrous.
Either trainees have been extinct from a major renewal, or the decision-makers have been bought by Amazon and Co. Otherwise, such an ill-considered reform cannot be explained. Small traders will be completely deprived of the basis for pan-European shipping. Regardless of the additional costs, only EU parliamentarians are likely to have enough time for unnecessary and additional bureaucracy.
Filed in German · English published by the European Commission
This will shut off the EU market for not only my own business but every other micro business in the world. These new rules are absurd for owners myself who maybe send less than 4 orders a year to each eu country We cannot afford this. Being a small business owner is becoming more and more difficult. This will be the death of many of us. Please reconsider
As a small business owner, I understand the importance of recycling packaging, I am already conscious about what I use when I send parcels. I keep boxes I've received from my own purchases to reuse, and try to avoid using plastics in my packaging. However the new regulations and requirements to sign up will cost more than the amount of parcels I actually send in year to each country.
This just kill my bussisnes. Me and my partner begin a small bussisnes of making handmade dice less than one year ago, all was going good, for first time in my life we found a place when I was happy and I can create things for the community around europe.
The power of attorney rule for each individual EU country is financially unaffordable for small and micro-enterprises. The result is that participation in the open market for these small businesses is prevented with a pay-to-play logic. They are actively pushed out of the economy. This is not in line with the basic idea of the European single market.
Filed in German · English published by the European Commission
As a micro-enterprise managing less than 100 orders per year, I would like to alert about several concrete difficulties encountered in the application of the EPR (Producer’s Wider Liability) and PPWR. 1. Impossible multi-country compliance at the scale of a micro-enterprise Selling online within the European Single Market theoretically means registering and contributing to an EPR eco-body in each country of…
Filed in French · English published by the European Commission
The new packaging law is simply a poison for small businesses. With my publisher, I may have 10 to 20 orders per book (a book is published every 2 years) from the EU. I would need to register in three to four countries. The cost and workload for a gain of around 100 is disproportionately high. This means that I have to exclude customers from the EU and can no longer supply them. Is the purpose of the EU?
Filed in German · English published by the European Commission
Feedback from a German micro-enterprise on producer registration and reporting requirements I am the owner of Althausen Werkstatt, a small one-person craft business in Germany. I manufacture handmade wooden products and sell them directly to consumers, mainly through my own online shop and at craft markets.
Subject: PPWR and micro-enterprises: a one-person business withdrawing from 22 member states Dear Member of the European Parliament, I am writing as the owner of a one-person business in Haarlem to give you a concrete example of how the Packaging and Packaging Waste Regulation is working in practice for a micro-enterprise, ahead of the committee vote on the authorised representative provisions.
Statement on the registration obligation for small businesses As a sole trader engaged in cross-border online sales within the EU, I see a structural problem for micro-enterprises in the proposed regulation. The requirement to register separately in each individual Member State creates an administrative and financial burden that is disproportionate to the actual sales volume of many small businesses.
I welcome the EUs environmental objectives under the PPWR. However, I am concerned that the requirements relating to producer registration and producer responsibility may place a disproportionate financial and administrative burden on micro-enterprises and independent small businesses. 1.
How should individual and small businesses still ship within the EU? I sell artistic products worldwide through Etsy. If I now pay an authorised representative and licences for each EU country, I can no longer sell within the EU because no one can afford it.
Filed in German · English published by the European Commission
As a small business owner, the new regulations are actively damaging my business. Up to now, about 20% of customers are outside Germany, but in various countries, with the volume of parcels between 1 to Sweden and 20 to the Netherlands (per year). Since the new regulations call for a representative in every country, plus individual packaging fees per country.
Dear European Commission, I am writing on behalf of Omasi Collection, a small Finnish jewellery business, regarding the implementation of the Packaging and Packaging Waste Regulation (PPWR). We support the environmental objectives of PPWR and believe businesses should take responsibility for the packaging they place on the market.
It seems like artists, craftsmen, small and micro businesses have been forgotten completely when making (and implementing?) these new regulations. I already use mostly upcycled materials for packaging, as I also make my art from upcycled and recycled materials. I cannot afford to be in compliance with these rules, so must stop offering any sales outside my own country.
It is a good thing to enact a law aimed at protecting the environment. However, it is wrong to implement it in a way that makes it impossible for small businesses to participate in trade; this law will force small companies to give up. It is simply not feasible to arrange for a representative in every single country.
This new scheme is designed to protect the environment. But the fact is that this may have a big impact. In our case, individual fighters who, in any case, look as little as possible at the cost of packaging, always use the appropriate carton and, for the most part, thicken already used cartons, which in any case have already been licensed, the new law is a bureaucratic and financial monster which cannot be covered…
Filed in German · English published by the European Commission
Ive run a successful business as an artist selling my screen printed clothing and art prints for 7 years now and ever since the GPSR legislation came in Ive had to stop shipping to the EU entirely. At times I thought about trying to comply but worried about being scammed and then with the packaging laws on top of it, it became completely impractical to even try.
As a small handmade business based in the EU, I am very concerned about the impact of the new EPR requirements, particularly the requirement to appoint an authorised representative in certain countries. For a small business like mine, the cost of hiring an authorised representative can be disproportionately high compared with the very small volume of products we sell to some EU countries.
Statement on the proposed EU legislation Feedback from Christopher Ehlich, Founder of Hofkoenigin.com an online shop for horse, pet, and farm supplies As the founder of a young, small online business, I oppose the proposed legislation in its currently planned form. The legislation imposes significant additional bureaucratic and financial burdens, particularly on small businesses, sole proprietorships, and start-ups.
As a micro-business making handmade products, I am worried that these rules place too much cost on very small sellers. If I sell one item to another EU country for less than 50, my profit may be only a few euros. Yet the compliance costs can be several times higher than both my profit and the total value of the sale. This means I may have to stop selling within the EU altogether.
The EU single market is an illusion of red tape destroying small businesses. It is an absolute joke of what is expected of small businesses here. It is completely disproportionate that, as an Austrian one-person company, I have to go through exactly the same administrative error for national packaging registers as a multi-million dollar group with its own army of lawyers.
Filed in German · English published by the European Commission
The new rules on packaging producers are killing my business, and many, many others. This is not hyperbole. I will not be able to continue as a business under the current format. I am a small business / artist making unique ceramics that I largely sell online in the EU. I cannot sell in my country of residence (Croatia) as there is no market for my style of work.
European Small and Medium Enterprises (SMEs) represent over 99% of businesses in the EU and serve as the backbone of employment and regional economic stability. However, the compounding volume of EU regulatory mandatesspanning ESG reporting, supply chain due diligence, and digital governanceis creating an unsustainable administrative crisis for independent businesses.
I am submitting this feedback as an operator of a very small German online shop that has so far also sold goods to consumers in other EU Member States. We expressly support the environmental objectives of the Packaging and Packaging Waste Regulation.
Filed in German · English published by the European Commission
I am a self employed artist and sole trader in Germany, running a very small online shop for the last 6 years. I fully support the environmental goals behind the PPWR but the way packaging EPR is implemented across different EU countries is making cross border trade unrealistic for small businesses. I have spent days contacting authorities and EPR organizations across the EU.
These rules risk making cross-border trade unaffordable for micro and small businesses. Paying separate registration fees, EPR costs and local representatives in multiple EU countries is simply not realistic for businesses with low sales volumes. Without exemptions or sensible thresholds, small businesses will be forced to restrict where they sell, while large corporations gain an even stronger advantage.
This rule may be manageable for large companies, but it creates a completely disproportionate burden for micro and small businesses. A small EU webshop selling only a handful of orders to customers in another Member State can be required to register separately, join local EPR schemes and, in some countries, appoint and pay for a local authorised representative.
For small and micro business there is still considerable confusion around both our obligations to be entered into a register per member states we ship packaging to and our EPR obligations. Across many member state there is notable variation between not only WHEN and authorized representative is required, but also WHO meets the member states definition of an Authorized representative.
I strongly support the environmental aims of the PPWR and the goal of reducing packaging waste across the EU. However, I am very concerned about the financial and administrative burden the new requirements can place on very small independent businesses. I run a one-person business in the UK and sell relatively small quantities of products to customers in different EU countries.
I support the environmental objectives of Regulation \(EU\) 2025/40 and the principle of producer responsibility. However, I am increasingly concerned that EU regulatory development is moving away from its stated ambition to support SMEs and micro enterprises, and instead is creating a steadily expanding layer of administrative obligations that small actors cannot realistically absorb.
How can big players be subject to the same rules as micro-enterprises and micro-enterprises? We are usually alone, do not have a legal department and have millions in the account. In any case, we are already fighting for our survival and now we are excluding from markets, and in practice from them. I seriously wonder why there is not simply a central body in which licences are issued and reported.
Filed in German · English published by the European Commission
Im disappointed that these rules risk making cross-border trade financially unfeasible for micro-businesses. Small brands selling low volumes may face separate registrations, reporting requirements and compliance costs in multiple EU countries, even when their actual packaging volumes are very small.
This set of rules makes no sense for small businesses. 1. The cost, in money and in time, far exceeds the capacities of one-person businesses. We do not have compliance teams to find, contact, and adapt to every update for every country we wish to ship to. I personally gain less than 10000 a year from my business, and the several additional costs of hiring A.R.
This new regulation has such administrative and fiscal complexity and cost that it makes small artisans unable to comply. The average sale I make is 100. I hand make each item and I might only sell 2000 into the EU market. An order could come from any of the 27 members but the idea of registration for possibly 1 sale in a country is clearly non viable.
I am a tiny business owner in Germany, working alone, selling handmade plushies for adults worldwide through the Etsy marketplace. I can accept roughly 4 orders/month. To avoid packaging costs and to help the environment, I reuse old cardboard boxes I receive from my own online orders for my shipments.
I am a small business owner in Germany. I grew up in the Netherlands, and moved here over 6 years ago. I love the EU, I love what it stands for... and this new PPWR and EPR is destroying exactly that. Back in 1999, when talks about the EU were a thing, and people were informed about it, one of the core values were 'Making trade within the Union easier, so to strengthen eachothers market'.
Stop killing Micro businesses and small art businesses! Last year with step 1 you made me loose sleep several nights of sleep, before I finally called the Danish Environmental authorities. I was then redirected to some private entity that they have outsourced the job to, who then told me I did not need to register, since I use off the shelf recycled cardboard boxes and are way below the threshold.
I have always been a supporter of the European Union. But the new Packaging Regulation removes free trade for almost all smaller companies. What is the meaning of this? — are we ecological? — or have lobbies become global players? — or does the European Union want to buy e-commerce? We will no longer be able to supply the European Union in the future, and the administrative burden and costs are high.
Filed in German · English published by the European Commission
While I support the underlying goal of making producers accountable for packaging waste and encouraging responsible waste management, I believe the proposed rules, in their current form, place a disproportionate and potentially devastating burden on small businesses and independent traders.
Small traders, artists, etc. make the European market impossible due to excessive financial and bureaucratic burdens. It strengthens the giants, consolidates their monopoly position and undermines the diversity of small traders in particular.
Filed in German · English published by the European Commission
Please, this is hurting all small businesses in EU. We could have some minimums amounts of parcels to ship to protect the small brands, or cheaper tax when you are under a certain amount of sales. Or do only one tax that would include every EU country, so we don't have to pay to every single country.
As an owner of a small business in Croatia, after learning about the new rules for packaging waste, I am very concerned for existence of my business and of businesses of my fellow artists, crafters and makers, in Croatia an all around the EU. While I understand the eco friendly idea behind the PPWR and EPR rules, they are simply disproportionate and designed for much bigger business entities.
The Regulation puts smaller traders at a cost-absorbing and unaffordable level of bureaucracy. Through such regulations, they are gradually displacing small traders from the market and opening up Amazon, temu and consortes to further dominance. However, they pay tax on their profits only to a small extent within Europe, so they cut into their own meat. EU citizens and businesses are calling for red tape to be cut.
Filed in German · English published by the European Commission
As a micro-entrepreneur in the second-hand trade, I achieved a total turnover of approximately EUR 30.000 in 2025. Of this amount, around EUR 8000 concerned around 45 consignments in 10 EU Member States. For EPR compliance, I incur fixed costs of at least EUR 350 per country per year, regardless of the actual sales volume.
Filed in German · English published by the European Commission
The Regulation on the PPWR and the authorised representative for each destination country are completely disproportionate and impose an unmistakable flood of bureaucracy on smaller shops. Cross-border trade for these companies will mostly be completely phased out, which should soon be reflected in declining numbers. I am afraid that smaller companies will be cheated. What should this mean?
Filed in German · English published by the European Commission
The new cross border fees and regulations will disproportionately impact small businesses in the EU and elsewhere by placing an undue burden on those businesses and individuals while allowing large corporations to proceed with business as usual. If the point of this legislation is to discriminate against small and individually owned businesses, then it is fulfilling that point.
Ladies and gentlemen, as the operator of a small online shop, I am writing to you with great concern. The current and upcoming Extended Producer Responsibility (EPR) schemes at EU level risk making cross-border small-scale trade impossible for small businesses.While large corporations can complete the complex licensing and reporting procedures through flat-rate budgets, the high fixed costs, different national…
Filed in German · English published by the European Commission
For small and medium-sized enterprises, it is a huge cost explosion to suddenly pay an agent in each country to carry out the simple work they can do themselves. This leads to higher costs, leading to higher prices for the final customer. Less turnover and ultimately less tax revenue in the country. We will no longer send out to other countries and will therefore not generate tax revenue there either.
Filed in German · English published by the European Commission
This law completely annihilates all small businesses in Europe, thus ruining the economy, people's livelihoods, creativity and freedoms. It's a preposterous law to impose upon small businesses. I had a very hard time believing it's even real. It stands against the very purpose of there being an European Union to begin with. Micro entreprises must be made exempt.
Unfortunately, as a small business, we have to say that we are forced to lay off employees if we lose further markets now. Compliance with the complex and country-specific rules on waste management in each EU Member State exceeds our capacity. Many of these rules are only available in English or in the national language and vary widely.
Filed in German · English published by the European Commission
I would like to ask an exemption for small and micro-businesses for the AR and the EPR. It targets us indiscriminately, most of the small businesses in the EU are people that belong to minorities or that are dealing with disabilities, that want to enter the workforce but are not given a chance. Having a small or micro business alleviates the struggle and provides us with income.
Als Kleinstunternehmer empfinde ich die immer umfangreicheren europäischen Vorgaben im Bereich Verpackungen als kaum noch tragbar. Grundsätzlich ist Umweltschutz wichtig und richtig. Aber die Umsetzung darf nicht dazu führen, dass kleine Händler mit denselben bürokratischen Anforderungen konfrontiert werden wie große Unternehmen und internationale Konzerne.
The Packaging Act and the ever-increasing bureaucratic requirements are posing ever-increasing challenges for small online traders in particular. I am concerned that this development will significantly weaken e-commerce in the coming years, particularly affecting small, individual traders.
Filed in German · English published by the European Commission
Packaging Regulations: Bureaucracy Instead of Practical Solutions You really have to ask yourself: Who is actually designing these regulations and did anyone seriously consult small and medium-sized online retailers before creating them? What is technically feasible? What is economically reasonable? What actually works in practice and what is simply unrealistic?
Dear Sir/Madam, The new PPWR is completely unrealistic in its practical implementation for small and medium-sized enterprises. In particular, the obligation to register separately for packaging in each EU Member State and, where appropriate, to pay their own licence and system fees, renders the very objective of the European single market absurd.
Filed in German · English published by the European Commission
Instead of cutting red tape, the EU, with the national registers of producers of packaging, creates even more burdens, costs and complicated individual rules. For small online traders, this simply means that shipping to many other EU countries is no longer worthwhile and must stop. What does this achieve?
Filed in German · English published by the European Commission
We are a small family business. We produce in Germany and have so far been shipping across Europe. By being able to buy our items in any European country, we have so far found customers who became permanent customers after the first test orders. This possibility no longer exists. Our growth prospects are significantly reduced by the new packaging obligations. We simply cannot afford to register in all countries.
Filed in German · English published by the European Commission
I operate a microbusiness established outside the EU and sell small quantities of goods directly to consumers in several EU Member States, including through online marketplaces. I support the principle of Extended Producer Responsibility and believe businesses should contribute fairly to the cost of managing the packaging waste they place on the market. Germany provides a useful example from my own business.
1. Single EU-wide packaging-register portal, modelled on existing OSS/IOSS, REACH and SCIP infrastructure. Member states keep fee-setting rights but the linguistic and technical burden is centralised. 2. Raise the micro-enterprise threshold to align with the VAT small-business regime, or introduce a packaging-specific de minimis (e.g.
I run a tiny one-woman-business as an artist. Financially, its simply not feasible for me to cover the upfront costs required just to potentially ship a package to another EU country. Ever since the Packaging Act was introduced in 2023, Ive been struggling to obtain the materials I need because more and more small businesses worldwide have stopped shipping to Germany because of the regulations.
The new Packaging Regulation is a debacle for SMEs and the free movement of goods within the EU. Aspect 1: The new rules make no economic sense for small and medium-sized consignors to be sent to other EU countries, either financially or in terms of time-consuming bureaucracy. They de facto exclude non-consignors from pan-European shipping, which is why this Regulation is discriminatory. Temu & Co.
Filed in German · English published by the European Commission
As the owner of a small business, I am deeply concerned about the new EU Packaging Regulation. Especially for small companies that want to develop and benefit from the European single market, the current requirements represent a huge financial and administrative burden. For Austria alone, I have already paid around EUR 450 this year to fulfil the packaging obligations.
Filed in German · English published by the European Commission
The new PPWR regime, which will apply from 12 August, is simply unrealistic and threatens the existence of genuine one-person companies. The alleged environmental objectives in this form are difficult to understand and it is completely unclear what real positive effect these measures are supposed to have.
Filed in German · English published by the European Commission
#PPWR - After careful consideration, its clear to me: Shipping to other EU countries will no longer be economically viable in the future. The bureaucratic burden is completely out of proportion to my actual shipping volumes. Even now, I feel like I spend more time dealing with regulations than on what I actually want to dodeveloping and designing my products. And now its going to get even more complicated.
#PPWR – After careful examination, it is clear to me: Shipping to other EU countries will no longer be economically worthwhile. The bureaucratic burden is disproportionate to my actual shipping volumes. Already today, I feel more time with rules than with what I want to do to develop and shape my products. And now it is even more complicated. The new EU Packaging Regulation (PPWR) will enter into force on 12 August.
Filed in German · English published by the European Commission
Subject: PPWR disproportionate burden on micro-enterprises risk of EU market consolidation To the European Commission / Umweltbundesamt, I operate Druckzeug.de (http://druckzeug.de/), a niche EU e-commerce shop for 3D-printer spare parts (Bambu Lab, BIQU, Advanc3D). I am a sole proprietor and micro-enterprise (<10 employees, <2m turnover).
For me, the PPWR is one of the greatest political disappointments in recent years. Rarely has a European regulation left me so doubtful about the idea of a common European single market. The European Union has been talking about the free movement of goods for decades.
Filed in German · English published by the European Commission
I’m running a small one-person company and I’m anticipating that the environment is very close to my heart. Reducing waste is important. But the high costs of appointing an authorised representative (for what exactly?) for only one country are already set too high. As a small business, I find several EU countries unaffordable and therefore impossible.
Filed in German · English published by the European Commission
The Regulation does not make things easier for us as small to medium-sized traders. It is becoming more complicated, more expensive, more bureaucratic and more polluting. The new directives make it difficult, for example, to reuse used packaging. It is easier and cheaper to buy new packaging immediately and to dispose of packaging that would have been recycled. At the same time, the bureaucratic burden is too high.
Filed in German · English published by the European Commission
We are a small and medium-sized trader for animal supplies in Germany with around 35 employees. Sending to other EU countries is not a technical problem for us. A parcel to the Netherlands is packed as quickly as one to Bavaria. It is now economically impossible.
Filed in German · English published by the European Commission
This policy is damaging and detrimental to small businesses both inside and outside the EU, and will reduce the choice for EU customers. The requirement to have a representative in each of the 27 EU countries (at a cost of approximately several hundred Euros each, and in addition to the requirement for a GSPR representative which also introduced yet more unnecessary cost for small businesses outside the EU) makes…
It has once again been possible to imagine something really great in order to weaken the European internal market, to exclude small companies and to keep the climbing bar for large non-European companies. Registration in each country and the associated costs are unaffordable for small businesses, as with any bureaucratic nonsense the costs continue to rise.
Filed in German · English published by the European Commission
Opinion on Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) Burden on small businesses in cross-border shipping Consignor: Volaris Computer, Cologne Small Enterprise in Computer hardware and IT services As a small IT and hardware trader based in Cologne, we would like to draw attention to an unintended but serious consequence of the PPWR in connection with the existing EPR regime: The cumulative…
Filed in German · English published by the European Commission
This new regulation is a sacrifice for all small traders who are doing their best in the EU. It simply becomes impossible to send goods to the EU and, above all, it is an incapacitation of traders acting on their own responsibility! This regulation is a peculiar bureaucratic monster, a cost explosion, and indeed it will prevent packaging because many simply stop shipping to other countries.
Filed in German · English published by the European Commission
Wasn't the EU's original purpose to facilitate intra-community trade by creating a single market? Where has that idea gone if the new packaging regulation is excluding thousands of small businesses across the EU? As a small producer, I'm also affected by this regulation, since I'm based in Portugal, produce there, and primarily ship to Germany.
Factual summary Small online traders, artists and retailers see the new packaging regime as a heavy bureaucratic and financial burden. The obligation to appoint an authorised representative in the respective EU Member States generates additional fixed costs. In the case of a small number of cross-border orders, these costs may not be economically viable for small businesses.
Filed in German · English published by the European Commission
Sorry, EU – but what is your goal? The destruction of all small businesses, excluding them from EU-wide trade? Should the EU not mean unification and free movement of goods for all? Yes, it did so in that it harmonised the previously completely unclear import conditions of all individual EU countries. But please indicate which small enterprise can be allowed to pay the annual fee per country.
Filed in German · English published by the European Commission
As a small entrepreneur, I learn very concretely what this bureaucracy means: I now have to stop shipping to other EU countries altogether because registrations, fees and different national requirements are no longer economically viable for me. I find this particularly bitter because the EU stands for a single market and a Europe without borders. In reality, new borders are emerging for small businesses.
Filed in German · English published by the European Commission
I fully understand the intention behind the PPWR and expressly support the objective of reducing packaging waste. However, the PPWR goes far beyond the objective in one respect by creating a de facto financial barrier to participation in the European internal market, which completely excludes small businesses, sole proprietorships, craftsmen, etc.
Filed in German · English published by the European Commission
The new packaging rules risk creating a significant barrier for small businesses selling across EU borders. For many micro and small businesses, the additional registration requirements, national obligations, authorised representatives and administrative costs make cross-border sales financially and bureaucratically disproportionate to the actual volume of packaging and waste involved.
The requirement to appoint an authorised representative in every Member State creates a disproportionate burden for small European businesses. As a small Austrian retailer, I am now forced to stop selling to almost all EU countries because the fixed administrative costs are not viable for a small number of orders.
I have a small company in Germany and it is impossible for me to appoint an authorised representative for the Packaging Ordinance in every EU country. That is why I will stop shipping outside Germany! The EU’s purpose is to facilitate trade between countries. However, by means of this Regulation, they shall cease to apply to small traders. According to Statista, 97 % of businesses in Germany are small, i.e.
Filed in German · English published by the European Commission
This new regulation is simply an unfortunate one and is simply unachievable for all small online traders and artists, from a bureaucratic and financial point of view. It reopens the door to wholesalers and strengthens their monopoly position. For the small retailer, this hurdle is insurmountable and the impression is created that the retail trade in Europe is simply to be destroyed.
Filed in German · English published by the European Commission
I hava a small creative business, my clients send me their unfinished projects, I finish it and sent it back, usually in the package it arrives in. Now I need to pay to use these packages ? ridiculous ! I have about 20 packages max a year, the other projects are delivered in person.
The PPWR has made it impossible for me to be part of the European market and to help my customers with their problems. I am a specialsit for modern and vintage pens and do penrestore. My parcels are very light and to stay in the European market will cost me 16000 Euro plus a lot of paperwork that stays in no relation to that what I will send and finaly that what I will earn.
The new Packaging Ordinance (PPWR) makes it extremely difficult for small traders to ship intra-European goods. As each country adopts its own regulations and also requires a fee-paying agent, many countries fall out if they do not have a corresponding volume of shipping. At present, this runs counter to an open and straightforward movement of goods within the EU.
Filed in German · English published by the European Commission
I have noted with regret that a well-intentioned and environmentally friendly project has created a bureaucratic monster without equals. Harmonisation of requirements, sorry that I don’t laugh. A patchwork without equals. Each country cooks its own ‘sweep’. I find it interesting to see myself on an equal footing as a micro-enterprise and, for example, Amazon.
Filed in German · English published by the European Commission
The PPWR is a perfect example of how well-intended EU regulation can disproportionately hurt small businesses. Large corporations can absorb country-specific registrations, reporting duties and authorised representative costs. Small retailers cannot. For cross-border e-commerce, the solution should be simple: implement PPWR compliance like the VAT One Stop Shop (OSS).
The environmental objectives of the Packaging Regulation (PPWR) and the sustainable management of packaging waste in the EU are to be warmly welcomed. It is true that distributors are used to finance recycling costs. However, the planned implementation represents an immense bureaucratic monster that de facto destroys the European single market for small and micro-enterprises (SMEs). 1.
Filed in German · English published by the European Commission
Public Feedback / Open Statement on the Impact of PPWR & EPR on Micro-Enterprises Subject: Urgent Appeal Regarding the Unintended Consequences of PPWR / EPR Compliance on Micro-Enterprises and the EU Single Market To the European Commission, As a small business owner within the European Union, I am writing to express my deepest concern regarding the implementation of the Packaging and Packaging Waste Regulation…
I would like to highlight the disproportionate burdens imposed by the new EU Packaging Regulation on small and micro-enterprises, in particular through the obligation to appoint authorised representatives for the extended producer responsibility in other Member States. In principle, I support the objective of reducing packaging waste and making producers more accountable.
Filed in German · English published by the European Commission
PPWR is the greatest bullshit every made! Instead of a well-functioning, unified solution, the crazy bureaucrats have created a monster characterized by extreme regulatory fragmentation. Each country can set its own rules, and finding authorized representatives is harder than winning the lottery. The PPWR is killing the Single Market and the European ideal.
We found documents relevant to teh declaration of conformity coherent with the PPWR. In addition it would be beneficial to add the amount of material (plastic, metal, wood,...) that the "manufacturer " of packaging is going to introduce in the European market through a System for Reuse.
It is deeply regrettable that the European Commission has not understood how much burden is imposed on the hundreds of thousands of small businesses that are already struggling with a wealth of administrative burdens.
Filed in Danish · English published by the European Commission
Deletion of additional category No 23 Other We suggest to delete the draft category No 23 Other. In accordance with Article 44(7) of Regulation (EU) 2025/40, manufacturers are to submit the information set out in point 1 of Part B of Annex IX to that Regulation to the register of producers.
Filed in German · English published by the European Commission
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.