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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 Also not shown: 312 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their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 223 submissions on this page · page 12 of 12 · 2,973 across the file. Search the whole file

DL

Dexpixel Ltd / Printerelle

· · filed 9 Aug 2026 · source

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.

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KingWolfInk

· · filed 9 Aug 2026 · source

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.

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CS

Clau's Cozy Closet

· · filed 9 Aug 2026 · source

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.

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AntevaCrafts

· · filed 9 Aug 2026 · source

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.

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SM

Studio Madebo

· · filed 9 Aug 2026 · source

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.

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LK

LIM KIM HONG

· · filed 9 Aug 2026 · source

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…

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L

LivingColoursDe

· · filed 9 Aug 2026 · source

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

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GC

GoneCozy Crafts

· · filed 9 Aug 2026 · source

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.

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A

Author

· · filed 9 Aug 2026 · source

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.

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MC

MY CHOLI - made by Inken

· · filed 9 Aug 2026 · source

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.

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MF

Mundo Flo

· · filed 9 Aug 2026 · source

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!

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LG

La Grosse Toile

· · filed 9 Aug 2026 · source

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.

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Crisydea

· · filed 9 Aug 2026 · source

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

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skatuya

· · filed 9 Aug 2026 · source

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.

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CN

Creative n' Chaotic

· · filed 9 Aug 2026 · source

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.

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BE

Bastelnarrisch e.U.

· · filed 9 Aug 2026 · source

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

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FA

Freelance artist

· · filed 9 Aug 2026 · source

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

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C

CaptainHoers

· · filed 9 Aug 2026 · source

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.

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DI

Ditta individuale

· · filed 9 Aug 2026 · source

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.

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M

Myself

· · filed 9 Aug 2026 · source

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.

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I

Illomax

· · filed 9 Aug 2026 · source

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.

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FD

Frollein Dotty

· · filed 9 Aug 2026 · source

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

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DL

Delta Leather works

· · filed 9 Aug 2026 · source

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.

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JS

Jody’s Crafted World

· · filed 9 Aug 2026 · source

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.

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TC

The Crimson Orchard

· · filed 9 Aug 2026 · source

- 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.

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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.