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

I operate a small online trade in billiard sports accessories in Germany and sell through my own online shop. I send around 320 parcels a year to 26 other EU countries. My turnover from these countries is around EUR 75.000. I expect to pay EUR 5000 per year for registration and authorised representatives in these countries.

Filed in German · English published by the European Commission

Submitted by Tree of Tales AB, a Swedish micro-enterprise manufacturing 3D-printed tabletop gaming accessories and selling cross-border within the EU. This legislation, as it currently operates for small cross-border producers, costs far more to comply with than the environmental harm it addresses is worth and its practical effect is to push micro-enterprises out of smaller national markets.

Ladies and gentlemen, as the operator of a small independent book publishing house, I would like to take this opportunity to draw your attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

First of all, we appreciate the work to try and reduce waste and move towards a more sustainable future, but this is the wrong approach. We're a small business of two people based in Sweden. To grow our business we need to sell our products outside of Sweden. Currently this means that we have our online store catering about 10 EU member states with an average of about 300/country/month.

Our company develops and produces material and material testing systems and related measuring and testing equipment. Our products are sold in several EU Member States. In addition, we regularly carry out calibrations, maintenance, repairs and service operations with our customers on site. We support the EU’s objectives to reduce packaging waste and strengthen the circular economy.

Filed in German · English published by the European Commission

I own a technology startup business in the Netherlands called baseworks.tech. My business effectively addresses several of the EU strategic priorities, among which: data sovereignty, privacy, independence from cloud providers in the IoT space.

Ladies and gentlemen, I would like to welcome your feedback on the Packaging Act. I will comment on this at once. As a matter of principle, I can understand that something needs to be done against the tip of the packaging. However, I do not see the problues in the mail-order cartons, but rather in the whole of the small things, which are 100-fold packed, e.g.

Filed in German · English published by the European Commission

It is not economically feasible for us to implement the Implementing Regulation. Smaller companies, such as ours, no longer have any chance at all against the big platforms; the frustration with the EU’s permanent gangling is growing. By the way, not only do we, but our customers are no longer able to understand this and express their views accordingly.

Filed in German · English published by the European Commission

For me, as a 1-man company, musical instrument construction, which accounts for 50 % of its annual turnover in the EU internal market, this regulation is a destruction of the means of subsistence. The costs for the Commissioner in each country, but also registration and licensing, and the bureaucratic burden of implementing all of this are disproportionate.

Filed in German · English published by the European Commission

I fully support the objective of reducing packaging waste and making producers responsible for the packaging they place on the market. However, the current implementation of packaging EPR requirements creates a disproportionate burden for micro-businesses. I am a one-person business based in the EU and depend on selling and shipping small numbers of parcels to customers across Europe.

I fully support any initiative to reduce packaging waste producers put on the market. However, I cannot understand how the PPWR law completely ignores the heavy, unreasonable burden it puts on micro-businesses across Europe. Very small businesses and artisans likely send only a few parcels a year, often use minimal packaging, and operate on narrow margins.

I am the owner of a small business based in Germany, selling yarn and knitting accessories. Approximately 60% of our turnover comes from customers within the EU. Our total package volume is very limited approximately 100 kg per year. Despite this small volume, the expected administrative and compliance costs related to PPRW could reach approximately 10,00020,000 per year.

Dear European Commission, Your new rules ruin not only my existence, but also a very large number of friends. For more than 10 years, I have been selling self-painted jackets, second-hand jackets, which I am giving a new life and appreciation to. Always with deep meaning and a lot of love. In recent years, I have built a studio, collected jackets, painted and invested a lot of time and money.

Filed in German · English published by the European Commission

PPWR - A Handmade Manufacturers Perspective. Dear European Commission, I strongly support the environmental objectives of the Packaging and Packaging Waste Regulation. However, the disproportion between environmental impact and administrative burden created for micro-manufacturers is just ridiculous. Let me give you my example.

Dear European Commission, as a self-employed person and producer of handmade products in the EU, I am writing to you regarding the practical impact of the Packaging and Packaging Waste Regulation (PPWR) and Extended Producer Responsibility (EPR) rules.

Filed in Slovak · English published by the European Commission

For micro-enterprises, a flat-rate tax per parcel to be levied by the carrier depending on the country of destination. It is therefore not necessary to have an authorised representative in each country and the micro-enterprise does not close the markets of the other European countries. The current proposal is an obstacle to the free movement of goods

Filed in French · English published by the European Commission

I am a self-employed artist and micro-business based in Portugal. I sell both original paintings and art prints to individual collectors across the EU. The current implementation of the PPWR creates a completely disproportionate administrative burden for businesses of my size. I may sell only a few original paintings per year.

The objectives of the PPWR are fundamentally important, but its current implementation places a disproportionate burden on small businesses. Cross-border sellers still have to comply with different registration requirements, EPR systems, authorised representatives and reporting obligations in each Member State.

The objectives of the PPWR make sense in principle, but the current implementation imposes a disproportionate burden on small businesses. Cross-border trade still requires different registrations, EPR systems, authorised representatives and reporting obligations to be fulfilled by each Member State.

Filed in German · English published by the European Commission

Feedback on the PPWR and EPR requirements for small businesses As a small online retailer based in the EU and selling products to consumers in several EU Member States, I strongly support the objectives of reducing packaging waste, improving recycling and establishing a circular economy.

Ladies and gentlemen, as a micro-entrepreneur and long-standing operator of a commercial eBay shop, I am writing to you to draw your attention to a problem that, in my view, should be urgently corrected when implementing the European packaging rules. I have been trading online on the eBay platform for more than 20 years. My business is small and cross-border shipping within the European Union is very limited.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Good afternoon. The topic is well known, no further explanation is needed here. In our opinion, the new packaging set was designed and launched by people or authorities who have no practical knowledge of the ‘real economy’ or active ‘economic behaviour’. The issue of the environment is important to all of us and we worked hard, including as small businesses, to further develop and promote it.

Filed in German · English published by the European Commission

It seems that nobody in the EU legislative process can seriously think about the consequences. We produce financial tombstones for banks across the EU. None of these banks generates turnover that would allow one agent per country to be hired for ~300 per year. We have now and immediately stopped deliveries to all EU countries except Germany. We also produced financial tombstones for various EU administration bodies.

Filed in German · English published by the European Commission

With this letter, I wish to express my deepest dismay, existential anxiety, and boundless frustration regarding the current legislation on Extended Producer Responsibility (EPR). As an independent micro-entrepreneur and creator, I stand bewildered before the ruins of what was once sold to me as the greatest promise of our continent: the European Single Market.

I am a micro-business based in Germany, selling decorative objects online. I support the environmental objectives of the PPWR and the principle of producer responsibility. However, separate EPR registration and compliance requirements in every EU Member State create a disproportionate burden for very small cross-border businesses. My sales are relatively few and spread across Europe.

I fully support the environmental objectives of Extended Producer Responsibility and the Packaging and Packaging Waste Regulation. However, the fragmented implementation of EPR obligations across Member States creates a disproportionate financial and administrative burden for micro-businesses selling cross-border within the EU. The core problem is proportionality. For a micro-business, many EPR costs are fixed.

Our Beautiful Touristic Map Of Iceland is a microscopic Icelandic family business that cannot possibly keep up with PPWR rules. This is absurd and completely un-doable for a two-person company with only 40-50 yearly sendings to the EU to pay individual registration and compliance fees across 27 different EU countries.

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

Filed in German · English published by the European Commission

For small businesses, a catastrophe is simply a disaster. For us, as two man companies, this arrangement entails additional costs that are difficult to bear, and shipping to some countries becomes completely unprofitable. Red tape, on the other hand, is growing even further. The EU should strengthen the single market! On the contrary, it is being weakened, especially for small businesses.

Filed in German · English published by the European Commission

I am the owner of a small independent book publishing house. With profound regret, I have been forced to terminate all sales and deliveries of our books to every country within the European Union. The Packaging and Packaging Waste Regulation (PPWR), and in particular the rules requiring registration in national registers of producers in every Member State where packaging is made available, constitute an unworkable…

Dear Member of the European Parliament,I am writing to you as a small business owner and a European citizen deeply invested in the future of our Single Market, regarding the implementation of the Packaging and Packaging Waste Regulation (PPWR).While I fully support the EUs environmental objectives and the critical need to reduce packaging waste, the current administrative execution of this regulation places a…

Sorry, but how dummy is this law? Has NULL thought about what this means for small businesses that also serve customers in other EU countries? Sometimes I really wonder what people are seated in governments and thus unthinkingly initiate laws. Thank you to all those who were co-responsible for this.

Filed in German · English published by the European Commission

I run a small EU-based apparel company (JIV Sport OÜ, Estonia) shipping directly to consumers across the EU. I'm writing to share the practical impact of the current fragmented national producer registration and authorised representative requirements under the PPWR. Our shipping volumes to many member states are modest - often under 50 kg/year of packaging per country.

We are a small Swedish antiquarian bookseller specialising in used and out-of-print books. We send no more than approximately 50 orders per year to customers in other European countries, mainly through platforms such as Bokliv and Bokbörsen. These sales are important both to our business and to readers seeking books that may not be available in their own country.

I'm a micro business (1 woman) based in the UK making handmade lampwork glass beads, jewellery and also supply specialist glass art materials to handmade artists. I've been building my business for 20 years, and have many lovely customers all over the world, including the EU. What I supply is handmade or unique to me, it's not mass produced.

The harmonisation of the registers of manufacturers of packaging is in principle to be welcomed. However, a single data format is not sufficient to effectively reduce the disproportionate burden on businesses operating across borders.

Filed in German · English published by the European Commission

I have been working as an e.K. since 2022 and I am extremely disappointed. This last change was the moment when I realised that it was not possible to stay or exist as a small shop at all. I am not given any options as to how to proceed, nor are all instances aware of how exactly the new rules should be implemented. The conclusion for me, only national dispatch.

Filed in German · English published by the European Commission

Hi , I am writing as a small European business owner, and I am genuinely furious about the way these packaging rules have been designed. The European Union constantly talks about supporting SMEs, entrepreneurship and the Single Market. Yet these rules achieve exactly the opposite.

There needs to be an exemption for micro businesses. A one person operation already has so many fees and regulations to consider from taxes, accounting, shipping, and beyond. While I support the goals of reducing waste and protecting the environment, the administration and financial burden of these regulations disproportionately affects micro businesses.

Stockholm17 AB is a small Swedish business that ships products from the United States through a 3PL provider to customers across all 27 EU Member States. I use IOSS and regularly declare and pay EU VAT. On 12 August, I had to suspend all sales to EU countries. The new requirements made cross-border EU sales commercially unviable for my business overnight.

For a micro business like ours, these requirements can be extremely burdensome and may even threaten the viability of the business. We ship only a small number of parcels to some EU countries sometimes just a few per year yet we are expected to pay significant registration and compliance fees.

We are a medium-sized German shoe retailer with several brick-and-mortar shops and a dedicated online shop. Until 12 August 2026, we have also supplied customers in other EU Member States. Since then, we have stopped all foreign deliveries from the EU as a precautionary measure. Not because there is no demand there or shipping does not work economically.

Filed in German · English published by the European Commission

As a small enterprise, the Packaging Ordinance is a burden. I have stopped shipping to another European country because it is not economically viable for my company. I send less than 100 parcels a year to other European countries. Every transaction is very important to me. However, in the case of this small quantity, the bureaucratic burden is simply not worthwhile, and certainly not to be warned of the risk.

Filed in German · English published by the European Commission

Hello, I am an art painter from Germany with an annual profit of around 3000. I sell pictures – mostly on site, but optionally on dispatch and optionally outside Germany. This never happened, but there was always the option. I usually use used grouped packaging for shipping, i.e. I do not even produce new waste.

Filed in German · English published by the European Commission

I am an SME trader in Germany. Unfortunately, with an annual turnover in Italy Spain Croatia Belgium Luxembourg of up to 3000 p.a. per country, I have to forego these revenues because of their new bureaucratic hurdles. Please find a solution where SMEs can profitably participate in European trade. You have taken this away from us. Thanks

Filed in German · English published by the European Commission

Totally astonished by how this was handled. A European law has been created, but it is managed differently by each Member State. Will a large company have no problem paying EUR 5/6000 every year to ship around the world but small businesses?

Filed in Italian · English published by the European Commission

I live in Italy and have a small business with a turnover of 15,000 a year. I sell online and occasionally sell abroad. I sell vintage products and use recycled boxes for shipping. In 2025, I shipped 13 packages to Germany, 4 to France, and just under 10 to other countries (all combined). With the new regulations, I would have to pay absurd costs for box disposal.

It was already very obvious that governments would like to see small businesses gone completely, but this plan would be the final straw. How can the EU, that consists of many Schengen countries that promote open trade, put rules in place that do exactly the opposite of what they should be doing?

I'm a small bussines owner from Lithuania. I have already lost half of my customers from US due to the new tariff system. Hearing the news about these new regulations in the EU devastates me. Since I started my bussines I've used as little packaging as possible and only use cardboard and paper. I understand the need to protect our environment. But this is not the way.

Hello to the EU: the new rule on packaging and packaging waste may be a good idea for our environment. For us craft bakeries, it is an additional ‘bureaucratic monster’ that we cannot stem. The burden on our deliberately small administration is simply disproportionate. Please relieve us of this burden for craft businesses. Peter Terbuyken

Filed in German · English published by the European Commission

I am regestered as a Micro-enterprise for handmade items. I don't have a lot of sales every year but there are some within the EU. I'm about to qualify as an Artist and will be setting up a business to sell my art...seriously...as a main source of income. If these new regulations go through and apply to small businesses I may as well give up now!

I have a small business based in Latvia and selling across the EU. We employ 2 people and use several manufacturers in the EU, source the materials in Sweden and Italy - supporting EU businesses!! These mandatory EPR registration fees and cross-border bureaucracy make it impossible for small independent businesses to sell across EU borders.

As a small business owner in Czechia, I strongly support the goal of reducing packaging waste, but I worry that this regulation risks undermining one of the EUs greatest achievements: the ability of ordinary people and small businesses to trade freely across national borders. In effect, we risk recreating borders within Europe not through tariffs, but through regulatory costs and paperwork.

I have a stationary textile shop and an online store. The rules may be necessary, but they are an unacceptable hurdle for small and medium-sized enterprises to sell abroad in Europe. This is another sargnagel for the German retail sector. What is important is that measures should finally be taken to protect the European retail sector. Protect our shops, our consumers from cheap goods from the Far East!

Filed in German · English published by the European Commission

The General Council of Chambers of Commerce of Catalonia welcomes the objective of the initiative to harmonise registration and reporting requirements under Extended Producer Responsibility for packaging, as greater homogeneity between Member States can facilitate compliance and reduce regulatory fragmentation, especially for companies operating in several markets.

Filed in Spanish · English published by the European Commission

Ladies and gentlemen, this idea is absolutely anti-economic. We small traders already pay for the Blue Angel in Germany. We dealers must indicate here the total weight of our packaging for 1 year. These weights include all packaging (whether in Germany or the rest of the world). Should we really pay 2x now? Where is cutting red tape?

Filed in German · English published by the European Commission

Christina Kellermann – German-Fire-Tech As a medium-sized company, we cooperate with many European manufacturers of safety products in the fire brigade sector. We develop, produce and deliver to our business partners across the EU.

Filed in German · English published by the European Commission

What on earth are you doing? The EUs biggest project is to achieve peace through international understanding and to create a large single market. Anything that hinders trade, freedom of movement and mutual understanding is counterproductive. Remember your remit: create sensible laws that protect the environment and consumers.

I am the only manufacturer of scrap metal accessories. I have been recycling iron for 20 years. And today I really do not have the free access to Europe that I was so happy about when my country became an EU member.

The problems created by this arrangement are destroying our ability to send out to all EU countries. Registering with representatives in each EU country generates immense costs and red tape. It is no longer worthwhile to send an annual turnover of 1,500 – 2000 to certain EU countries. As applications often cost 200-300 and are very obscure.

Filed in German · English published by the European Commission

Die vorgesehenen Regelungen zu nationalen Herstellerregistern stellen in ihrer derzeitigen Form eine erhebliche finanzielle Belastung dar, die insbesondere für kleine und mittlere Unternehmen (KMU) kaum tragbar ist. Was ursprünglich als Instrument zur besseren Nachverfolgung der Verpackungsverantwortung gedacht ist, droht in der Praxis zu einem kostspieligen und bürokratischen Flickenteppich zu werden.

PPWR Excessive Burden on Medium-Sized Businesses We are a medium-sized company supplying customers and business partners in various EU Member States. Our customers and manufacturers rightly expect us to be able to deliver throughout the European Single Market. We fully support the environmental objectives of the PPWR.

I am a small producer of handmade goods who was de facto banned from participating in the single European market. And I, like all small, medium and large producers on the continent, know that our production is not competitive with that in China, the USA, India and other countries, because our product itself is burdened with multiple environmental taxes under different names from the moment our product is a raw…

Ladies and gentlemen, I have been running a small mail order shop with my own production since 1985. Trade, shipping and administration are one thing. From this perspective, I would like to comment on one point: the obligation to appoint an authorised representative for the extended producer responsibility in each target country.

Filed in German · English published by the European Commission

We are a regional small-scale bakery with several sales outlets. We do not send goods to other EU Member States and purchase our packaging exclusively from German manufacturers and suppliers. Our limit for ever-new documentation, registration and reporting obligations has been reached.

Filed in German · English published by the European Commission

Hi, I am a independent bookseller in the UK. I don't sell massive quantities to the EU but would like to keep selling secondhand books to my neighbouring countries via online marketplaces and our own website. All of the envelopes we use to post books are recycleable and we use green suppliers or reuse our cardboard and tape because we believe in sustainability.

The requirement for manufacturers to register in every EU country or to appoint an authorized representative is very time-consuming for SMEs in the B2B sector and constitutes a disproportionate additional burden. Furthermore, as a producer of raw materials for the food and cosmetics industries, we do not know whether the buyer is a distributor or a commercial end user. This could lead to double taxation.

Ladies and gentlemen, I have been operating an ebay shop for about 20 years and handling second-hand cameras. Under the new PPWR Directive, I had to stop all my sales abroad in the EU. As a result, I have around 25 % less turnover. I cannot designate and register a person for each possible EU country. I think it should be an open market in the EU?

Filed in German · English published by the European Commission

... Bureaucracy ... Even Stalin didn't do as much harm to his own citizens as Brussels is doing to European citizens and small businesses today. More registrations, more paperwork, more fees, more bureaucracy all supposedly to protect the environment. Is this really what the European Union was supposed to become?

Hello, the new PPWR is a bureaucratic monster. Why is this not easier? It is incomprehensible what should happen as an entrepreneur in this case. Each package must already be labelled and this label makes it clear what material the package is made of. This system could have been extended. The PPWR is abolished or owned by manufacturers of packaging material. There seems to have been too much lobbying here.

Filed in German · English published by the European Commission

Thank you for your time in considering all the feedback provided. I strongly believe in environmental protections and recycling however believe a proportionate response is required to differentiate micro-business and what is within our capabilities compared to other businesses.

A terrible mistake that will only do damage to small businesses without doing enough for the environment. I bet the CEOs of Temu, Amazon and co. celebrated after the PPWR dropped. Competition from small businesses may finally be reduced, since you need a full-time person to handle all of this bureaucratic nightmare.

**Subject: Comments on the PPWR disproportionate burden on small traders** Dear Sir/Madam, as a small trader who occasionally also sells goods to customers in other EU Member States, I would like to express my concern about the practical implications of the new packaging rules (PPWR). In principle, I support the objective of making packaging greener and reducing packaging waste.

Filed in German · English published by the European Commission

In general, I believe it's a mistake to burden businesses (especially small ones) with green choices and sustainability goals, which risk serious economic damage, especially in certain market sectors. Sustainability has become a burdensome expense for citizens, both at work and in their private lives, rather than a truly ecological and beneficial action for all.

The cost and admin time implementing this would be prohibitive for most small companies. The whole thing is very anti-competitive and goes against the spirit of the free trading bloc. Packaging waste is a problem that is mostly caused by mega-companies like Amazon, Shein and Temu, not by small sellers. Anybody with skin in the game can take part in the EU Consultation page - link below.

Ladies and gentlemen of the European Commission, as the owner of a small trading and manufacturing company, I would like to explain to you how increasing regulation matters in practice from the point of view of a small entrepreneur. In my view, the envisaged national registers of producers are particularly problematic.

Filed in German · English published by the European Commission

1. Very serious argument of keeping FREE transborder deliveries in this unpeaceful era, is that the huge merchants, marketplaces and fulfillments are extremely vulnerable for military attacs and sabotage. Take a a look at the videos of ablazing warehouses of russian biggest marketplace! The online trade is paralized there, 10000th of sellers has lost there mercandise for billions of overnight!

Comments from IPC-Computer Deutschland GmbH on the PPWR rules on manufacturer registration I am submitting this opinion as CEO of IPC-Computer Deutschland GmbH, a German medium-sized enterprise specialising in notebook spare parts and repairs since 2003.

Filed in German · English published by the European Commission

Complaint against the disproportionate nature of the authorised representative obligation under Article 40(2) of the EU Packaging Regulation (PPWR) Dear Sir/Madam, as an operator of small online sales, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised…

Filed in German · English published by the European Commission

Ladies and gentlemen, I would like to express my deep concern about the practical impact of the new EU Packaging Regulation on micro-enterprises. I own a very small business in Germany and operate an eBay shop through which I sell car parts, among other things. I run my company mainly on my own and only have a minor employee to help. In principle, I expressly support the objectives of the Regulation.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

I am the managing director of a small German GmbH selling new CDs and DVDs through Amazon and eBay. Our company is based entirely in Germany. We store our goods in Germany and ship orders directly from Germany to customers in other EU Member States. We do not operate warehouses, branches or subsidiaries in those countries.

The new EPR scheme is a catastrophe and puts me in difficulty as a small company (dispatching antiquaria for books and autographers, I + 2 mini-jobs). Registering with an authorised representative in all EU countries would cost me around EUR 12.000 at least once a year, with an EU annual turnover of around EUR 20.000. After deduction of ports and associated costs, the MULT is the profit of my company in the EU.

Filed in German · English published by the European Commission

We totally agree with the target of reducing packaging waste and recycling but the new rules are simply impossible for a small business like ours to comply with. For example, we may send one tiny parcel to another EU country per year (all recyclable materials inside and out, have been for years).

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

We Verband Erzgebirgischer Kunsthandwerker und Spielzeughersteller e.V. represent the interests of manufacturers and traders in one of the most traditional craft industries in Germany and Europe. Archgebirgian handicrafts were recognised as Intangible Cultural Heritage in 2025.

Filed in German · English published by the European Commission

We are a company that sells only on marketplaces. We are defined as micro-enterprises. So far we have sold from and to other EU countries. The new obligation to appoint an authorised representative has now led us to stop sending goods abroad. If I send 5 packages per year to a country, but for that country alone there are already fixed costs around 300, we make a loss.

Filed in German · English published by the European Commission

We support the environmental objectives of the PPWR. However, the main problem for cross-border commerce is not the environmental fees themselves, but the enormous administrative and fixed compliance costs. Selling to another EU Member State requires separate registrations, authorised representatives, contracts with local environmental organisations and recurring annual fees, regardless of the actual sales volume.

Ladies and gentlemen, this new scheme is a catastrophe for musicians and micro-label operators who sell their music on phonograms, CDs or cassettes in micro-booms. I welcome the idea of protecting the environment behind the Regulation, but this is how it is implemented, meaning the death toll for small, non-commercial artists and cultural professionals who offer their art through Bandcamp, for example.

Filed in German · English published by the European Commission

As a small business owner and artist based in Belgium, I find the current cross-border EPR and Authorized Representative (AR) requirements for packaging completely unworkable for small businesses. It is deeply concerning that these requirements are coming into effect while the necessary infrastructure remains fragmented, unclear, and in many cases prohibitively expensive.

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

Filed in German · English published by the European Commission

As a micro-enterprise, I have now stopped sending parcels to other EU countries, as the administrative burden and above all the costs for each EU country exceed turnover. It is now easier/less bureaucratic and financially cheaper for me to send my goods to non-EU countries than within the EU, because this cannot be the purpose of such a regulation. So much about the single market, it was completely destroyed for me.

Filed in German · English published by the European Commission

I am a lawyer in Germany and have been advising exclusively internet traders for over 20 years. Most of my clients are micro-enterprises within the meaning of the PPWR. I am well aware that the PPWR pursues important environmental policy objectives.

Filed in German · English published by the European Commission

Please make cross-border packaging reporting requirements reasonable and proportionate for micro and small enterprises. I send only about 1020 small packages per year from my business to other EU countries. However, under the current regime, I would have to fulfil the packaging reporting and other producer responsibility obligations separately in each country of destination.

Filed in Estonian · English published by the European Commission

Natürliche utaten Ohne Farb & Konservierungsstoffe 100% Paleo egan Ref. Ares(2026)8059730 - 21/08/2026 Ohne uc er luten & etrei efrei usat EU Kommision Ausschuss C37000 21.08.2026 Rückmeldung zu den geplanten Vorgaben für nationale Herstellerregister nach der PPWR Erstens sollten Kleinstunternehmer nach den bekannten Grenzwerten für Mitarbeiterzahl und Umsatz generell von der Bevollmächtigtenpflicht ausgenommen…

Filed in German · English published by the European Commission

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

Feedback on proportionality for micro-enterprises The EU’s packaging waste reduction targets are generally useful. However, the current requirements are completely disproportionate for micro-enterprises with few cross-border shipments. To illustrate: A micro-enterprise may send 40 parcels to Austria, 10 to France, 5 to Italy and 10 to the Netherlands in total just 65 consignments throughout the year.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as a small German distributor of technical products, we also supply customers in other EU Member States. The envisaged obligation to appoint a separate authorised representative for the extended producer responsibility in each destination country places a significant burden on us.

Filed in German · English published by the European Commission

As a micro-entrepreneur in VintageOnlinehandel, I consider my economic freedom to be severely restricted by the planned obligation to grant PPWRBe power of attorney to small traders. The obligation to appoint a paid agent for each individual EU country is financially unsustainable for small traders and disproportionate to the very small quantities of packaging we actually send to other Member States.

Filed in German · English published by the European Commission

We are a small traditional business in Germany and we produce long-life baked goods, all of which are packaged in order to keep the product in good shape. We have been registered with LUCID since 2019 and have also had a licensing contract since then. In principle, I am in favour of financing the disposal of the packaging floods and, in particular, ‘to-go’ packaging.

Filed in German · English published by the European Commission

As a micro-business based in Sweden, we serve a very specific niche everywhere in Europe. Our customers are part of a minority that needs our products, but we can't bare the cost of each country registration without going out of business.

Hello, I have had a microenterprise of linogravure for a few months. I am still far from generating a viable income. I get to know each other gradually and send orders to various European countries (with a few orders per month). My consignments are made of recyclable cardboard packaging and the content is also recyclable.

Filed in French · English published by the European Commission

As a very small sized family-owned food producer established in the European Union, we fully support the objectives of the Packaging and Packaging Waste Regulation and the need to improve environmental protection, increase recycling rates and promote a circular economy. We recognise that reliable data can contribute to better environmental outcomes and a more sustainable future.

As a business owner with mostly EU shipments, with my wife owning a small business with EU orders, the new regulations are backbreaking. I understand the need to enforce better and more environmental friendly packaging, however the fees and required documentation are too steep and take it too far, especially for lets say people that are into handmade products.

I am writing as the owner of a small European company to share my concerns about the current packaging rules and the practical impact they may have on small businesses. I fully support the goal of reducing packaging waste and improving environmental responsibility.

A good idea, disastrous implementation. We will now only use new, licensed packaging within Germany and will no longer use > 90 % of reused cartons – which, moreover, we have had to license again as new packaging. In spite of this, the environment has so far been accepted, but it is now meaningless.

Filed in German · English published by the European Commission

As a micro-entrepreneur running a small vintage watch business based in Luxembourg, I am writing to express my strong concerns regarding the current implementation of Extended Producer Responsibility (EPR) under the PPWR framework. ​While I fully support the European Union's environmental goals, the practical execution creates an overwhelming administrative and financial burden for small actors.

As an independent creator, I make and sell handmade goods through my own small shop, and the EUs Extended Producer Responsibility (EPR) rules currently make cross-border sales nearly impossible at my scale. Each member state runs its own registration scheme, which means separate authorized representatives, separate fees, separate reporting deadlines etcetera.

I don't know where to start. The PPWR is a disaster. I run a small business earning just enough for my family's rent and groceries, and having to get representatives in all these EU countries is not feasible for me at all. Besides running a webshop, I am also a visual artist working with plastic: www.mathieuklomp.nl.

As a micro-entrepreneur based in Poland running a small e-commerce business (sole proprietorship) selling specialized goods (Lego bricks and related accessories) directly to B2C and B2B customers across Europe via platforms like eBay and Bricklink, I must strongly oppose the current implementation plans for the PPWR regarding national producer registers and Extended Producer Responsibility (EPR).

We are a small owner-run organic handicraft bakery in Saxony with its own production, a specialist shop and an online shop with comparatively small shipping volumes. We support the objective of preventing packaging waste and financing recycling in a user-friendly way.

Filed in German · English published by the European Commission

PPWR can be dealt with in a short and crunchy way: Afuera – this can be done away with! Do not renegotiate, adapt or defuse, but simply delete without replacement. It is a completely superfluous bureaucratic monster which does not produce the slightest social benefit.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

I am a musician and run a small independent record label in the UK. I ship records, tapes and merch around the world, with a significant and important fan base in the EU. Although we only send around one to two hundred packages to the EU each year, these customers are vital to keeping my label alive.

I have spent many years building a small business in Germany through a great deal of hard work, personal initiative, and personal risk. I fully support the objective of the legislation - less packaging waste and greater recyclability - and consider it urgently necessary. Nevertheless, I am convinced that the PPWR in its current form is the wrong approach.

I am a sole trader in Poland selling handmade amber jewellery to customers across the EU. I fully support environmental protection and reducing packaging waste, but the current EPR system places a disproportionate burden on micro-businesses. I may send only a few parcels per year to some EU countries, using just a few kilograms or even less of packaging.

Ladies and gentlemen, I have a small shop with beautiful Tyrolean products of all kinds. As many tourists shop with me, they are also delighted if they can also order the products from our entrepreneur-led shop online. We have around 400 orders per year. If I had to hire a firm in each EU country to handle the PPWR in the recipient country, this would not be financially viable for our business.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

I am musician and musical instrument workshop owner located Czech Republic. We make 10-20 very specialized instruments per year. and our customers are all over the world. In some EU countries we may have sold only one instrument in 30 years. For a specialised business like ours, the new system creates serious practical problems. 1.

This regulation is death for online traders, especially smaller ones. We want to be an EU, and then we are doing away with each other’s trade. We cannot do this at all, both bureaucratically and in monetary terms. If you don't want all online traders to stop shipping abroad in the EU, then withdraw this rule!

Filed in German · English published by the European Commission

Dear Member of the European Parliament, My name is Eszter Réti, an architect by training (MOME, Budapest) and founder of Atelier Poupée, a Grenoble-based micro-entreprise designing and producing architect-led wooden dollhouses, positioned as collectible design objects rather than conventional toys.

Unfortunately, small businesses are once again placed at a disadvantage. We cannot afford to register in all Member States, often just one package per year. We will stop shipping to neighbouring countries and continue to focus on the non-EU market. This also means that replacement LEDs may no longer be able to be ordered and therefore defective lamps will migrate into the waste, which is counterproductive.

Filed in German · English published by the European Commission

This new regulation is a blow to micro businesses! JAI a small e-shop with few sales and fewer than 5 consignments per country per year. These new rules make it impossible to continue selling to other countries. In addition, each country imposes its own rules and costs. I do not see why this is a good thing for small businesses. I am aware of the cause of the environment and recycling, but not to that extent.

Filed in French · English published by the European Commission

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

Filed in German · English published by the European Commission

completely odd, especially in terms of communication – different practices have been described on various platforms. Lack of consistent and clear communication on what needs to be implemented. In addition, as a small company, we are indirectly curtailed in our foreign sales.

Filed in German · English published by the European Commission

I represent a Lithuanian micro-enterprise with one employee and an annual turnover of approximately EUR 30,000. We sell low volumes of sheepskin products online and package the orders ourselves. The proposed requirements create a disproportionate level of responsibility, administration and expense for very small businesses. A micro-enterprise may receive only a few orders per year from each EU Member State.

I strongly support the environmental goals of the PPWR, but the current system of national producer registrations and EPR obligations creates a disproportionate burden for small businesses selling across EU borders. I run a small online business in the Netherlands. We sell primarily in our home market, but we also receive orders from consumers in other EU Member States.

As an online trader, we have switched off all EU countries. The burden is too high for us, the costs are too high. This clearly favours large shops or marketplaces such as Amazon. In our view, the new directive completely ignores ‘sound sense’. Why is there no simpler EU-wide solution, such as a VAT one-stop shop?

Filed in German · English published by the European Commission

We support the environmental objectives of Regulation (EU) 2025/40 and the principle that companies contribute fairly to the costs of collecting, recycling and treating the packaging they place on the European market. However, for SMEs with only sporadic cross-border sales, the current system of producer registration risks creating a disproportionate administrative burden.

Filed in Dutch · English published by the European Commission

This packaging regulation is killing the idea of united European market. We absolutely support the idea of reducing packaging waste, but current solution is creating a lot of administrative waste. Please take it back and let's create something that is sustainable and works for everyone. Why can't there be one entry point or maybe it can be handled other way.

Hello. Mandatory EPR registration fees and cross-border bureaucracy make it impossible for small independent businesses to sell across EU borders. I am demanding a de minimis exemption or a simplified One Stop Shop system for micro-entrepreneurs. My mom recently became tethraplegic. I need to provide for her. I have spent a lifetime learning skills and crafts. You're making my hands USELESS. Create a threshhold.

As a Spanish micro-enterprise and independent artisan making handmade leather goods, I am writing to express my deepest concern. While I fully support the EU's environmental goals, the current implementation of the PPWR and fragmented national EPR frameworks poses an existential threat to small traditional crafts across the European Union.

Concrete proposals! In principle, the PPWR is good. Only must it be simplified and partially (effectively) de-bureaucratised (which is the case for a stretched name). To this end, we are putting forward concrete proposals to simplify the OMNIBUS system and would welcome the European Commission’s decision to implement it!

Filed in German · English published by the European Commission

Good afternoon, as an operator of a small online gardening business, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

As a small company producing in Berlin (around 25 employees), which produces modular shelving systems on request, we would like to draw attention to the problem of the current PPWR rules (in particular the rules on producer registers). We offer delivery to more than 20 EU countries. However, as our main market is in Germany, we supply only very small quantities in many of the countries indicated.

Filed in German · English published by the European Commission

I am small business owner and that mandatory EPR registration fees and cross-border bureaucracy make it impossible for small independent businesses to sell across EU borders. Demand a de minimis exemption or a simplified One Stop Shop system for micro-entrepreneurs.

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

Filed in German · English published by the European Commission

As a tax advisory in Spain, we work with small businesses and local craft workshops. We are already seeing the impact of the new ERP and packaging rules, as clients have stopped selling to European countries and, as a direct result, have seen their revenue decline substantially. To put some numbers to the story: let's think about an artist with an online store.

TimeTEX HERMEDIA Verlag, [address removed] – Deutschland Branche: Produkte für die Bildung, wie z.B. Lehr- und Lernmittel, Lehrer-Kalender, Lehrerbedarf [name removed] W. J. Hercher – CEO und Mitgesellschafter, [email removed] Thema: PPWR Praxisvorschlag für eine Omnibus-Vereinfachung der PPWR Aus Sicht eines mittelständischen europäischen Herstellers und Importeurs Bürokratie abbauen – Umweltziele erhalten –…

Filed in German · English published by the European Commission

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

The 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.

Bizarre, ill-conceived, and too ridiculous for words. It has nothing to do with reducing waste anymore; in fact, you are creating much more waste. Moreover, this was devised solely for and by a bunch of lean entrepreneurs who will get rich off this. The small business owner is going under, and the big players, who don't even pay unnecessary taxes, are growing larger. Take action before everything truly falls apart.

I own a farm that sells and repairs the agricultural, forestry and garden machinery I rarely send parcels outside Germany. But I completely disagree with the new packaging regulation. Do you want to protect the environment and treat used, recycled cartons as if they were new to the market?

Filed in German · English published by the European Commission

Ladies and gentlemen, we would like to draw your attention to the concrete impact of the PPWR on small businesses and the European single market. We are a German company with six employees and we sell products for model building. For many years we have supplied customers across the EU.

Filed in German · English published by the European Commission

I fully agree that packaging management is an important element in the fight against waste and the burden on disposal. However, this new regulation is clumsy at best. It forces small exporters like myself to comply with the same conditions and regulations as a multi-national corporation. We sell a variety of Irish made goods to nice people all over the EU.

Please find enclosed our feedback on the practical implementation of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). Uhlmann Pac-Systeme GmbH & Co. KG expressly supports the environmental and circular economy objectives of the PPWR. At the same time, we see considerable room for improvement in the practical design of Extended Producer Responsibility (EPR).

Filed in German · English published by the European Commission

I have a miniature company, rather just a workshop – in one person. I produce reproductions of historical costume heads, preserving traditions. As other EU countries have the same problem of shortages of costume components, I will also send headscarves to them + Slovakia about 6 times a year. I would like to send more, but I am not yet familiar with the international brand.

Filed in Czech · English published by the European Commission

I have a microscopic sole proprietorship that has only been open for 4 months. When I read out about the hepr and the representative’s obligation, the world fell on me. Not only is it impossible to afford to pay taxes for the disposal of packaging, but even less so a legal representative for every country, for newly born companies, where only one person, as in my case or very few, work, we have not even had the time…

Filed in Italian · English published by the European Commission

Both the EPR and the PPWE Regulations are extremely ruthless for smaller companies, which are unable to bear the costs of registering in 27 different EU countries, nor can they bear the administrative burden. How, in the world, so hard legislation has gone all the way through the EU system. It is not reassuring. Of course, the intentions behind the regulations are very fine, I have neither any objection to it.

Filed in Danish · English published by the European Commission

We are a small Portuguese company producing handbags in very limited quantities, working with local artisans and traditional skills that are increasingly at risk of disappearing. We fully support the objective of reducing packaging waste and making producers responsible for the packaging they place on the market.

Ladies and gentlemen, as founder and managing director of Goodvines Getränke GmbH, a small German manufacturer of premium non-alcoholic wines and aperitifs, I would like to draw your attention to what I consider to be a particularly critical point in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

ENGINE is a small Swedish direct-to-consumer activewear brand, run by a single founder, currently selling within Sweden and expanding sales into other EU member states. We support the Commission's move to harmonise the format of producer registers and reporting obligations under Regulation (EU) 2025/40.

Hi. I am a frequent supporter and customer of small businesses and have also started my own in Sweden. My plan was to hopefully one day start to sell my artwork in the EU but these new regulations will make it impossible to do that. Instead of reaching new people with our goods, these fees will make the sales unsustainable and it would take long before it is even marginally profitable to sell across countries.

Good afternoon, the attribution “manufacturer”, “producer”, “distributor” is not clear. It shall also not be taken into account if single-use cartons of another product, e.g. from a household electrical appliance, are used as transport packaging for the shipment of e.g. machine components. The cartonboard is still clean and intact and can thus be directly recycled at 100 %.

Filed in German · English published by the European Commission

An EU-wide one-stop shop instead of national multi-bureaucracy! We welcome the Regulation’s environmental objectives and the envisaged uniform registration and reporting formats. However, uniform forms alone are not sufficient.

Filed in German · English published by the European Commission

I am a one business independent company selling handmade products directly to customers across the EU. I fully support the environmental objectives of the PPWR. However, I am very concerned about the financial and administrative burden for my own and all other small businesses selling cross-border. Small companies do not have dedicated legal or compliance departments, unlike larger market places..

*Subject matter: Opinion on the implementation of the Packaging Regulation (PPWR) Design of producer registers and obligation of authorised representatives for SMEs* Dear Sir/Madam, as the operator of the still young webshop, I would like to take this opportunity to express my views on the practical implementation of the Packaging and Packaging Waste Regulation (PPWR) in the context of this consultation.

Filed in German · English published by the European Commission

As a very small trader, I am concerned about the amount of administration that the new packaging rules could create. I fully support the goal of reducing packaging waste, but the requirements should be proportionate to the size of the business and the amount of packaging involved.

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to two points which, in my view, are particularly critical with regard to the planned implementation of the PPWR producer registers: First, the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

We are a small independent French company selling physical cultural products directly to customers across the EU. We fully support the environmental objectives of the PPWR. However, we are very concerned about the administrative and financial burden created for small businesses selling cross-border. Unlike large marketplaces such as Amazon, small companies do not have dedicated legal or compliance departments.

Ares(2026)8029651 - 20/08/2026 PPWR: Die EU darf Kleinstunternehmen nicht aus dem BinnenmarktRef. regulieren Sehr geehrte Europäische Kommission, wir wenden uns mit großer Sorge an Sie! Wir sind ein Kleinstunternehmen Barre Products und Hersteller von Nahrungsergänzungsmitteln.

Filed in German · English published by the European Commission

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

I work as an accountant and consultant for small business owners, and also rum an association that helps small entrepreneurs , especiall those in fragile situation. While I love our planet and support the recycling effort, the PPWR regulations at the moment are unsustainable for small creators. The burden both finalcially and administratively is way too high, and the impact on info will be catastrophic.

I soon have a micro company registered as I am developing a new solar driven water heater and plan to sell all over Europe. I have no funds to cover the 3000 fees for packaging waste registering. Please implement a micro company exemption and put a moratorium on current rules. I might have to close my project otherwize.

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

Filed in German · English published by the European Commission

As a small trader who also sends small quantities of his goods to other Member States of the European Union, I would like to express my deep concern about the increasing bureaucratic and financial burdens resulting from the new packaging requirements. In principle, I support the objective of making packaging greener, promoting recycling and making producers more accountable.

Filed in German · English published by the European Commission

I run a small one-person jewellery business based in the UK, creating pieces inspired by Kazakh and Central Asian culture. I may receive only a few orders per year from some EU countries, yet I can still be expected to deal with separate registrations, fees, reporting requirements and, in some cases, local representatives.

PPWR Stellungnahme Stellungnahme zur öffentlichen Konsultation Initiative: Verpackungen und Verpackungsabfälle — Vorschriften über nationale Durchführungsrechtsakts zu Art. 44 Abs. 14 der Verordnung (EU) 2025/40 (PPWR) Ref.

Filed in German · English published by the European Commission

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

Our business mainly sells on the Big markets DE and IT. However we do make a profit of 400-1000 Eur per year inside the next 5 markets such as NL BE FR ES SE. And we for the last around 20 countries we make small profit of around 100-200 eur Per Year. With this destructive law it means we have to pay on top of the Packaging Waste fees - AR fees 150-300 eur per coountry. And this is only for the packaging category.

As an independent artist running a small stationery shop with a very limited number of sales per year and only a handful of orders in individual EU countries, I believe the new packaging regulations place a disproportionate and unrealistic burdenboth financial and bureaucraticon micro businesses.

What do you do? First, Trump’s removal of the de minimis rule deprives my handmade glass beads business of all US customers, leaving almost only the EU as a market, and now I also have to pay extra costs and make a lot of effort for all that administration on an EU country basis. 1 shipping a sale of EUR 32 already gives shipping costs of EUR 11 with minimal margin.

Filed in Dutch · English published by the European Commission

If you want the European single market to cease to exist. Congratulations: And in this they succeeded. This makes the EU obsolete as an economic community! These rules destroy livelihoods and create economic weakness. What then follows has often been observed in history.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

As manufacturers of packaging, we fundamentally support the objective of the PPWR to harmonise packaging requirements within the European Union and promote a functioning circular economy. However, from the point of view of an industrial packaging manufacturer, we see significant challenges in the practical implementation.

Filed in German · English published by the European Commission

I am a sole self-employed craft business based in Spain, selling handmade jewellery online. I support the environmental objectives of the Packaging and Packaging Waste Regulation and I fully agree that businesses should contribute fairly to the management of the packaging waste they generate.

Congratulations! You managed to do it again! Destroying the entire European single market! How to think of scrap?! We have now stopped all exports. Thank you for that! This definitely costs a few jobs! Sooner or later, the EU will completely ruin us with your senseless, impractical and absurd bureaucracy! Do you really have any qualifications to see what impact your decisions have on the economy?

Filed in German · English published by the European Commission

Very simple. From now on all trade with other EU-countries are stopped. My small business cant motivate the very time- and money consuming work to register i each country I would like to send a single book to. Not mentioning if I have to pay for a legal entity to handle it for me. This is very non-EU. See to that, at least for very small companies, there is a common registration for all of EU.

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.

Dear, We are a small owner-run company that sells water sports accessories. Last year’s annual turnover was approximately EUR 600.000. In various EU countries, the proportion of turnover is between EUR 300.000 and EUR 50. Registration (not the actual taxes) costs around EUR 500 per EU Member State. In our return calculation, therefore, registration will only be worthwhile if registration costs are more than earned.

Filed in German · English published by the European Commission

In addition to our activity as a craftsman, we also sell goods via a sales platform. As these are mostly rare individual pieces, it is already a tremendous effort to insert the parts with all the necessary information. So far, we had offered these parts for the whole of the EU – the parts are constantly going to a wide range of countries.

Filed in German · English published by the European Commission

As a small trader – a ceramicsman who develops single-piece handicrafts – it is simply unthinkable how it is possible after the entry into force of these rules to survive and sell their products to other countries. How can we pay for packaging taxes in all European countries, even when earning an average salary? NOT AT ALL. It is unfortunate that fewer businesses and artists in particular are being disrupted.

Filed in Lithuanian · English published by the European Commission

The new rules on packaging and packaging waste are a complete disaster for small businesses. Yes, there are businesses much smaller than 10 employees and 2 million Euros annual turnover. I am running my business all by myself and it just about gives me enough of a result to make a living.

I am a very small specialist music publisher. With this perhaps well-intentioned regulation, you are preventing the distribution of cultural goods. I had imagined the European Union differently: Open borders, free movement of goods, uniform and comprehensible procedures for all Member States. Please refer to the attached pdf for details.

Filed in German · English published by the European Commission

The planned national registers of producers will lead to additional bureaucracy, multiple registrations and higher costs for businesses. A particular problem is that establishments need to comply with different national requirements when trading cross-border in several EU countries. This runs counter to the objective of a single European internal market.

Filed in German · English published by the European Commission

We are a small company in motorcycle accessories. The shipment is international. With the rules, I would have to bear an annual cost of more than 4000.- not to cover all quantities per country. If there is no simple solution, we will stop shipping within the countries concerned. Everyone is willing to contribute, but this should depend on the size of the business and turnover.

Filed in German · English published by the European Commission

Dear Sir/Madam, As a small e-commerce business owner, I am writing to express urgent concern regarding the implementation of the Packaging and Packaging Waste Regulation (PPWR) specifically the obligation to appoint an Authorized Representative (AR) for Extended Producer Responsibility (EPR) when selling cross-border. Under the current setup, AR requirements generate fixed, non-scaling costs per country.

I am a micro-entrepreneur (artisanal craft) with a very small turnover and tiny shipping boxes. Nevertheless, I have been registered with the Green Point in Germany for years. And yes, I think it is very important that packaging waste is reduced as online trade grows. But what has now been decided is not financially viable for me, not to mention the bureaucratic burden.

Filed in German · English published by the European Commission

We are a small family company from Latvia. Our business is oriented entirely towards the common European market, through stores like eBay and the like. Our business is closed. 3 families were left without a livelihood. The new regulation increases the price of each of our products by 21.03 euros. And we make a net profit of 15.20 euros per product. Europe is no longer a good place for us to live.

This is the complete destruction of small business. I only send a few shipments to certain European countries, and I can't even predict how much I'll sell in each one. If I have to purchase this representation, I will simply have to close down because it means complete financial bankruptcy.

Ladies and gentlemen, as operators of small online sales, we would like to use the consultation to draw attention to what we consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

For many years, we have been delivering our musical notes to customers across Europe. For us, the EU single market has been a great success: a common economic space without borders and unnecessary barriers, where small specialised companies could also reach customers in all Member States. This is now over for us. We have stopped shipping to customers in other EU Member States.

Filed in German · English published by the European Commission

The proposed packaging waste system is not sufficiently adapted to the reality of small businesses and micro-enterprises operating across the EU. As a small business selling handmade products online to customers in different EU countries, I find the new requirements disproportionately complex, costly and administratively burdensome.

Hello, I and many other solo business entrepreneurs in France do not understand what is being proposed. The mechanism for sharing this information is not robust, many people in a Facebook group I belong to for female business owners in France did not know anything about it. I use entirely recycled packaging to pack the 30 second hand goods I sell on a global online marketplace each year.

an unbearable burden for a small business. sometimes I don't sell a single item or I sell only 1-2 items to a European country per year and a fixed fee of 200-800 euros just for the opportunity to send to that country is inadequate. I only sell 0-3 items of super small items to each EU country per year and the fees requested are enormous. small businesses deserve exceptions

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

Filed in German · English published by the European Commission

Dear Sir or Madam. The current packaging rules place a disproportionate burden on micro-businesses. We are a two-person family business 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.

This does not work at all, costs far too much and some countries still have non-usable portals for registration. The obligation of an authorised representative ultimately makes it impossible. The only alternative would be a portal for reporting for all countries and payment to an account from where it is then distributed, basically in the same way as OSS VAT returns.

Filed in German · English published by the European Commission

The rules are once again as blooming as then the GDPR (not misunderstood, I am not against data protection, privacy or now also sustainability). Some laws are adopted without specifying what this means and how they are to be implemented in the real world. Regulations enter into force and, with a few exceptions, no country is prepared for them. No one knows what it is, it is almost impossible to obtain information.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a small 1-man online trader with only sporadic orders from other EU countries, it is completely uneconomical and organisationally impossible to conclude a separate waste disposal contract for each EU country. As much as I can understand your efforts, I must nevertheless inform you that EU trade will become impossible for me.

Filed in German · English published by the European Commission

I import and sell high-quality, low-volume Japanese artisanal goods to customers across the EU, and I am writing to say plainly that the PPWR, as implemented, is destroying small businesses like mine. The Regulation was justified as a single-market measure, yet it has left me facing separate registration, separate declarations, separate deadlines and separate evidence files in every member state I sell to.

Im a sole trader running a small handmade jewellery business from Cornwall, UK every piece made by hand, sold through Etsy, Folksy, my own shop and Faire, using minimal, recycled cardboard packaging. The extended producer responsibility (EPR) rules for packaging under PPWR make cross-border EU sales unworkable for a business my size.

I am a sole trader (small e-commerce) As a result of the obligation to appoint an authorised representative for Extended Producer Responsibility (EPR) in cross-border sales, I have on 12 August. All EU countries (except D) blocked as supplier country. This is completely at odds with the EU’s free internal market! This authorisation for each EU country is not financially viable for small traders.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to what I consider to be a serious point in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales. For small online traders, selling to other EU Member States is an important part of the single market.

Filed in German · English published by the European Commission

Ladies and gentlemen, "I am not really able to do this anymore. I am already struggling with CE, WEEE, the old Packaging Regulation, the Duales System, etc. I fully support the objectives. Unfortunately, in this sense, I am also a first-time distributor in the EU, but I also sell my products directly. Nevertheless, I am a mini-company. I am a one-person company.

Filed in German · English published by the European Commission

I am shocked to see the new legistlation. I am a Hungarian-Swiss new small business owner. My companyi s based in Switzerland but I intended to create an affiliation for the european market for my european consumers. I am launching this October/ November and now remaking my strategy to avoid all EU countries sales as I cannot unfortunately afford nor a legal representative nor paying high fees in 27 countries.

Our company was founded in 1990, employs between one and five permanent employees, and since its creation has successfully trained 17 young people in various commercial professions. The requirements of the PPWR pose significant economic and administrative problems for our direct cross-border sales to end-customers within the EU.

Filed in German · English published by the European Commission

I believe that the system currently being developed is not well suited to small businesses, particularly those that sell in small quantities and ship their products to different EU countries. For a small business, taking responsibility for packaging is not the difficult part.

EPR rules are disproportionate for micro-businesses I run a one-person micro-business in Lithuania selling handmade linen home textiles across the EU. I fully support EPR and paying for the environmental impact of the products and packaging I place on the market. However, the current system is becoming disproportionate for businesses of my size.

We have just established the business less than a year ago. Everything has been planned based on the EU wide market research and presence. It is extremely difficult to start a business from zero with these requirements. I understand the rules when business and turnover reach a level where it is possible to pay the fees.

The current packaging regulations impose an entirely disproportionate financial and administrative burden on the smallest enterprises. Many of us operate as one-person businesses receiving only a handful of orders per year from various EU Member States.

We are a family business in Lithuania. We make steel shelf brackets in a small workshop and sell them online to customers in about 17 countries. This has been our income for years. This act should not be adopted in this form. To keep selling into another EU country we would need to register there and pay an authorised representative in that country.

Clearly no consideration has been given to micro or small businesses within this new regulation. As a small business, this regulation completely stops me being able to sell to other EU countries, because of the costs involved.

Ladies and gentlemen, as the owner of a small trading company in Germany, I would like to draw your attention to a significant problem in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border sales within the EU.

Filed in German · English published by the European Commission

Dear, We are a medium-sized weather forecaster and sell a unique product in Europe via e-commerce: a WetterDisplay that provides a live picture of weather trends on a large map at all times. We have been selling it since 2019, now in the 4th Generation.

Filed in German · English published by the European Commission

I'm an independent music artist releasing my first album on vinyl soon. Without an exception for micro-businesses like mine, I will make a substantial loss (both monetary and opportunity cost) on every single record I sell outside my own country. The risks, time investment and associated costs of complying with the new regulation are destroying my business before it can even start.

Ladies and gentlemen, I operate a small handmade business in Germany and sell through an online marketplace and my own website. I send 250 packages to 25 other EU countries each year. My turnover from these countries is EUR 7500. I am expected to pay EUR 6500 per year for registration and authorised representatives in these countries.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, I operate a small handmade business in Germany and sell through an online marketplace and my own website. I send 150 packages to 20 other EU countries each year. My turnover from these countries is EUR 8000. I am expected to pay EUR 6500 per year for registration and authorised representatives in these countries.

Filed in German · English published by the European Commission

Ladies and gentlemen, I am a sole trader without employees and send my physical goods exclusively with environmentally friendly shipping bags made of 100 % recycled cardboard and paper. I deliberately renounce plastic in order to protect the environment and facilitate recycling.

Filed in German · English published by the European Commission

I am a self-employed sculptor in Spain, working from home, and my only way of selling my work is online. Some of my customers are in other EU countries. The bureaucracy and costs involved in these new EPR requirements are simply unmanageable for a small artisan like me. There are many of us in this situation, and these rules could make it impossible for us to continue selling our work.

Ladies and gentlemen, we are a small online trader in the field of model railways. We delivered 191 parcels (less than 1 kg) to 21 EU countries in 2025. According to the calculation of a packaging licence provider, we would have to expect a cost of around EUR 8000 per year for these 191 packages.

Filed in German · English published by the European Commission

Dear Commissioner, I am writing to you not as a lawyer, lobbyist or representative of a large organisation, but simply as a European artisan and owner of a small handmade business in Germany. For many years, I have created handcrafted lampwork glass beads and one-of-a-kind glass jewellery in my own workshop. Every bead is made by hand in the flame.

Ladies and gentlemen, I run a small online business – and I had to stop sending me abroad in Europe for the time being, as it is not acceptable for me, as a sole trader, to appoint an authorised representative in each EU country. The financial burden is simply unbearable! That is absolutely impossible for me to do. I hope that this will be reconsidered and changed.

Filed in German · English published by the European Commission

It is quite clear these rules were created without thinking of the sole traders, small businesses that operate within the EU. These regulations as they stand place the same burdens of registration cost and compliance on the mega corporations as a single person operating a small business. The environmental impact of these 2 types of operations are clearly wildly different.

Ladies and gentlemen, as the owner of a small retail business, I expressly support the objective of a sustainable circular economy and the reduction of packaging waste. However, the designs of the national producer registers provided for under the PPWR have the very opposite effect of European free trade in practice: You are pushing small traders out of the EU cross-border market.

Filed in German · English published by the European Commission

Ladies and gentlemen, as founder of Chill n Feel, a small German family business, I would like to draw your attention to the significant consequences of the EU Packaging Regulation (PPWR) for small specialised providers and affected families. We develop and sell special companion clothing for babies and children with neurodermitis, highly sensitive skin and special medical needs.

Filed in German · English published by the European Commission

Hello, as the owner of specialised online sales of niche products, I fully support the basic objectives of the new EU Packaging Regulation (PPWR), in particular the prevention of packaging waste and the promotion of the circular economy. Micro and small businesses also want to play their part in sustainable action.

Filed in German · English published by the European Commission

As the owner of a stationary small business, I consider these rules to be completely unrealistic. The sending of parcels plays little role in my business; however, what is at issue here is the principle and fundamental freedom of action of small undertakings.

Filed in German · English published by the European Commission

In the context of the consultation on the planned requirements for national producer registers under the PPWR, I would like to draw your attention to the resulting burdens for small online traders. I have been a small online retailer in the field of handicrafts for 14 years, I produce all the products in my own name and also manage the online shop as a one-woman entrepreneur.

Filed in German · English published by the European Commission

Ladies and gentlemen, for many years I have been engaged in small online sales (currently no employees other than me) and I have specialised in the sale/trade of automotive spare parts for BMW Young and Oldtimer. For almost two years, I have also been increasingly using the European market, as it offers great potential for customers.

Filed in German · English published by the European Commission

I ship less than 10 orders to the EU in a month. Having to register in each country that orders would cost more than the value of the goods. Additionally I have always reused packaging, cardboard boxes, mailers etc. Rarely purchasing new materials for shipping, Compliance would be an impossibility adding more cost and waste to the process.

I support better recycling and reducing packaging waste, but the current system is far too complicated for small businesses. There should be one EU-wide system where a business registers once and that registration covers all EU countries. Reporting could also be done in one place, with packaging amounts assigned to each country.

As the owner of a small business with additional online sales, I must draw your attention to an impossible aspect of the planned implementation of the PPWR producer register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Subject: PPWR-Manufacturers’ Register Mandatory representative for cross-border sales Dear Sir/Madam, as a family-run shoehouse with a small online shop, we would like to draw attention to a particularly critical point in our view in the planned implementation of the PPWR-Manufacturers’ Register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of…

Filed in German · English published by the European Commission

Ladies and gentlemen, we have been selling online on a small scale in Germany for many years and have regularly supplied customers in other EU Member States. We expressly support the PPWR’s fundamental objectives of reducing packaging waste, promoting recycling and ensuring that companies contribute adequately to the costs of disposing of their packaging.

Filed in German · English published by the European Commission

As a sole trader/micro company with an online shop with both purchased, imported and home-made products, the administrative rules and the additional costs related to the PPWR are not workable. 1. It is an EU rule, why separate registration with different fees in each country. 2. Why is everything placed in the user industry?

Filed in Dutch · English published by the European Commission

Ladies and gentlemen, as an operator of a small online shop, I would like to draw your attention to an issue of the planned implementation of the PPWR which, in my view, is particularly problematic for small traders: the obligation to appoint an authorised representative for extended producer responsibility in case of sales to other EU Member States.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Sehr geehrte Damen und Herren, ich betreibe ein Handelshaus in Braunschweig (4 festangestellte Mitarbeiter) und Handeln mit Briefmarken und Münzen. Etwa 20 % des Umsatzes you Lieferungen in die EU, Tendenz steigend.

Filed in Estonian · English published by the European Commission

Yes. I would formulate this in a factual and clear manner, without exaggerating it. Importantly, you make it clear that the scheme is economically disproportionate for small businesses and, in the worst case scenario, forces you to stop supplying EU countries.

Filed in German · English published by the European Commission

Title/Subject: Alibi bureaucracy rather than real solutions: Why PPWR and national registers fail and how targeted research and foundations create real sustainability ​Dears and gentlemen, ​I use this consultation to point out a fundamental systemic error in the current EU packaging regulation. The structure of PPWR and national individual registers (such as LUCID, etc.) is nothing more than a futile alibi function.

Filed in German · English published by the European Commission

for years, if you set up your business as an individual fighter, you find a niche market and therefore customers around the world. Today, with one strike each EU costs around EUR 300 per year, plus enormous administrative burdens and red tape. Through one strike, this EU is destroying millions of people with the EU Packaging Regulation (PPWR), which an individual fighter cannot afford.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Hello, I would like to see a threshold for small businesses for each country in the future. For example, from the 50 or 100 pack onwards, you will first have to sign a contract in the country concerned. This will also allow small businesses to participate in EU trade. Or that there will be a one-stop-shop solution by being able to conclude a contract for several countries. Please also bear in mind the costs.

Filed in German · English published by the European Commission

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.

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of an online small and medium-sized business, I would like to draw your attention to a critical point in my view regarding the planned implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

As a very small, one-person business selling handmade products online across the EU, I am concerned that the proposed requirements could create a disproportionate administrative and financial burden for micro-businesses. I may receive only a few orders per year from some EU countries, yet I could potentially be required to deal with separate registrations and obligations in each country.