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

Whilst we all want to reduce waste and protect the environment, the proposed obligations are very difficult for small businesses and the self-employed to meet, as we do not have the same administrative, technical or financial resources as large companies. It's utterly against your own Think Small First policy and even violates the principles of a frictionless single market with an insane 27 different systems.

In the board game sector, small businesses (1 persons) cannot technically and humanely comply with PPWR and EPR because the sum of the documents requested in each country and the eco contribution to be paid is disproportionate to the size of our societies. How can companies with one or a few employees have the knowledge to adapt to the rules of each country?

Filed in French · English published by the European Commission

Various problems are encountered by companies in the board game sector: — Small businesses cannot technically and humanely comply with the PPWR and the EPR because the sum of the documents requested in each country and the eco contribution to be paid is disproportionate to the selling price of the board games. How can companies with a few employees have the knowledge to adapt to the rules of each country?

Filed in French · English published by the European Commission

As a micro-enterprise (individual, non-employees, individual artistic products), I operate an online shop and sell workshops. The PPWR affects my business model in a way that, in my view, is disproportionate to its ultimate objective.

Filed in German · English published by the European Commission

I strongly urge the European Union to reconsider the PPWR and, in its current form, withdraw it or substantially simplify its requirements for micro and small businesses. As a small creative business owner, I am deeply concerned about the financial and administrative burden that these new obligations could create.

I ask for the withdrawal of this regulation on behalf of all small creative businesses that may be forced to stop shipping to EU countries because they simply cannot afford the costs and, above all, the endless bureaucracy that would place an unsustainable burden on their businesses. The EU was built to create a common market, yet this regulation would achieve exactly the opposite.

For a de minimis threshold or centralised processing for micro-enterprises, I very much welcome the EU’s initiative to continue tackling online packaging waste. A few weeks after the entry into force of the EU Packaging Regulation, I would like to present my experience as a small businessman: As a sole trader with an etsy shop (online marketplace) for silver jewellery, I see my existence as a side business directly…

Filed in German · English published by the European Commission

Hello, I am a micro company, currently 3000 CA per NA, and hope to get the equivalent of a salary, which plans to send a few dozen small packages per year, containing only paper (and zero plastic, colon on the fingertips). So should I give up this development of activity for a story of paperwork that is irrelevant and completely impossible for me?

Filed in French · English published by the European Commission

We have the feeling and the certainty that EU bureaucrats have no idea of the economy. In your world image, there is a ‘DIE’ economy that earns a lot of money and ‘DIE’ is meant to suffocate small people who are exploited – or, as in this case, under packaging waste. No! The economy is ours!

Filed in German · English published by the European Commission

Despite major efforts, we are currently unable to meet the requirements of the Packaging Ordinance. We still lack the information from upstream suppliers in the supply chain. All suppliers are based in Europe. Documentation at the packaging manufacturer would be useful. This should be examined and passed on to the other levels of the supply chain.

Filed in German · English published by the European Commission

SEMI Europe welcomes the opportunity to provide feedback on the draft Implementing Regulation establishing rules on national registers of producers under the Packaging and Packaging Waste Regulation (PPWR). SEMI Europe supports the Commission's objective of improving harmonisation, reducing administrative burdens, and facilitating compliance through common registration and reporting requirements.

I operate a small online shop in Germany with an annual turnover of < 50.000 and around 1000 orders per year. So far, my offer has been well received across Europe, especially as I am the only source of supply for some products in the EU. As a result of the need to appoint a PWWR delegate and the associated costs (around 8000-10000/year), I had to stop shipping to other European countries.

Filed in German · English published by the European Commission

It seems that the only thing Europe’s communities are able to produce are rules, regulations, legeistlations that make business just impossible! Companies no longer hire employees who produce but check the rules! You killed the automotive industry. You have killed agriculture and you are once again attacking small businesses!

Filed in French · English published by the European Commission

Harmonisation must replace, rather than supplement, divergent national reporting requirements. The Implementing Regulation should prevent Member States from maintaining materially different templates, mandatory fields or reporting categories unless clearly justified and aligned with the EU data set. A common EU data set should be established.

Anitec-Assinform supports the European Commissions objective of establishing a harmonised EU framework for producer registration and reporting under Regulation (EU) 2025/40. Key priorities: Harmonisation: ensure common registration, reporting, packaging categories and data requirements across Member States, limiting national divergences.

If the genuine objective of the PPWR is to reduce packaging waste and prevent disproportionately large packaging from being used for small products then small-format postal items specifically intended for shipping goods should be exempted from these requirements. In particular, any small product that can be shipped inside an ordinary letter envelope should be exempt.

This August 2026, and after over a year of preparation, I have launched my fashion brand, advocating for slow fashion, better consumption, durable and quality pieces of clothes through sustainable materials and circular packaging. A business with good intentions.

Hello, The PPWR must not create new administrative barriers within the European market. Media object companies work with several European countries on a daily basis. The obligation to appoint a representative and to carry out specific procedures in each Member State creates a significant administrative and financial burden, particularly for SMEs.

Filed in French · English published by the European Commission

We submit detailed comments as an attachment and summarise the key points here. 1. THE DRAFT STANDARDISES A FORM, NOT AN INTERFACE. It specifies which particulars must be supplied, but not the machine-readable structure in which they are to be transmitted: no schema, no exchange format, no API, no reference implementation, no test sandbox.

We are an SME in the media object: advertising object and personalised textile. Our job is to source, order by order, from suppliers located in several Member States, who often ship directly to the final customer. So we do not choose packaging and we do not always see it.

Filed in French · English published by the European Commission

As the owner of a Spanish micro-company that distributes to other EU countries, I am obliged to give my opinion, which is not positive, on the new PPWR rules. I have a small brand and I produce everything in the most sustainable way possible. I am fully in favour of legislation that will help improve waste management and reduce its impact.

Filed in Spanish · English published by the European Commission

Ladies and gentlemen, the Gemeinschaft Deutscher Hutfachgeschäfte e.V. (GDH) is a professional association for specialised Hutfach retail trade. Our members include around 80 owner-run specialist dealers, who often run the stationary shop with headgear and accessories (modes) only with family members.

Filed in German · English published by the European Commission

Your true beliefs are determined by your actions rather than your words. With this legislation you have shown that you do not believe that small businesses should form part of the Single Market. We all know that the single market is a failure for services, and now you want to make it a failure for small business goods as well.

This consultation on the Implementing Regulation is taking place in parallel with other important policy and legislative processes to reform the Extended Producer Responsibility (EPR), including the proposal to suspend the mandate of authorised representatives until 2034 (as part of the environmental bus), as well as the Circular Economy Act (CEA) announced for autumn 2026.

Filed in German · English published by the European Commission

Our situation: We are a French company of three people (one manager and two employees) specialising in the purchase and resale of advertising objects, customised textiles and communication media. Our business model has three features that make the registration and tracking of packaging particularly complex: — We work with a large number of suppliers established in several Member States, not with some stable…

Filed in French · English published by the European Commission

Toughness for small and medium-sized enterprises, not just those! For us, it is simply not feasible or unreasonable to set up further more intensive accounting for our packaging, with research into the materials. In that case, the main thrust of our business will be overlooked. Who is interested in what plastic this is, where it comes from, what Co2 print of it, etc....

Filed in German · English published by the European Commission

The PPWR must not create new administrative barriers within the European market. Media object companies work with several European countries on a daily basis. The obligation to appoint a representative and to carry out specific procedures in each Member State creates a significant administrative and financial burden, particularly for SMEs.

Filed in French · English published by the European Commission

The new EU packaging rules are a real sacrifice for small businesses. Ever-increasing requirements, documentation requirements and additional costs create a huge bureaucratic burden. While large corporations have their own departments for this purpose, small businesses have to deal with everything in addition to day-to-day business.

Filed in German · English published by the European Commission

- Die Gebühren für einen Bevollmächtigten vor Ort (in jedem einzelnen Land) sind sehr hoch und lohnen sich für kleine Betriebe oft nicht. Die Grundgebühr ist unabhängig davon, ob man 1 Paket oder 1 Millionen Pakete in ein Land versendet. - Ein weiteres ist, dass der EU-Binnenmarkt kaputt geht. Es gibt jetzt schon viele Betriebe, die nicht mehr ins Ausland verkaufen vor allem kleine und mittelständische Unternehmen.

The objectives of the Packaging and Packaging Waste Regulation (PPWR) cannot be achieved by the requirements of the PPWR in an international aviation environment due to many specificities. PPWR therefore need to be harmonised with aeronautical-specific rules. This applies in particular to the requirements of ICAO, EASA, aviation security law (e.g.

Filed in German · English published by the European Commission

The EUs approach to Extended Producer Responsibility (EPR), packaging and waste-management regulation risks placing a severe and disproportionate burden on small UK businesses. Environmental responsibility is important, but obligations must reflect the amount of waste a business actually generates.

Uwagi do projektowanych obowiązków dotyczących raportowania opakowań ● Jestem szkółkarzem – znam się na roślinach, ich produkcji i sprzedaży, a nie na biurokracji. Prowadzę niewielkie przedsiębiorstwo i chciałbym móc koncentrować się przede wszystkim na swojej pracy.

Filed in Polish · English published by the European Commission

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

Polish Nurserymen Association (PNA) draws attention to the fact that the draft implementing regulation on the format for the registration and reporting of packaging producers under the PPWR imposes obligations on micro and small enterprises that are disproportionate to their scale of operation and to the specific nature of potted plant production.

In principle, as a small and medium-sized enterprise, we support the objectives of the PPWR, in particular resource conservation, recyclability and uniform rules across Europe. However, in terms of practical implementation, we see some disproportionate effects on established B2B business models.

Filed in German · English published by the European Commission

We very much welcome measures to prevent packaging waste. However, the EU Packaging Regulation, which has been in force since 12 August 2026, is deficient in its design and poses unsolvable problems for businesses, not least due to the amended FAQs just before the date of application. The current implementing rules cannot solve these fundamental problems.

Filed in German · English published by the European Commission

Ornamo Art and Design Finland represents designers, artists and design professionals, including sole professionals, micro-enterprises and small design businesses operating in Finland and across the EU Single Market. Ornamo supports the objectives of the Packaging and Packaging Waste Regulation: reducing packaging waste, strengthening circularity and improving producer responsibility.

I am a self-employed designer based in Denmark. I sell my work in small quantities, including directly to customers in other EU Member States. I fully support the environmental objectives of the Packaging and Packaging Waste Regulation. However, the administrative requirements connected with cross-border sales can become disproportionate for very small businesses like mine.

Brussels, September 2026 EUROPEN’s inputs on Article 44(14) of the Packaging and Packaging Waste Regulation, establishing a register of producers for packaging and the obligation on producers to report to their national schemes.

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

Comments on the draft implementing act on article 44(14) of the PPWR (the August version) Office Circular Economy Dato 08-09-2026 General comments The Danish Energy Agency is the competent Danish authority for the PPWR. Responsibility for this area was transferred from the Ministry of Environment in June.

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

The current implementation across Member States is highly unclear and fragmented. It is difficult to determine which national registers are operational. Service providers offer to handle quantity reporting and appoint authorised representatives and producer responsibility organisations on our behalf, but provide conflicting information and charge widely varying fees.

Taito ry supports the principles of the circular economy and sees the reduction of packaging waste as a good objective. Craft operators are often inherently low-emission and resource-efficient, based on long-lived products, reparability and responsible use of materials.

Filed in Finnish · English published by the European Commission

It is beyond question that a company has a responsibility for its packaging, but implementation is so complicated. Even before the new Packaging Regulation, there were individual EU countries in which an authorised representative was necessary.

Filed in German · English published by the European Commission

As a micro business we ship small quantities of orders to multiple EU countries. The costs for PPWR and EPR compliance are greatly disproportionate and unsustainable for micro-businesses. Having to register, pay fees, file reports for every single country separately leads to high costs for micro businesses which they can not absorb. Why not introduce a one-stop shop with equal PRO fees across the EU?

Dear Commission, we are a small online shop based in Hungary - online since 2011. Gradually we were able to introduce a multiligual platform and as such opening to the EU market. The recent changes with EPR and other regulations made already our sending very difficult and cumbersom ... We send approx. 100 orders per year throughout the EU and we can not predict, from which countries we will get orders.

I run a record label as a sole proprietor and small business in Germany. In addition to digital sales, I sell physical mediaspecifically vinyl and CDsand ship them to various EU countries. I use custom-made packaging materials for each format to ensure shipping is as efficient and eco-friendly as possible.

As trading companies, we are in principle fully behind the basic objectives of the PPWR. However, in our view, transposal into practice, in particular the declarations of conformity, is a huge bureaucratic monster which, moreover, does not make a real and comprehensible contribution to achieving the objectives of the Act.

Filed in German · English published by the European Commission

AVBS, the ornamental horticulture and green federation, represents the Flemish ornamental horticulture and nursery sector. The Federation has already discussed the PPWR with industry representatives. For ornamental farms, which are predominantly small to medium-sized enterprises, the impact of the PPWR Regulation risks being disproportionate.

Filed in Dutch · English published by the European Commission

Ladies and gentlemen, we are a family-run medium-sized enterprise and supply around 80 countries worldwide. We support the environmental idea and try to contribute. We are investing in renewable energy, working actively on our energy efficiency and resource-efficient use of our means of production.

Filed in German · English published by the European Commission

As a small business, the burden and costs are so high that we have stopped shipping across the EU. Our packages are small and have only 50-100 g of cardboard per consignment. In some cases, we have only 10 customers per EU country. We can no longer supply all these customers. It is the case that up to EUR 120 additional costs per consignment are borne by customers for goods with a value of less than EUR 100.

Filed in German · English published by the European Commission

In principle, we welcome the objective of harmonising and making more uniform the registration and reporting obligations under the PPWR within the European Union. From the point of view of practical implementation, we wonder in particular to what extent the planned reporting formats will lead to additional requirements compared to the already existing national reporting processes.

Filed in German · English published by the European Commission

As a manufacturer of hair cosmetics, we supply customers at home and abroad who market our products as their own labels under their own brand. However, the practical implementation of the PPWR raises considerable questions and additional red tape for us.

Filed in German · English published by the European Commission

Erion Packaging is an Italian producer responsibility organisation (PRO) operating in the field of packaging and packaging waste. In this capacity, it supports producers in the collective fulfilment of their extended producer responsibility obligations and has a direct operational interest in ensuring that the national registers established under Article 44 of Regulation (EU) 2025/40 are harmonised, proportionate…

We support the fundamental objective of reducing packaging waste. However, it is not clear how the present act is intended to contribute to this. We therefore take a critical view of this draft. In its current form, it results in a significant additional bureaucratic burden for manufacturers without making sufficient use of the possibilities offered by modern digital solutions.

Filed in German · English published by the European Commission

I run a small business in Sweden where I build musical instruments by hand. I sell a small number of instruments each year, including to customers in other EU countries. I care about the environment and understand the intention behind reducing packaging waste.

I am a self-employed ceramic artist based in Bornholm, Denmark. Sometimes I sell one of my ceramic pieces directly to customers in other EU Member States. I also do workshops once a year, where I sometimes have people from close neighbour countries attending, and when the ceramic piece they made in my workshop is ready a few weeks later, I send it to them.

We are a family-run medium-sized trading company supplying customers both domestically and in different EU Member States. We strongly support the objectives of the PPWR. However, concrete implementation risks creating new red tape and de facto barriers to trade for SMEs in the European single market. National registration and EPR obligations are particularly problematic.

Filed in German · English published by the European Commission

I am an independent PPWR compliance practice based in France, advising brand owners and private label operators across several Member States. These comments are confined to the technical content of the draft implementing regulation and its annexes. 1. Annex II, Parts A and B the plastics categories are not mutually exclusive Category 10.0 covers PE and PE-majority composites, rigid.

The PPWR pursues the right objective of reducing packaging waste. However, this objective should not be confused with the development of ever-increasing registration and reporting structures. A system that only records packaging quantities in more detail does not yet achieve waste prevention.

Filed in German · English published by the European Commission

Good afternoon, we warmly welcome the prevention and introduction of packaging into the recycling process and appreciate the improvements. In our view, 100 % of the costs of the disposal process should be incurred where packaging is produced. All information on species and weight is available here. This should also apply to special/gift packaging. Once a packaging is sold, it is already registered.

Filed in German · English published by the European Commission

We are a small export farm with 7 full-time employees and export plants to more than 15 European countries. We support the objectives of the PPWR and the importance of more sustainable packaging. At the same time, we are deeply concerned about the practicability of regulation for small businesses operating across borders. See our reply in the attached annex

Filed in Dutch · English published by the European Commission

As a small retailer in the advertising sector, we support the objective of reducing packaging waste and strengthening recycling across Europe. At the same time, the implementation of these objectives must not lead to disproportionate bureaucracy for small and medium-sized enterprises. As a trader, we have no influence on the packaging design or on the choice of the packaging materials of our suppliers.

Filed in German · English published by the European Commission

I do not understand the benefits of PPWR initiative at all. In what world does it make sense for one-person to small businesses have and pay for a representative in every single EU country in order to send a package? How is this aligned with goals of EU and being able to trade across EU without unnecessary byrocracy?

This Regulation creates unnecessary costs and administrative burdens. The fees should be charged by the manufacturers of the packaging directly when selling the packaging to the purchaser. This would be the simplest and cheapest. Why not implement it?

Filed in German · English published by the European Commission

I am a producer of ornamental plants operating a nursery with 16 permanent employees and up to approximately 35 employees during the production season. We produce around 2 million plants annually, with approximately 50% of our production sold to customers in other EU Member States.

the PPWR standard in force since 12 August 2026 increases red tape and costs for small businesses. It seems to us that commitments that would need to be resolved elsewhere are being passed on to companies. To date, micro-enterprises are already following, both on a compulsory and a voluntary basis, a process of compliance with environmental and governance regulations (see ESG), thanks, for example, to the support…

Filed in Italian · English published by the European Commission

In the EU, it should be possible to send this documentation without being able to do so. The burden is far too great. As a small retail outlet, the costs are too high. All of this is opaque. There should be a lot of simplification and it should not be necessary to register and pay twice and three times.

Filed in German · English published by the European Commission

Dear European Commission,I am writing to express my deepest concern regarding the practical consequences of the new Packaging and Packaging Waste Regulation (PPWR), particularly the requirement for micro-enterprises to register individually in every EU member state to which they ship goods.While the environmental goals of reducing packaging waste are vital, the current regulatory framework creates an insurmountable…

We are a small, owner-managed German importing and trading company specialising in customised promotional products. A substantial proportion of our products are manufactured for individual customer orders by different suppliers outside the EU, particularly in Asia. We support the objectives of the PPWR and the harmonisation of producer registration and reporting requirements.

Ladies and gentlemen, as the owner of a small family-run nursery, I would like to draw your attention to the planned additional requirements for packaging registration. Our company is a second-generation family business with 10 employees. We produce our plants ourselves and sell them mostly within a radius of around 50 km. We produce packaging only in small quantities.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a small e-commerce company, we would like to draw attention to the significant economic consequences of the obligation to appoint an authorised representative for extended producer responsibility (EPR) in cross-border sales under the PPWR.

Filed in German · English published by the European Commission

As a solo-founder microenterprise (leather goods, e-commerce) selling across multiple EU markets, I support the goal of a harmonised registration/reporting format. However, the draft only simplifies the reporting format for producers under 10 tonnes/year. It does not simplify registration, which remains identical regardless of producer size.

I understand and support the objective behind the EUs packaging legislation: reducing waste, increasing producer responsibility, and creating a more sustainable European economy. However, the way these obligations are currently implemented creates a disproportionate burden for small and micro businesses, particularly those selling across EU borders.

Small cross-border businesses need one EU compliance procedure I support the environmental objectives of the PPWR and the aim of harmonising producer registration and reporting. However, the proposal does not solve a fundamental problem for small businesses in the Single Market: separate compliance in every Member State where we have customers. I operate a small specialised electronics business in the Netherlands.

Packaging and packaging waste – rules on national registers of producers While the EU Packaging and Packaging Waste Regulation (PPWR) certainly contains many sensible measures to tackle the pressing concern regarding packaging waste, the proposed rules regarding the registration and reporting formats do not address the highly problematic issues caused by the regulation.

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

Dear Commission, what should I say? the rationale is right; implementation is problematic for all companies. I would change the following: A simple register with ID, where the manufacturer declares conformity once. After that, it is no longer necessary to declare conformity every time. Easy calculation Europe-wide: Weight x price x material factor (I would define large groups of materials here).

Filed in German · English published by the European Commission

Hello, as a small horticultural company with four employees, we feel very burdened by the new regulations. We produce small quantities of plants ourselves. If a plant becomes too small for the pot used, individual plants of a ‘batch’ (sometimes consisting of only 10 plants) are sometimes packed into two different pot sizes. The old pots will not be thrown away, but we are waiting for their next use as planters.

Filed in German · English published by the European Commission

I run a very small company in Finland. It is just me. I make skincare products and do everything myself, product, packaging, shop, customer service, accounting, all of it. I am writing because I am genuinely worried about what PPWR and the national EPR rules built on it are doing to businesses like mine, and I do not think that worry is being heard. I am not against the idea behind this law.

EKO-KOM, a.s. is the sole Packaging Recovery Organization (PRO) in the Czech Republic providing EPR services to over 21 thousand enterprises placing packaging on Czech market and assuring its separate collection and recycling within 6208 municipalities covering 99 % of the Czech population. The full commentary on the drafted Delegated Decision is attached to this feedback.

We would like to express the following views on the legislative act: 1) A separate registration in each country involves an enormous amount of work: understanding the specific requirements of each country, registering 27 times, and then constantly uploading data 27 times and paying 27 invoices. On top of that, managing 27 accounts, updating 27 accounts when a member of staff changes, carrying out 27 audits, etc.

We are a wholesaler of promotional items (established in Germany, 18 employees) and are responsible for medium-sized and large companies in the field of promotional items. We manage the ranges, store and ship them all over the world.

Filed in German · English published by the European Commission

Ladies and gentlemen of the European Commission, as European SMEs, we support the environmental objectives of the new Packaging Regulation (PPWR) to reduce packaging waste. However, the current practical implementation of this Regulation leads to exactly the opposite of what the European Union stands for! It destroys the free European single market for small and medium-sized enterprises (SMEs).

Filed in German · English published by the European Commission

Mandatory national representation: a structural brake on intra-European trade For a company of our size, operating in several European countries, the obligation to appoint a tax or legal representative in each Member State is, in practice, unmanageable. Each country imposes its own formalities, its own interlocutors and its own deadlines.

Filed in French · English published by the European Commission

We operate a medium-sized sawmill and have a turnover of around 60 million. Our main markets are outside Germany (30 %) in EU countries (70 %). We benefit from the achievements of the single market that has been created. No border controls, no tariffs, a single currency makes it easy to exchange goods and is one of Europe’s great success stories.

Filed in German · English published by the European Commission

Ladies and gentlemen, the new PPWR is a disaster for small and medium-sized enterprises. We do not have the human and financial cushion to carry out such burdensome administrative tasks in addition to the existing day-to-day business. As a self-employed person, I already work 60-70 hours a week, and instead of alleviations, new entitlements constantly accrue to us.

Filed in German · English published by the European Commission

Hello there, I am one of many small sellers from around the world who is affected by the new rules of the waste reduction actions law. While I appreciate the efforts to reduce waste, particularly plastics, the way it's being implemented hurts small businesses like us. We don't have the ability to hire the required representation in any state within the EU.

Hello, for us, your regulation means the end of our activities in Europe. We can only sell economically to the US. Bad, because we were on the right track. Five years of reconstruction work have now been wasted. We are nearing the end. Your regulation is completely contrary to the European spirit of free movement of goods, and unfortunately one has to say that it does not reveal any idea of economic connections.

Filed in German · English published by the European Commission

Ladies and Gentlemen of the European Commission, Europe is by far the slowest growing economic region in the world. Brussels is making a significant contribution to this with a love for bureaucratisation and complication, which is already kafkaesque in scale: Supply chain due diligence, the Accessibility Regulation and now the Packaging Regulation (inter alia). Omitting freedom-restricting measures such as DSOs.

Filed in German · English published by the European Commission

The increasing density of regulations, documentation requirements, reporting procedures and evidence is becoming an increasing burden on businesses. The problem is not only competitiveness. On the contrary, the ever-increasing bureaucracy requires considerable human, financial and organisational resources, which are lacking for the actual business activity. The EU Packaging Regulation is a concrete example of this.

Filed in German · English published by the European Commission

The German nursery sector has an annual turnover of around 1.3 billion, covering an area of 15.350 hectares with 14.500 workers per year; around 20 % of annual turnover goes to exports. This means that 1368 mostly small and medium-sized enterprises produce over 30.000 different tree species and varieties that contribute to biodiversity. The Federation of German Nurseries (BdB) represents around 900 nurseries.

Filed in German · English published by the European Commission

Following registration across multiple separate registries required to sell on major marketplaces, the financial toll amounts to an additional 1.04 euros per shipment. This reality stands in stark contrast to the EU's stated recycling and sustainability objectives, calculated here on a volume of 10,000 courier packages annually.

Ladies and gentlemen, I operate a very small handmade business in Germany and sell handmade products via an online marketplace. At present, I am sending only within Germany. In future, I would in principle like to extend my mailing to other EU countries, thereby reaching customers within the European single market.

Filed in German · English published by the European Commission

Fecc welcomes the European Commissions initiative to establish a more harmonised framework for national registers of producers under the Packaging and Packaging Waste Regulation (PPWR). In the attached feedback, Fecc provides practical considerations from the perspective of the chemical value chain, with a particular focus on consistent implementation across Member States, proportionate data requirements…

This is a very difficult and costly procedure. These small businesses cannot be covered. Why not include the cost of packaging in the transport price and ensure that each courier pays the revenue to the local government? It seems to be a simple and economical solution.

Filed in Italian · English published by the European Commission

PPWR must not exclude small businesses from the European single market We are Ayluna Naturkosmetik GmbH, a small German company. So far, we have also sold our products directly to end customers in other EU Member States via our online shop.

Filed in German · English published by the European Commission

In order to enable all businesses in the EU (from small businesses to large corporations) to participate in the EU’s internal market, the costs of registration and data collection must be significantly reduced. Otherwise, the PPWR will mean that many small businesses will no longer be able to participate in the EU’s internal market and will only sell nationally.

Filed in German · English published by the European Commission

We are small-scale SMEs. For the first time, learning what all these administrative rules mean for us is a huge effort and can only be implemented in an understandable form with the help of AI. It is a scandal for us and we are sure that we are speaking for the largest share of our like-minded SMEs to live in a so-called Union, which has promised to simplify everything since the beginning and now imposes nothing…

Filed in German · English published by the European Commission

In the case of small farms in particular, the financial and, above all, time-related costs are not worthwhile in terms of the benefits of the PPWR in question, as they have not yet materialised. Perhaps the harmonisation sought is somewhat lightening the burden. The burden on the taxpayer is also not negligible.

Filed in German · English published by the European Commission

Sehr geehrte Damen und Herren, als inhabergeführter Bäckereibetrieb mit einer größeren Betriebsstruktur und einer Vielzahl an Verkaufsstellen verfolgen wir die geplanten Regelungen zur Umsetzung der europäischen Verpackungsvorschriften mit großer Sorge.

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)

Ernster is an independent medium-sized bookselling company established in Luxembourg. As a company operating in a small country at the heart of the European Union, cross-border shipments are a normal part of our activities. Although Ernster is a medium-sized enterprise, the number of parcels shipped to individual Member States may remain limited.

Filed in French · English published by the European Commission

Let us take a very simple example. A small European business makes ceramic cups by hand. That is its business. It designs them, produces them, fires them and sells them. It does not manufacture cardboard. It does not run a recycling company. It does not collect packaging waste. It has nothing to do with the waste-management industry. But then it puts one ceramic cup into a cardboard box and sends it to a customer.

We welcome the European Commission’s aim to harmonise requirements for packaging and packaging waste within the European Union. Uniform rules can in principle contribute to greater transparency and comparable conditions of competition.

Filed in German · English published by the European Commission

Register of producers under Article 44 PPWR disproportionate burden for SMEs in cross-border B2B supplies We welcome the aim of harmonising the requirements for registers of producers within the European Union. However, from the point of view of a German SME, the planned implementing regulation should be more focused on effectively avoiding multiple registrations and parallel national administrative procedures.

Filed in German · English published by the European Commission

Opinion on the practical implementation of the PPWR from the point of view of a medium-sized importer and wholesaler We support the PPWR’s objective of reducing packaging, improving recycling and, above all, creating uniform rules within the EU. However, in practical preparation for the new requirements, we note that there is still considerable uncertainty in some places.

Filed in German · English published by the European Commission

I run a one-person garage specializing in classic American cars. I import a large number of parts and vehicles from the USA, and one of my US suppliers has stopped supplying to Europe because of the PPWR. The rules surrounding the PPWR are unclear.

We are considered micro-enterprises within the meaning of the PPWR. After discussions with our cartonboard producer, it became clear to us once again that this regulation needs a fundamental overhaul! First of all, the cartonboard producer was not aware of the existence of the micro-enterprise scheme. After further consultation, he described it as a voluntary service to assume the role of producer in our case.

Filed in German · English published by the European Commission

As the owner of MerchMeister e.Kfr., a small owner-run company for promotional items and customised business boxes, I support the objectives of the PPWR in principle: Packaging should be avoided, materials reused and resources conserved.

Filed in German · English published by the European Commission

Good afternoon, we are a plant wholesaler in Germany, exporting mainly plants to Denmark and Sweden. We are a small company with 7 employees. We are totally unable to meet the new packaging requirements. We already have very limited working time to meet other legal requirements, e.g. every month we have to submit our export data (Intrastatt), which is already a lot of work.

Filed in German · English published by the European Commission

Subject: Urgent need to improve the PPWR Implementing Regulation: Preserving the EU’s internal market for small and medium-sized enterprises (SMEs) Dear Sir/Madam, the fundamental objectives of the PPWR to prevent waste and promote the circular economy are correct and necessary.

Filed in German · English published by the European Commission

Rolls-Royce develops and delivers complex power and propulsion solutions for safety-critical applications in the air, at sea and on land. Our products and service packages enable our customers to connect and protect people, societies, cultures, and economies together, and they meet the growing need for power generation across multiple industries.

We are a small, owner-run two-person business in the B2B advertising trade and we work almost exclusively on a project-by-project basis. Our customers approach us with specific requests, we advise, source suitable products and, in around 90 % of cases, have them delivered directly from the manufacturer to the customer.

Filed in German · English published by the European Commission

As managing director of a small company, I strongly oppose the new PPWR. It is reasonable for small and medium-sized enterprises to meet the conditions. It is not financially possible for most small businesses and they are thereby excluded from the EU’s single market. The PPWR must be amended in such a way that small quantities supplied to EU countries are exempt from the new rules.

Filed in German · English published by the European Commission

We are a small owner-run family business from Germany active in the sale of advertising goods with three employees. We support the fundamental objectives of the PPWR, in particular the avoidance of unnecessary packaging, the promotion of recyclable materials and the responsible use of resources. However, the concrete implementation of the Regulation is of great concern to us as a small business.

Filed in German · English published by the European Commission

Konsultationsbeitrag zum Entwurf einer Durchführungsverordnung über das Format für die Registrierung und Berichterstattung im Herstellerregister im Rahmen der PPWR Die Handwerkskammer Koblenz vertritt die Interessen von rund 21.900 Mitgliedsbetrieben aus dem nördlichen Rheinland-Pfalz/Deutschland. Die Mehrzahl unserer Mitglieder sind Kleinstbetriebe mit etwa 10 Beschäftigten.

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)

As a small specialist print shop for advertising balloons and trade fair balloons with only a few employees, the PPWR meets us with the same bureaucratic workload as a large group with its own compliance department. The EU does not provide for a general exemption for micro-enterprises.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a medium-sized enterprise, we have always been keen to manage our resources as sustainably and sparingly as possible in order to save costs. The PPWR Regulation now creates requirements that are disproportionate to the benefits and poses challenges for SMEs in particular, which in our view are detrimental to business.

Filed in German · English published by the European Commission

The EU packaging rules place an impossible administrative burden on self-employed people and microbusinesses. Small entrepreneurs working alone are expected to understand different registration systems, authorised representatives, recycling contracts and reporting obligations in every country where they sell. There is no clear, affordable, centralised system and very little practical assistance.

I welcome a reduction in packaging waste but as i have a small handmade pottery business in ireland I only have small sales to different countries in the eu each year. I try to use a mix of recycled packaging and filling for orders so it would be impossible to follow PPWR rules and I will have to suspend my shipping to the EU.

The objectives of the PPWR in terms of resource conservation, recycling and more uniform packaging regulation across Europe are basically understandable. In practical implementation, however, much more attention needs to be paid to the fact that administrative obligations are relatively much more burdensome for small and medium-sized enterprises than for large enterprises.

Filed in German · English published by the European Commission

Ladies and gentlemen, uniform rules as a framework for all economic operators are definitely necessary and indispensable. But how can you seriously believe that the PPWR law could improve anything from an environmental point of view?

Filed in German · English published by the European Commission

I am a small, family-run producer with around 4,000 customers across Europe every year. And apparently, I now need to charge each of them an additional 3.40 for shipping not because the courier suddenly became more expensive, but because I have to comply with another piece of European green bureaucracy. 3.40. So how exactly am I supposed to explain to a customer that 3.40 is the price of recycling a courier bag?

Moin, why is the supply chain not placed first, the producer must confirm and implement the information in accordance with EU law and confirm it with a suffix, and only then does the product go to the world! So it’s easy to follow. I’m about to open my webshop and we’ll be painted again.

Filed in German · English published by the European Commission

Ladies and gentlemen, the new legal situation with regard to the PPWR Regulation causes considerable additional effort, unpredictable costs and time for our company. We wonder who should be involved in this matter and who should pay for it?! All of this feels like a fever room!

Filed in German · English published by the European Commission

As a small business model operating in the European single market, I am obliged to pay more than EUR 10.930 in registers, administration and companies responsible for accounting for packaging used for transport. This simply physically kills my business. Here are a number of fundamental questions. Last year, my total expenditure on packaging was EUR 1.560.

Filed in Spanish · English published by the European Commission

Plastics Europe supports the objective of establishing common formats for registration in, and reporting to, national producer registers in the context of the PPWR. Effective harmonisation is essential to the functioning of the Single Market: companies operating in several Member States should not face divergent data fields, classifications, submission processes or national interpretations for the same EPR…

I fully share the view that all of this is a huge dilemma, which is supposed to disguise itself as an eco-policy. There is simply no reasonable explanation why packaging transported within the EU should be distinguished according to whether it originates from a producer or private individuals. At the end, every single package must be recycled, regardless of who the sender is.

Filed in German · English published by the European Commission

ASPACK, the Spanish association representing manufacturers of folding cartons and other paperboard packaging, welcomes the Commissions initiative to harmonise national packaging producer registers. We support the objective of improving transparency and reducing administrative burdens, provided that the new requirements are proportionate and do not duplicate existing obligations.

Ladies and gentlemen, as the operator of a small two-person 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 writing to you because I am directly concerned by the new requirements concerning the Packaging and Packaging Waste Regulation (PPWR), which entered into force on 12 August 2026, as a small entrepreneur. As Water The Goods, my business partner and I support the objective of reducing packaging and promoting recycling.

The basic principle behind the PPWR is sound: to avoid unnecessary packaging and promote recycling. However, the current implementation places a disproportionate burden on small businesses in terms of costs and reporting obligations, even where only the smallest quantities are dispatched to other EU Member States.

Good afternoon, we have a medium-sized nursery. In the context of environmental protection, we have been recycling all pots, containers and tracks for years in our own interest. As an example, we are using our commemorative pots for the 25th anniversary of gardening as early as the 11st anniversary. Year. These are filled up to 3 times a year.

Filed in German · English published by the European Commission

I am a self-employed capmaker based in Denmark. I sell my work in small quantities, including directly to customers in other EU Member States. I recycle the packaging whenever I can. So I pack some of my goods in packaging that I already received, when I receive raw materials for my caps from ex. Weaveries, fabric suppliers ect.

Grundsätzlich begrüßen wir das Ziel der PPWR, europaweit einheitliche Anforderungen an Verpackungen und Verpackungsabfälle zu schaffen und dadurch mehr Transparenz und Nachhaltigkeit zu erreichen. Aus unserer praktischen Erfahrung bestehen jedoch erhebliche Bedenken hinsichtlich der Umsetzbarkeit der Verordnung im betrieblichen Alltag.

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)

Ladies and gentlemen, as the operator of a vesand bookshop, 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, regardless of how many consignments we carry out to the…

Filed in German · English published by the European Commission

As a microbusiness/artist in Canada that is looking to deepen ties with the EU, this regulation makes it prohibitively expensive in both time, money and bureaucracy to actually provide physical products to the EU or even produce products in the EU.

I have a small one-man business based in the UK. My sales to the EU contribute perhaps 60% towards my total global sales. The new EPR legislation means that like many artists, creators and small businesses, I have had to withdraw from the EU market. I commend any government that makes moves towards reducing waste.

This regulation and the obligation to have 27 representatives for counting packages, given that every courier has tracking, completely close the European market to me and my production. It is evident that the GREEN DEAL is a pretty good DEAL for many companies. At least that is what history has shown in the last 10 years. I don't know if these over 400 deputies who voted for this madness have a conscience.

As a person who is an independent artist, almost half my sales are from the internet, a great deal of which was formerly overseas. PPWR took away so many of my sales. None of my fellow small businesses can afford to a representative to be able to keep shipping to the EU.

As a person who is an convention artist, my money comes from 3 sources commission from other people in the collective, social media and sales made directly. PPWR took away most of those. Neither me or my colleagues can afford paying for representatives in every country to keep our buisnesses afloat. The market is saturated, so getting a convention table isnt always possible.

As a small family manufacturer with about 1500 shipments per year throughout Europe, my cost for recycling one courier package will be exactly 9.12 Euros. All offers for a local representative have some extremely unrealistically high prices. How do you think I can exist?

This comment alone from the draft should be enough to understand why such a regulation is wrong, obsolete and goes against the very basic principle of a free market that was intended when the EU was established : « beyond the harmonised provisions laid down in that Regulation, including by setting additional national recycling targets. ».

I am an independent artist living in Italy, selling my own artworks. I use recycled packaging since I deeply care about the environment. I can't see another way to understand the new PPWR law other than coming from a wish to remove artisans, artists and small businesses from the market so that the big, mass producing (and famously unethical) companies can take it over.

Dear Eu commission, I do love Europe genuinely, I really think it is the best place to live in the world. I am a German-French 42year old employee living in Italy where I started a side business as a jewelry maker.

I support the European Unions goal of reducing packaging waste and improving recycling across Europe. However, the current packaging and Extended Producer Responsibility requirements create a disproportionate administrative and financial burden for micro-businesses, artists, and self-employed people.

Hello, I am a small manufacturer of wooden products based in Finland. My main market is outside Europe, but I send about 400 courier packages within the EU every year. This regulation has closed the doors to the European market for me personally. I cannot afford to pay such expensive administrative services, if I did, my production would become about 45% more expensive, which is completely absurd.

As a ceramic manufacturer who sends about 1000 shipments to the EU, I would say that this is a huge scam. I have to give 60% of my hard-earned money to some companies that count packets. What is this policy? This is so cruel to small businesses all over Europe.

Hello, I am an artist and myself have a small business. Thanks to the new EU Packaging Regulation, I lose 600 every month! This may not be a lot for politicians, but it’s a lot of money for me... I do not have any employees and I work entirely on my own. I depend on my salary I can now start again from scratch and see how I can get it back on my feet... Years of work for nothing.

Filed in German · English published by the European Commission

I am a self-employed micro-entrepreneur in Portugal, running a very small handmade business. I support the need to reduce packaging waste and protect the environment. What I cannot understand is how the current system can be considered proportionate for businesses operating on a very small scale.

I am a French artist-author running a very small online business selling my own original artworks and art prints directly to consumers across the European Union. I fully support the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR).

I am a small single person business owner in the US. I sell between 5-20 packages per year spread across the EU. To find a representative in each country would be $300-$800 USD per country. I will no longer be able to share my artwork with all the wonderful community members who have supported me over the years. Each of my sales are between $15USD - $25USD and would not make sense for me to sell in the EU.

I am artisanal jewelry maker in the US, I sell mainly on Etsy. My designs are unique and I enjoy a loyal following in Europe. Let's state first that I support the goal of the legislation, however the implementation as is will force me to stop shipping to most EU countries. The patchwork of requirements that change from country to country, the separate registration costs and Authorized Representatives.

Urgent Need for Proportionality, Microenterprise Exemptions, and Recognition of Informal Reuse I am writing to express significant concern regarding the practical application of the new Packaging and Packaging Waste Regulation (PPWR) on small businesses and microenterprises.

As a small business we usually ship under 5 items to certain countries for a profit of under 100 euros. This legislation introduces costs per country that are higher than this amount alone which forces us and any business of our size to completely stop shipping to those countries.

Dear European Commission, the ETO as the umbrella industry association of the European aftermarket automotive accessories industry supports the objectives of the PPWR: reducing packaging waste, improving recyclability and harmonising packaging rules across the EU.

I am writing this not as a corporation or an industry representative, but as one person trying to earn an income through a very small business. I was not able to pursue the education I would have wanted because of its cost. Like many people, I do not have substantial capital, investors, employees or professional advisers behind me.

We would like to highlight the importance of ensuring that the proposed reporting requirements remain proportionate and practically implementable, particularly for SMEs and micro-enterprises. The distinction between producers placing less than 10 tonnes and those placing 10 tonnes or more of packaging on the market per calendar year is a positive step.

I am a small independent jewellery seller based in Canada, selling handmade products through an online marketplace to customers in Europe. I fully support the environmental objectives of the PPWR and the principle that businesses should take responsibility for the packaging they place on the market. I am willing to pay reasonable recycling and packaging contributions based on the actual amount of packaging I use.

As a small business owner (Micro enterprise) this principle behind this bill makes sense, ie everyone try to use as much recyclable packaging and reduce packing as possible. But the approach and demand both administratively and financially put on small businesses is effectively closing the European single market to them. My personal experience, just with a single customer.

I support common packaging labels and one reporting system across the EU. EPR fees make sense if the money is used for collection and recycling. What makes no sense is forcing a small company to deal with 27 registers, procedures, fees and authorised representatives because it sends a few parcels to other EU countries. Responsibility should stay with the company that controls the packaging, material or data.

My company Leo Ropes Ltd , make specialised performance ropes for Circus, and though we are micro company we are one of the premium rope making companies worldwide, selling to companies like Cirque du Soleil. With the new flat rate EPR representation fees, I have to stop selling ropes to 17 out of the 19 EU countries I usually supply to.

The new PPWR EU legislation looks like it has been created only with the large companies in mind. It has been put into force without any regard to the small businesses that sells small amount of items to a few countries across Europe. My business is located in the UK.

Below are three case studies and possible solutions. Case study #1: Under the law, micro-enterprises that have packaging manufactured to their own specifications on a contract basis are exempt from the manufacturers obligation, and the role of manufacturer is then transferred to the supplier. There is no obligation to notify the supplier of the micro-enterprises status.

We are a micro-enterprise from Croatia with three employees, selling our handmade products online to consumers in all 27 EU Member States. Our turnover is not concentrated in one or two large markets it is spread thinly across the entire Union. No single country accounts for a large share on its own, but together these many small markets make up the majority of our business.

I run a small business. There are two of us. We produce in Europe and sell to customers and to independent shops across sixteen EU member states. I want to be clear at the start that I am not against extended producer responsibility. I am registered in Germany, I hold an active packaging licence and I pay my contribution every year. I think the polluter pays principle is right and I am willing to pay my share.

Ladies and gentlemen, the EU Packaging Regulation makes it almost impossible for smaller companies to continue the existing business successfully. However, as I do not currently know how we can solve this problem, I am writing to you in the hope that you will support us. More specifically, we account for around 25-30 % of our turnover outside Germany.

Filed in German · English published by the European Commission

I am theoretically obliged to appoint agents. However, there is not yet a usable structure for this, which is why I am unable to do so. For me, as a one-man business, this deprives me of the possibility of European trade, as I will have to expect payment of stamps on every shipment.

Filed in German · English published by the European Commission

The European Federation of Auctioneers (EFA) represents over 3,500 auction houses across Europe, primarily small and medium-sized businesses with annual turnovers often below 5 million. Our members trade in unique cultural goods (paintings, sculptures, books, etc.), each requiring individual, handcrafted packaging tailored to its size, weight, and fragility.

The Kunsthändlerverband Deutschland (KD) represents the leading art and antique dealers and auction houses in Germany. Our member firms are mainly micro-enterprises with fewer than 10 employees. Your customers are not only in Germany but also abroad, including in other EU Member States. The works of art and art objects with which our members trade are unicate.

Filed in German · English published by the European Commission

Nearly a month under this regulation: tens of thousands of European micro-businesses wiped out, zero actual progress. The harsh truth of EU rulearrogant to the core, uncompromising, and utterly brainless. As a small ceramic artisan shipping 500700 parcels across the EU annually through Etsy and eBay, this regulation has completely locked me out of the "free market"a concept that proved to be a worthless scrap of…

As a small business with over 50 years of history and approximately 1,000 shipments annually within the EU, I wish to express my utmost concern regarding the current wording of this regulation. The heavy financial and administrative burden will either block small businesses from accessing Europe's single market or drive production costs so high that our goods become unaffordable for the end consumer, ultimately…

As a UK-based micro business (sole trader) selling stationery and phone cases directly to consumers in the EU, I welcome the Commission's effort to harmonise registration and reporting formats under Article 44. A single standardised electronic format across Member States is a real improvement over today's patchwork of national systems.

The current implementation of the Extended Producer Responsibility (EPR) packaging laws is an absolute disaster for small entrepreneurs. Instead of protecting the environment, it is effectively shutting independent creators out of the EU Single Market. I run a micro-business in the Netherlands, working incredibly hard for a modest monthly profit of around 800.

According to FEVAD (the French E-commerce and Distance Selling Federation), there are roughly 153,000 to 200,000 active e-commerce sites and businesses in France. A massive percentage of these are independent sellers, artisans, and micro-enterprises operating out of their homes or small workshops.

The proposed rules on registration and reporting formats to national packaging registers do not address the significant barriers to cross-border trade within the EU caused by the PPWR as requiring businesses to register and report separately in every Member State would impose substantial administrative and financial burdens, particularly on small and micro-enterprises.

As a small-scale organic farming business shipping just over 1,000 packages annually across Europe, I am facing an unsustainable administrative burden. Compliance costs alone will consume approximately 56% of my net annual profit.

The LIFE4EPR project would like to draw the European Commissions attention to work currently being carried out within the project that is directly relevant to the implementation of Article 44 of Regulation (EU) 2025/40. LIFE4EPR is an EU-funded LIFE project aimed at supporting greater harmonisation of Extended Producer Responsibility (EPR) systems across the European Union.

SNA | SYNDICAT DES NÉGOCIANTS EN ART EUROPEAN COMMISSION | PPWR Ref. Ares(2026)8453833 - 04/09/2026 FORMAL POLICY SUBMISSION PPWR - National Registers of Producers SNA position on the draft Commission Implementing Regulation Ares(2026)7688068 | 4 September 2026 Organisation identification ORGANISATION Syndicat des Négociants en Art (SNA) LEGAL SEAT 8 rue Saint-Marc, 75002 Paris, [name removed] SIREN 784 854 119 |…

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

Lempertz is one of the leading art auction houses in Germany and the oldest family-owned auction house in the world. We hold auctions of around 5,000 works of art and art objects every year, spanning a wide range of categories, periods and regions. Our clients include art collectors, art dealers and art institutions worldwide.

The industry supports the PPWRs environmental objectives but is seeking a more proportionate, practical and legally certain implementation that does not push smaller businesses out of the market. The proposed Regulation does not fix issues publishers would have when they must send packages in several member States.

I love the goal of reducing waste and creating a more sustainable waste processing system. This is why I have used recyclable shipping materials for a long time. However, as an independent artist, I do not have the time or money required to be compliant with all 27 EU member states under these new regulations.

It seems that, with these new packaging regulations, the EU has once again overlooked the reality of micro and small businesses the very businesses it should be supporting and helping to grow. I recently moved my business from the UK back to Portugal, my home country, with the belief that returning to the EU would mean benefiting from a single market, fair trading conditions and a more straightforward regulatory…

DANSK ERHVERV Børsgade 4 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2026)8443957 - 04/09/2026 Danish Chamber of Commerce response to the draft Implementing Regulation on registration and reporting under Article 44 in the PPWR General remarks The Danish Chamber of Commerce welcomes the Commission's objective of establishing harmonised formats for registration and reporting under…

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

PPWR EPR requirements create a disproportionate administrative burden for micro and small cross-border webshops. I support the environmental objectives of Regulation (EU) 2025/40 and the principle that producers should contribute to the management of packaging waste.

We are a small family-run nursery with a total of five people, including three family members and two non-family employees. Our daily work is primarily about cultivating, caring for and selling plants. As a family, we carry out the necessary office and administrative work in addition to our actual work. In principle, we support the PPWR’s objective of reducing packaging waste and using resources responsibly.

Filed in German · English published by the European Commission

Lubin,4 września 2026 Uwagi do projektu rozporządzenia wykonawczego Komisji Europejskiej dotyczącego formatu rejestracji producentów oraz zasad sprawozdawczości do rejestrów producentów na podstawie rozporządzenia (UE) 2025/40 (PPWR). KGHM Polska Miedź S.A.

Filed in Polish · English published by the European Commission

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

As a manufacturer of personalized bathroom accessories with 26 years of experience on the European market, I cannot hide my huge concerns about the growing bureaucratic burdens that are being created to serve various private interests related to a number of EU environmental policies. A pure idea for a cleaner Europe is becoming a horror for all residents of this continent.

We deliver to almost all EU countries with packaging that we produce ourselves. We therefore need to document the packaging and report it to the relevant countries. This can only be done with an authorised representative. There are costs for registration, plenipotentiary, administrative fees, etc., and for each EU country we deliver to. We have calculated this by means of an example.

Filed in German · English published by the European Commission

In principle, we welcome any simplification and harmonisation of the registration obligation for the Packaging Regulation. In our view, a single, harmonised registration body is mandatory. Companies in each country must not have to search for the registration body, which may still require different requirements. The EU should offer an EU-wide platform that makes it easier for companies to register.

Filed in German · English published by the European Commission

As a small manufacturer of garden decorations, I cannot hide my immense concern about yet another absolutely pointless bureaucratic burden that all businesses in Europe are subjected to. Recycling is an activity with an environmental purpose, which has been a business for decades throughout Europe, and not an expensive administrative activity. I cannot hide my absolute anger at various packaging registers.

This year I had 18 orders (18 envelopes) shipped to EU countries from my small handmade postcardcard shop. Under this system, that means I would have to register and pay a fee in every single one of those countries - I don't even earn that much from my shop in total. This is absolute nonsense, and I am very disappointed.

We are a small craftsman and live from shipping to all EU countries. Unfortunately, there are countries in which we only have around five consignments a year. We send to other countries more often, but mainly to other smaller companies. However, they already have their own licensing in the country. Our dispatch takes place in small cardboard boxes, which often weigh only 100 grams and are only of letter size.

Filed in German · English published by the European Commission

If I send 5 packages to a country, I am obliged to register and pay for its administration. But if a private individual sends 5 packages to the exact same country, this is not subject to any regulations. The regulation is very wrong, the philosophy that the producer is responsible for recycling the packaging is very wrong.

As a small craftsman, our jobs (6) are at serious risk as a result of this new scheme. We supply almost all EU countries, but some only once a year with our clarinets. Registration and the associated costs are disproportionate to the orders. Unfortunately, we cannot exist without these assignments. We only use simple boxes for shipping.

Filed in German · English published by the European Commission

The harmonised registration formats are just a series of bureaucratic activities related to recycling a courier package. The regulation is just another bureaucratic nightmare. As a micro-manufacturer of personalised home decor items, I cannot hide my huge disappointment with this regulation. The bureaucratic burden is completely unacceptable for any micro-enterprise in the EU.

To whom it may concern, I am on the precipice of launching a micro enterprise selling eco conscious clothing. This regulation has essentially stopped my enterprise in its tracks. There is no affordable mechanism for me to comply with these regulations.

We are a family-run nursery with a total of five permanent staff. We do not even have two full-time staff for all clerical and administrative tasks. Against this background, we are very concerned about the planned requirements for the registration, classification and reporting of packaging under the PPWR. In principle, we support the objective of reducing packaging waste and using resources responsibly.

Filed in German · English published by the European Commission

IVSH welcomes the opportunity to contribute to this consultation. While harmonised registration formats are a positive step, companies continue to face significant administrative burdens arising from fragmented national registration and reporting systems. Our submission therefore focuses on the need for a more integrated, proportionate and SME-friendly approach to PPWR compliance across the Single Market.

The proposed QR code may be a pragmatic way to implement the labelling obligations under the current legal situation. However, my fundamental question does not answer the recommendation: Why must the associated obligations and the additional administrative burden arise at the level of each individual horticultural establishment instead of fulfilling the requirements as far as possible at the level of the…

Filed in German · English published by the European Commission

As a small German sole trader and a committed European, I can no longer participate in the Single Market. The regulatory requirements are completely disproportionate to the 100 small packages I ship to the European Union each year. I sell printer spare partsproducts that can extend the lifespan of devices and prevent vast amounts of electronic waste.

EPR - the basis of all problems and all fraud. Before receiving a salary in Brussels, every employee must pass an intelligence test and a psychological test. The obvious fact "every envelope is transported by a courier company" is visible to everyone and only in this building in Brussels they don't see it. And oh my god - after 6000 comments, someone wrote "5 cents in the cost of transportation solves all problems".

I cannot write “I support the EU’s efforts to recycle”. It is not normal for a profit-making company to be further subsidised in the name of an alleged ecological policy. It is not normal for a recycling company to have a long line of representatives and staff counting the barely paid packaging.

Filed in Italian · English published by the European Commission

Under the current PPWR rollout, selling to customers in other EU states has become a financial impossibility for micro and small businesses. The requirement to hire a local Authorized Representative (AR) in up to 27 countries is a flawed, disproportionate burden. I urge the European Commission and Parliament to establish a permanent, legally binding micro-business exemption threshold based on turnover or volume.

Based on a review of other submissions to this consultation, the overwhelming sentiment appears to be one of shared support for the underlying goal of reducing packaging waste, alongside serious concern about how that goal is currently being implemented.

Greetings, Im finding this to be unfair for small, handmade businesses such as myself. I do have customers in the EU, but its fairly rare. Im not a corporation shipping hundreds, thousands, or millions of Goods to the EU, so the process and fees would be a hardship to maintain, for what amounts to maybe 8-10 EU sales per year.

I run a very small art business and sell my products online. I fully understand the reason behind reducing packaging waste, and I don't have a problem with reasonable packaging requirements. I personally only use recycled paper for my packaging to reduce waste, with 0 plastic in my products. What I find difficult is how expensive and complicated compliance can become for a business as small as mine.

Some natural misunderstandings can take a good idea, exploit it to inhumane limits and go as far as destroying the planet’s largest economic union. That is what has happened. I am just a consumer, but I see what is happening to European producers.

Filed in Spanish · English published by the European Commission

The idea was not thought to come to an end. If I deliver one or two parcels worth 120.- each to a customer and then have to pay hundreds of euros for the authorised person (e.g. 300.-), I have to transfer this to the delivery, i.e. the order costs instead of 120.- now 270.-.-. The customer then stops ordering. Moreover, the bureaucratic burden is too high to make it anyway.

Filed in German · English published by the European Commission

The European Union is rebuilding national borders inside its own Single Market. I run a micro-enterprise in France specialising in vintage and antique objects and selling online across the EU. Like many small businesses, I may make several sales to one Member State, one sale to another, and none at all to a third.

It is time for the EU to go down in history and start anew. The EU was created so that all producers from member states would have free access to the single market. Today, everything around us is made in China. Only large traders and importers of Chinese goods have free access to the single market. European goods have disappeared from the continent.

This is the absolute death for European microbusinesses. How can you expect to treat microbusinesses with less than 100 sales per year to comply with 1000's of Euros and the mind bending maze of European bureaucracy for every country the same way you would regulate Amazon? The truth is this just another stupid tax on top of all the stupid taxes heaped upon us. This will be the death of my microbusiness in Spain.

EXEMPT MICROBUSINESSES FROM THESE RULES. You are making the EU Single Market impossible for sole traders and the smallest businesses. Hundreds of thousands of microbusinesses cannot afford this level of compliance, and we do not have compliance departments to manage it. I am a sole trader based in Portugal and I work completely alone. My turnover is small.

I am very sensitive to environmental issues, but this law does not make it possible to combat pollution linked to shipments. I would even say, on the contrary! It disproportionately penalises self-businesses, which have absolutely no means of absorbing the costs and other taxes generated. My self-enterprise is an additional activity, generating a turnover of 3000 per year.

Filed in French · English published by the European Commission

This is not eco-policy. This is eco-bullying. This is not a policy for recycling. This is inhuman torture of small businesses for the purpose of accumulating profits in companies for counting. In Brussels, everything possible is being done to destroy European business and replace it with imported goods from China. I am a small business with about 400 shipments a year in almost all European countries.

PPWR is killing the EU Single Market for microbusinesses. It does not create a serious burden for Amazon-sized corporations. It creates a potentially impossible burden for one-person businesses like mine. I am a sole trader established in Portugal. I am the only person in my business. I provide custom machine embroidery on clothing, textile bags and other small textile products.

I do not support this regulation or these registers. They are designed to generate profits for dubious private entities. 2027 fast approaching: artificial intelligence is ubiquitous, each carrier has a number for each consignment and each shop has a unique code for each product. This regulation aims to meet the ever-growing financial ambitions of dubious companies exploiting the EU’s environmental policy.

Filed in French · English published by the European Commission

I support the environmental goals of the PPWR, but its registration system is disproportionate for microbusinesses. A small seller trading across the EU may need to register separately in up to 27 countries, follow different procedures, file reports and appoint authorised representatives.

We support the environmental objectives of the Packaging and Packaging Waste (PPWR) Regulation and recognise the role of the Producer Extended Responsibility (EPR) schemes in promoting the circular economy. However, the implementation of these obligations must remain consistent with the fundamental principles of the European Union, in particular the free movement of goods and the proper functioning of the single…

Filed in Italian · English published by the European Commission

I'm an online seller of a mix of handmade goods and crafting accessories. I am not a high-volume seller, and I also don't make high-cost sales. However, I sell things that are in a niche market that people cannot find anywhere else, so I pride myself on selling them worldwide. If these packaging laws pass as proposed now, I won't be able to afford to sell in any EU countries.

I am a one-person craft business and ceramic maker based in Ireland. I fully support the environmental aims of PPWR, but I am concerned that its implementation is disproportionate for microenterprises and may create the opposite of the intended environmental outcomes. I sell handmade ceramics and send only a handful of parcels to other EU countries each year.

Absurd bureaucracy that goes against the laws of the European single market and will destroy small trade. Law drafted by civil servants who do not know the concepts of clear communication: there are thousands of discussions about how and when this incomprehensible law is applied. It is a norm worthy of the worst Soviet bureaucracies. The EU was not.

Filed in Spanish · English published by the European Commission

One month after the entry into force of this extremely illegal regulation (which de facto removes access for small businesses to the common European market), not a single politician or political party has taken any steps to change it. Large platforms are massively removing the visibility of ads from small craftsmen who have not registered in 27 countries. And there are already messages everywhere.

I have been producing personalized clothing designs for 20 years. I sell mainly on eBay and Etsy. Today I received messages - I must attach my number or my ads will be removed. I make between 250 - 300 sales a year throughout Europe. Physically and financially I cannot afford to make 27 registrations and pay 27 companies to count my packaging. Thank you to the EU for killing a 20-year-old family business.

as the owner of a German sole trader, I expressly support the objectives of the European Green Deal and the reduction of packaging waste. However, the specific design of the PPWR, in particular the obligations that have been in force since 12 August 2026, fundamentally jeopardises the economic existence of micro and smaller market participants.I would therefore urge you to support the following adjustments: Small…

Filed in German · English published by the European Commission

I am a horticultural master and have a nursery with 7 employees in Germany. We only supply the German market, so do not operate across borders, but the planned registration and reporting obligations on packaging under the PPWR would impose a significant burden on us. Our company does not have its own administrative department.

Filed in German · English published by the European Commission

We are online traders from Germany and we sell our own products through various channels. Our main market is Germany, but in the past we have supplied smaller quantities within the EU. As we need a PPWR authorised representative for most countries in order to be able to declare the packaging waste generated at all, selling it abroad in the EU is no longer worthwhile for us.

Filed in German · English published by the European Commission

Ladies and Gentlemen, we are RYSER’S, a small, independent retail company from Germany. We support the idea of reducing packaging waste. However, we consider the practical implementation of the new Packaging Regulation to be disproportionate and unrealistic for small businesses.

Filed in German · English published by the European Commission

In principle, the initiative to prevent packaging waste is to be welcomed. However, this Regulation misses the reality. As SMEs, we have to make an effort that is not economically responsible. It may be that the large company hires staff to do the job, but it is not affordable and feasible for us.

Filed in German · English published by the European Commission

We are a small agricultural nursery with 3 employees and ownership. The upcoming packaging reform presents us with a significant additional bureaucratic burden. As our office is not full-time and the work of the owner takes place more or less during ‘leisure’ after normal working hours.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop without further employees, 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 an independent luxury fashion brand based in Germany, we urge the European Commission, Parliament, and Member States to finalize a clear micro-business exemption or de minimis threshold regarding Authorized Representative (AR) requirements under the Packaging and Packaging Waste Regulation (PPWR).

I am a microbusiness owner and this new regulation will be the end of my business and many many more. Looks like this is European Commission goal with this new packaging rules. You all know very well that microbusiness and huge corporations will need to follow the same rules. That is not just and it is a shame on Commitea - to eliminate small business and favor corporations, but not EU citizens.

Fratelli Geroldi S.r.l., an Italian SME producing self-adhesive labels and other printed products also intended for the packaging sector, expresses concern about the establishment of national registers of producers if future implementing rules do not clearly distinguish the producer of the finished packaging from the B2B supplier of individual packaging components.

Filed in Italian · English published by the European Commission

For microenterprises as well as SMEs, the PPWR deployment and compliance costs put at risk the competitiveness of society. Indeed, this would require the hiring of one FTE in order not to penalise the productivity of the existing structure. In the context of the free trade area, this new regulation is still an additional constraint for European businesses, which have already been in difficulty for several years.

Filed in French · English published by the European Commission

I am the founder and sole proprietor of Brut Studios, a small bedding company based in Berlin. I am already registered with Germanys LUCID packaging register and pay for the packaging that my business places on the German market. I support the principle that businesses should take responsibility for their packaging waste.

We cannot register in all 27 countries. In Poland, for example, the website is only available in Polish. A local tax number is required in Spain, France and Poland. The entire number of notifications with different deadlines, etc., would require us to fill a full-time post for this task. The free internal market no longer exists.

Filed in German · English published by the European Commission

Hi, I run a small online shop (Japanese Natural Stones) selling kitchen knives and sharpening stones worldwide, including many EU countries. Right now if you sell packaged goods across EU countries you need to register as a producer separately in every single one - different portal, different language, different rules.

We operate a specialised online shop for a niche product in the field of manual labour and have been supplying customers in many Member States of the European Union for over 25 years. Companies such as ours are particularly hard hit by the current design of the Packaging Ordinance.

Filed in German · English published by the European Commission

I am a trader myself and I sell my articles via eBay. To be honest, I do not understand why the packaging requirements must make intra-EU shipping so complicated. I would like to continue selling my articles to customers across the EU. This is exactly what we ultimately have a common European market.

Filed in German · English published by the European Commission

As a medium-sized rose garden centre, we cultivate and sell garden roses and other plants to private end customers. In addition to selling locally, we run an online shop and send mainly within Germany, but also to other EU Member States. In principle, we welcome the PPWR’s objectives of reducing packaging waste, conserving resources and creating more uniform standards across Europe.

Filed in German · English published by the European Commission

I am an artisan creating and selling handmade products to customers across the EU. I want to follow environmental rules, but separate registrations, fees and representatives in every country are simply not proportionate when I may send only a few parcels there each year. These requirements may force artisans and micro-businesses like mine to stop selling across EU borders.

Opinion of the Freiburg Chamber of Crafts on the consultation on packaging and packaging waste Rules on national registers of producers The Freiburg Chamber of Crafts generally supports the European Union’s climate and environmental objectives and the overarching objectives of the Packaging and Packaging Waste Regulation (PPWR).

Filed in German · English published by the European Commission

The new EU Packaging Regulation (PPWR) obliges manufacturers to appoint an authorised representative in each Member State, regardless of whether or not sales are actually made in that country. This requirement would lead to a significant additional administrative and financial burden. Moreover, it is not easy to implement the mandatory markings and symbols in medical technology.

Filed in German · English published by the European Commission

We support the objectives of the PPWR and the Commissions efforts to establish a harmonised registration and reporting framework across the European Union. At the same time, the implementing act should ensure that reporting obligations remain proportionate and practical for highly regulated industries such as aerospace.

I am writing as a European citizen and a small e-commerce owner who works with nature every day. We all want a greener Europe, but the current PPWR feels like a punishing blow to the very people the EU should protect. While massive corporations have the endless capital to absorb these new packaging mandates, small businesses do not.

Filed in Italian · English published by the European Commission

Sehr geehrte Damen und Herren, als Betreiber eines kleinen Online-Handels möchte ich die Gelegenheit nutzen, auf einen aus meiner Sicht besonders kritischen Punkt der geplanten Umsetzung der PPWR-Herstellerregister hinzuweisen: die Pflicht zur Bestellung eines Bevollmächtigten für die erweiterte Herstellerverantwortung beim grenzüberschreitenden Verkauf.

As an artisan and sole proprietor, I fully support the environmental goals of the PPWR. However, treating a micro-business the same as a massive multinational is structurally flawed. The requirement to appoint an expensive Authorized Representative in every EU Member State creates an impossible administrative and financial barrier for me.

Hello, as a micro enterprise with revenues already heavily affected by US taxes and those towards Chinese sites where I find part of my raw materials because these are not produced in Europe, this is an additional blow.

Filed in French · English published by the European Commission

This draft implementing act is an important step towards a more uniform implementation across Europe of the registration and volume reporting requirements under the PPWR. In particular, the aim of being able to submit data in a uniform form, thereby reducing the administrative burden on businesses, is expressly to be welcomed.

Filed in German · English published by the European Commission

In principle, a sensible concern to reduce packaging waste. But this bill is a complete bureaucratic monster. Some things that would be useful from the point of view of a small enterprise: — Abolish the registration requirement for small operators. A company here in Germany charges EUR 300 per EU country to which you want to send for the registration of the customer.

Filed in German · English published by the European Commission

As a micro business owner, this proposal would force me to register separately in every EU country I sell in, even when I make just a handful of orders there each year a financially and administratively impossible burden for a one person business. The result won't be better packaging waste management.

Ladies and gentlemen, the Deutscher Klöppelverband is an association which cultivates, promotes and preserves the craftsmanship of Klöppeln. We publish 1 specialist book each year and sell it at home and abroad. With the new packaging rules, we are, to say the least, overwhelmed. Everyone works on a voluntary basis.

Filed in German · English published by the European Commission