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

In general, the PPWR is not designed to prevent packaging and protect the environment. It practically prevents the use of packaging that is as used as possible. Barriers to used packaging are infinitely high, rather than encouraging the use of used packaging. The figures from the statistics for the collection of packaging will never be correct because the packaging is licensed and counted several times.

Filed in German · English published by the European Commission

Ladies and gentlemen, the Regulation is also a daunting challenge for us (companies with < 9 employees). We have been working with the PPWR for more than 50 % of working time for weeks and months. But now on the individual criticisms: — The environmental aspect: We are active in the chemical sector and we sell our products in barrels or in the IBC.

Filed in German · English published by the European Commission

As an EU-based micro-business owner, the current fragmented implementation of Packaging and Packaging Waste EPR rules is completely destroying the single market for small creators, artisans, and e-commerce startups.

Opinion on PPWR bureaucracy must not act as a brake on the European single market! In principle, we support the PPWR’s objective of reducing packaging waste, improving recycling and reducing packaging volumes. However, from the point of view of a medium-sized online trader, we see significant problems with the practical implementation of extended producer responsibility in cross-border EU trade.

Filed in German · English published by the European Commission

The Bundesverband Reifenhandel und Vulkaniseur-Handwerk (Brv) supports in principle the climate and environmental objectives of the European Union and the objectives of the Packaging and Packaging Waste Regulation (PPWR).

Filed in German · English published by the European Commission

Opinion of Dresden’s hairdresser and beauty maker The hairdresser and beauty maker Dresden generally supports the European Union’s objectives of preventing packaging waste and strengthening the circular economy.

Filed in German · English published by the European Commission

The Interessengemeinschaft Deutscher Kunsthandel represents around 1000 member companies (antiquariate, galleries, art dealers, coin dealers and art auction houses). The sector as a whole has an annual turnover of only 1.2 billion and is characterised by micro-enterprises. Cultural goods are unictics. They differ in shape and weight. Therefore, no packaging is similar to the other.

Filed in German · English published by the European Commission

We have completely stopped sending it to other EU countries. Why is it not possible for the manufacturers of the packaging to provide the information and not for each individual distributor placing the packaging on the market? We are all unconscious, as we are expected to do here. The basic idea is that there is a free EU single market.

Filed in German · English published by the European Commission

The provisions of the PPWR, which have been in force since 12.08.26, are excessively bureaucratic for small traders, do not stem and make shipments to other EU countries unprofitable. Consequence: the single market no longer applies to small businesses, it is de facto dead. We will stop deliveries within the EU. Very damaging, damaging to business and resulting in less tax revenue for the government/EU countries.

Filed in German · English published by the European Commission

Harmonisation: National producer registration requirements should be harmonised across EU Member States to avoid different obligations. Simplicity: Registration and reporting procedures should be simple, clear and easy for businesses to comply with. One-stop registration: Preferably, producers operating in multiple countries should have a single, streamlined registration process.

Disproportionate burden on micro-enterprises in cross-border shipping. I operate a one-person company in Germany and sell handmade products in very small quantities. So far, I have sent to Austria, among others. These are only about 5 to 20 orders per year.

Filed in German · English published by the European Commission

Taken from the European Union website: "One of the keystones of the European Union (EU) internal market is the principle of the free movement of goods." Now needing to pay a big amount of money for a representative in every single member state isn't really my idea of 'free' movement of goods. Don't get me wrong, I have no problem with the environmental aspect of this regulation.

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

Filed in German · English published by the European Commission

The burden this regulation puts on small and micro business goes against the principle of a single market. This is killing small business and the appeal of the EU. Having to register in each country individually is unsustainable for small businesses. Exemptions must be put in place for a minimum threshold of transactions per year.

As the owner-manager of a growing independent micro-enterprise specializing in vintage timepieces, established in Luxembourg in 2024, I am submitting this feedback to highlight the severe operational threat posed by the current Extended Producer Responsibility (EPR) compliance framework and the ongoing enforcement of the Packaging and Packaging Waste Regulation (PPWR), which entered into force on 12 August 2026 and…

The PPWR is superfluous Europe needs less bureaucracy, no longer the targets behind the European Packaging and Packaging Waste Regulation (PPWR) sound right: less packaging waste, more recycling and a functioning circular economy. But there is no need for another gigantic set of rules. Europe already has extensive rules on packaging, disposal, recycling, producer responsibility and packaging registers.

Filed in German · English published by the European Commission

Regarding the PPWR regulation. I will start by saying, I do think this regulation is well needed to accomplish the climate goals within the EU. We all need to do more for the environment. But, as a one person business already struggling to have time for all administrative tasks it means to run a company, this regulation is devastating since there is no way I have the time to sign up in each and every country I ship…

We are a 4-person micro-enterprise selling sustainable clothing online across the EU. We fully support the goal behind PPWR, but the way it has been implemented is painful for a company our size. Having to register separately, report separately, and pay separately in every member state we sell into is a level of bureaucracy that a small team simply cannot absorb without pulling time and resources away from the…

The requirements introduced by the PPWR for companies operating across borders, in particular the obligation to appoint an authorised representative for extended producer responsibility in each Member State, impose a disproportionate burden on micro and small enterprises.

Filed in German · English published by the European Commission

Hello, We do not agree with the rules and we are protesting! Where does the promised reduction of red tape take place? No, a new bureaucratic monster will be created! We feel harassed and in no way valued for our daily performance. As a owner-run bakery with a successor (to date), we no longer feel at all understood and represented by politicians!

Filed in German · English published by the European Commission

The EU Regulation on the PPWR, which has now entered into force, increases red tape in a disproportionate manner. The declarations of conformity, which now concern not only the packaging (bag, cardboard, cups, etc.), but also the inks, adhesives or, in the case of pallets, the pallet material and the wrapping foil or the pallet shipping label, impose a considerable additional burden.

Filed in German · English published by the European Commission

I am a small craftsman and in the future, in order to give me more opportunities for my business, I wanted to evaluate the sale of my small craftsmen’s creations in Europe, but this new waste tax, both from an economic and management point of view, would make it no longer possible to sell my small works. There is a risk that the cost of sorting waste will be too high in proportion to the sale.

Filed in Italian · English published by the European Commission

Dear Sir/Madam, I consider the proof of packaging waste to be very bureaucratic. As a backing company, we have so far been able to report all our packaging via the manufacturer and thus also to pay the fees. The current burden of passing it on to ALL individual holdings is unnecessary and pointless.

Filed in German · English published by the European Commission

I operate a small handmade business in Germany and sell through an online marketplace. I send 10 packages to 2 other EU countries each year. My turnover from these countries is EUR 1000. I pay many more euros per year for registration and plenipotentiaries in these countries. Because the fixed costs exceed my turnover abroad, I have stopped shipping to other EU countries. This draft is under REFIT, i.e.

Filed in German · English published by the European Commission

I am an employee of a micro-enterprise that runs an online shop for the sale of server hardware. Let me first explain what impact the enhanced requirements for EPR compliance and the new rules of the PPWR Regulation have for us. EPR compliance has already been registered in some EU countries, such as France, but now it will be more.

Filed in German · English published by the European Commission

Dear Sir or Madam, KOCH Pac-Systeme GmbH belongs to the Uhlmann Group and as a part of the same corporate group, we support the environmental and circular-economy objectives of Regulation (EU) 2025/40 and share Uhlmann Pac-Systemes critical assessment of its practical implementation.

Simonds Farsons Cisk plc would like to confirm its full support for the feedback submitted by the Malta Beverage Producers Association (MBPA) on this proposal. As a producer directly subject to DRS and wider EPR reporting obligations, we support the need for the proposed framework to facilitate interoperability and data exchange between national producer registers and existing DRS and PRO reporting systems, thereby…

We are a small company that produces, among other things, a product for the plastic-processing industry to avoid the waste of so much material if the plastic changes colour. This product is sold, inter alia, throughout Europe. These are usually small packages of 12x1 kg. The costs now incurred cannot be passed on to customers and are not bearable by us, so shipping is no longer worthwhile.

Filed in German · English published by the European Commission

I am writing on behalf of the Malta Beverage Producers Association (MBPA) in Malta whose founding members are The General Soft Drinks Co. Ltd, Simonds Farsons Cisk plc and Marsovin Winery Ltd. From a local implementation perspective, we would like to submit the following observation for consideration: Where an established Deposit Return Scheme (DRS) and/or Producer Responsibility Organisation (PRO) reporting system…

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

Filed in German · English published by the European Commission

Ravensburger stands behind the PPWR as it stands for sustainability. Nevertheless, the PPWR prevents the free movement of goods within the EU and prevents the company from entering new markets within the EU. In order to enter new markets and test the outlet, we start this market with the smallest shipments.

Filed in German · English published by the European Commission

Practical difficulties in applying the PPWR to small bakeries The practical application of the PPWR leads to considerable uncertainties and sometimes disproportionate administrative and financial burdens for small bakeries.

Filed in German · English published by the European Commission

As a small e-commerce operator, 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

To the European Parliament (Committee on Petitions) and the European Commission, We, the undersigned European micro-entrepreneurs, individual artisans, and independent creators, hereby submit an urgent appeal regarding the disproportionate administrative and financial burden imposed on micro-enterprises by the Packaging and Packaging Waste Regulation (PPWR) and the associated Extended Producer Responsibility (EPR)…

This PPWR mandates a maximum empty space of 50% in shipping boxes by 2030. In practice, this is completely unfeasible for small products because international postal and logistical standards force e-commerce businesses to apply a large A6 shipping label flat onto the box. As a result, the physical dimensions of the box cannot be made smaller than the size of the sticker itself.

To Whom It May Concern, I founded HY. FIFTY as a European brand and company with the purpose of bringing European culture, craftsmanship and the tradition of gathering around one table. The company is based in Germany, works with manufacturing partners in Europe and aims to reach people throughout the EU.

The General Soft Drinks Co Ltd, a beverage producer based in Malta and a founding member of the Malta Beverage Producer Association (MBPA), welcomes the opportunity to comment on the draft Implementing Regulation establishing the format for registration in, and reporting to, national producer registers under Regulation (EU) 2025/40 (PPWR).

I ask you to reconsider PPWR. I am an artist and small online shop owner from Finland. Online shop is big part of my business. I have to stop selling in EU and that is a big part of my sales. In other words this regulation will destroy one important way to make living. It should be easy to sell and buy in EU Single Market. We need a strong EU and not divided. You split EU to smaller markets.

The current packaging rules place a disproportionate burden on micro-businesses and small online sellers. Many of us are one-person businesses with only a few orders per year from individual EU countries. Having to deal with separate registrations, fees and reporting requirements in every Member State can make small-scale cross-border sales simply not worth the cost.

To the European Commission, I am writing as a sole artisan who has handcrafting products and earning an independent living in the EU for over 20 years. I have consistently operated in full compliance with European tax laws, paying EU VAT on every cross-border order.

As a German medium-sized company, we operate a specialised online retail business and supply customers in many EU Member States. We strongly support the objectives of the PPWR regarding packaging prevention, recycling and producer responsibility.

Filed in German · English published by the European Commission

The Ulm Chamber of Crafts’ environmental advice supports the EU’s waste prevention and circular economy objectives. However, the current extended producer responsibility (EPR) schemes under the PPWR place a disproportionate burden on small and medium-sized craft enterprises in particular.

Filed in German · English published by the European Commission

The intention of the PPWR is so clear and also makes sense: Reduce packaging and waste. Only at present does it look like this: — large corporations that have been sending parcels to their customers for years or decades within the EU know exactly how many parcels generate what turnover and profit in which EU country.

Filed in German · English published by the European Commission

The proposed rules may create a disproportionate administrative burden for small and micro businesses. Small businesses often have limited financial and human resources and may not have dedicated staff to manage additional registration, reporting and compliance requirements. The requirements should therefore be simplified and proportionate to the size and environmental impact of the business.

I support the EUs environmental goals and reducing packaging waste. However, PPWR risks placing a disproportionate financial and administrative burden on micro- and small businesses, with consequences for the wider EU economy. 1. The domino effect If PPWR compliance costs thousands of euros plus significant administrative work, some small businesses will become unprofitable and shut down.

As a solo micro-business owner from Lithuania, the current decentralized packaging registration and reporting system is unmanageable. Handling compliance, fees, and representatives in multiple EU Member States for just a few annual orders is financially draining and physically impossible for a one-person business.Furthermore, as a resident of Lithuania (a small market), I see many small European brands blocking…

The PPWR risks making the EU the only market in the world that a micro EU business can no longer afford to serve. We are a micro-enterprise based in Portugal, with a small online shop selling merchandise to its international community. Our sales volumes in individual EU Member States are very small.

ZVEI supports the European Commission's objective of establishing harmonised and interoperable producer registration and reporting systems under Article 44 PPWR (EU Regulation 2025/40). To achieve this objective without creating new administrative burdens, the implementing act should follow three principles: reporting requirements must be limited to data that producers can reasonably obtain; information already…

I am the owner and sole representative of a small craft business in Italy and I am associated with the applications submitted by a large number of my colleagues from other EU countries. This legislative proposal is unmanageable for a small business, both economically and in terms of management, and will encourage small businesses to close down to the European market for the sole benefit of the large commercial…

Filed in Italian · English published by the European Commission

As a small e-commerce operator, I would like to take this opportunity to draw attention to what I consider to be a particularly problematic aspect of the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

I am the owner of an Italian micro-enterprise selling physical products online. We also sell within the European market, but we have had to suspend shipping to some Member States because of the costs and administrative requirements imposed by the different national packaging regulations.

Im a small business owner, and I make, pack, and ship everything myself. I already pay the packaging fee, even though I use very little packaging. With regulations like these, I may simply have to close my business. And thats especially sad because it sets a terrible example for my children why would they want to work hard and build something of their own if small businesses are made impossible to sustain?

I want to express my strong opposition to the current PPWR requirements and, more importantly, the way these regulations affect small and newly established businesses. I have literally had to go through hell just to establish a legal business and start selling products within the EU.

I strongly oppose these requirements in their current form. I run a one-person handmade business in Lithuania. I create, package and dispatch every order myself while also managing all administrative, tax and legal obligations. Requiring micro-businesses to register, report, pay fees and potentially appoint representatives in every EU Member State where even a single parcel is sent is completely disproportionate.

I am the founder of Essência da Luz, a new micro-enterprise based in Portugal. We develop locally inspired natural products and have invested approximately EUR 30,000 in product development, production, design, packaging and our online shop. I fully support the objectives of the PPWR and the polluter-pays principle. We are willing to report the packaging we place on the market and pay appropriate EPR contributions.

Ladies and gentlemen, it is absolutely ok for me that you should also, or above all, take on joint responsibility for the disposal of the packaging as an online trader. I am happy to contribute and support the disposal and recycling systems to ensure this. However, these requirements should also be applied to an extent that is also feasible for small and medium-sized enterprises.

Filed in German · English published by the European Commission

This requirement creates a heavy administrative and financial burden for small businesses without delivering any real environmental benefit. Forced localization only generates unnecessary bureaucracy, increases operating costs, and restricts cross-border trade for small merchants within the EU single market.

For a small businesses that are owned by one person this initiative not only gives a huge financial responsibility, but also makes it impossible to sell your handmade products across Europe... imagine having to pay if sending to Germany, Portugal, Spain few times a year only, but paying the fee and for the representative... it will end my business.

I am a small business owner specialising in the reconstruction of archaeological artefacts. I run a one-person business and sell only what I make with my own hands. The proposed changes would impose costs that I simply cannot afford. They would also cut off an additional source of income my international customers.

I would like to share my concerns about the new EU waste and packaging rules and how they affect very small businesses like mine. I am a small independent designer from Lithuania. I make unique, one-of-a-kind clothing pieces myself, and most of my customers are from other EU countries. I usually have around 5 orders per month. This is a very small business.

Hello, unfortunately this regulation is very opaque for many bakeries. Thanks to my wholesaler (Bäko), it was possible to clarify ambiguities, as I only buy pre-certified packaging. This definitely does not produce less waste. The impression is that it is ‘only for money’. The DSD system was clearer. Instead of being simpler for farms, it is becoming more and more difficult. Politics promises the opposite.

Filed in German · English published by the European Commission

Hello, we are, as a small business who are providing custom additive manufacturing solutions, the new rules are very hindering to our business, not to mention too expensive to be able to afford to register even to key countries. Also, very confusing as there are no centralized solution.

Sandra MG (Lithuania) I am an independent artisan and micro-enterprise owner from Lithuania, creating unique, 100% handmade knitwear and acting as a keeper of traditional crafts. I sell my work across Europe, but the current packaging and waste management policies are becoming completely unacceptable.

MBE Deutschland GmbH supports the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR), in particular waste prevention and the promotion of the circular economy. At the same time, however, the company criticises the planned implementation, as it underestimates the challenges faced by European businesses, in particular packaging and shipping service providers.

Filed in German · English published by the European Commission

I am a small manufacturer of personalized designer items related to home decoration. I do not support the EU policy related to recycling. It serves the dubious intentions of private companies from France, Germany and other Western countries that administer the process called recycling.

If this amendment is adopted, small manufacturers like me, who send up to 100 shipments per year to European countries, will have to shut down our operations because we simply wont be able to ship anymore. Although such quantities seem ridiculously small compared to the large companies that ship that many packages in a single day, this volume of shipments generates a significant portion of our revenue, without which…

I am a micro-business and independent maker based in the European Union, selling handmade products online. I fully support the environmental objectives of the Packaging and Packaging Waste Regulation and the principle that producers should take responsibility for the packaging they place on the market.

CINOA represents art and antique dealers, galleries, auction houses, antiquarian booksellers, numismatic dealers and fairs, predominantly micro and small enterprises. The FUNDAMENTAL PROBLEM is that PPWR risks imposing the same fixed registration burden on a business placing a handful of packages on a national market as on one placing very large quantities.

1. Reporting should be based on realistically available information in the supply chain. The company should be able to reliably obtain the information needed for reporting from the supply chain. In particular, the ability of importers, distance sellers and distributors to access detailed packaging information often depends on the ability of manufacturers and suppliers to provide information.

Filed in Finnish · English published by the European Commission

Dear Members of the European Parliament, I love being European, I feel being European. So lovely being connected with other people in Europe, easy to travel, having the Euro it got easy do pay in different countries. I just love Europe!!! And as a small business owner I also would love to make business across Europe.

Blechwarenfabrikation GmbH Seit 1948 Lares Blechwarenfabrikation GmbH, Felix-Wankel-Str. 7, D-74915 Waibstadt Europäische Kommission Generaldirektion Binnenmarkt, Industrie, Unternehmertum und KMU (GD GROW) Rue de la Loi 200 1049 Brüssel Belgien Waibstadt, 31.

Filed in German · English published by the European Commission

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

I strongly oppose this proposed legislation. It would place a disproportionate financial and administrative burden on small businesses, independent makers and Etsy sellers. Large corporations may be able to absorb these costs, but for a one-person or small business, additional bureaucracy will mean higher prices, lost customers and even closing the business altogether.

The Single Market should not result in 27 separate EPR registration and compliance burdens for a micro-enterprise selling only a few kilograms of packaged products in each Member State. The proposed system risks creating a disproportionate administrative and financial burden for micro and small enterprises, particularly those whose business model is based on cross-border online sales.

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

Filed in German · English published by the European Commission

The PPWR is important to harmonize packaging regulations throughout the European Community. Many companies work with far-East industries as well as with small local companies (1020 employees). It can be challenging to explain to these companies why they need to support the packaging life cycle with documented test reports and other technical documentation.

Since the EU has long made trade in the EU more difficult, the new Packaging Regulation is actively making trade in the EU impossible for all small and medium-sized operators. The costs may be profitable only for larger firms. As tea and speciality consignments, we ourselves were forced to immediately stop trading in the combined EU (except Norway) from the cut-off date.

Filed in German · English published by the European Commission

I am the owner of a small German online shop and would like to describe the concrete consequences of the PPWR for my company. Since 12 August 2026, we have stopped shipping to almost all other EU Member States. Not because we do not want to serve these markets, but because the new EPR classification is economically and administratively disproportionate for a small company.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Hi! I just read what this law means for small companies in Europe and I don't understand how can we continue to operate. Not to mention hobby makers. This law needs to exempt small players from the regulation or simply put the cost on packaging manufacturers. Kindly, Johan Losvik

The European Beer Consumers' Union (EBCU) \nsupports the aim of the Packaging and Packaging Waste Regulation: producers should contribute fairly to packaging collection and recycling costs. We do not contest this principle.

I am a small business owner in the United States selling used and antiquarian books. I currently am registered with the German government regarding packaging waste. It would be prohibitive for me to register with all EU entities separately regarding packaging waste considering the small number of dealings I have with EU customers.

The enormous requirement of registering with every country has led to my canceling orders to EU. It is not simple or fiscally doable to pay every country for the occasional order that I receive. As a collective union, you could make it simpler by having the buyer register with each country for the disposal of recycling material. That would make more sense and would be locally controlled.

We are a small used book seller in Canada, with annual sales of about CAD 150,000, about 5,000 of which is to Eurozone countries. Most of our books are scholarly or antiquarian and we sell primarily to universities and scholars in Europe. With these new very complicated regulations, we feel at a loss as to how to proceed. Must we hire a "representative" in each individual European country?

Whilst I remain in support of the general ethos behind this legislation, it's application and process is cumbersome, expensive and will not solve the issue of recycling. As a UK bookseller, I send a small number of books to European buyers, both individuals and institutions.

The current EPR system risks recreating within the EU Single Market exactly the kind of barriers that the Single Market was created to remove. Replacing customs barriers with regulatory and administrative barriers does not solve the problem, it merely changes its form.

I have elected to not ship to the EU parcels valued below 150 Euros, as the costs of compliance with al these registrations with all the EU countries far far exceed any possible profit from such transactions. Small privately owned used booksellers such as myself, selling used and mostly older pre-ISBN books, and unique old prints and art, must leave it to EU buyers to obtain such material from local retailers- who…

Recycling existed before the EU was created. Like any business, it brought profits before the EU was created. Why, in the name of bringing even more significant profits to certain companies in Western Europe, has the whole of Europe been placed under a Green dictatorship? Everything is falling apart in the EU. Both big and small are languishing. And the consumer is the ECO-MARTYR on planet Earth.

I am a micro-business owner based in Bulgaria, selling handmade products through Etsy to customers across the European Union. My products and parcels are very small and lightweight. A typical parcel, including the handmade product and all packaging, weighs only around 100160 grams. The actual packaging itself weighs only a small fraction of this.

Mack & Schneider GmbH is a German SME in plastics processing, manufacturing technical plastic parts as a Tier 1 supplier to the automotive industry and the B2B sector. We sincerely appreciate this opportunity to give feedback and hope to contribute to a regulatory framework that strengthens Europes competitiveness considering the needs and limits of SMEs and micro-businesses.

As a small e-commerce business, the new regulation is synonymous with the destruction of the EU’s single market, supporting big companies from e.g. the USA and China, and allowing small traders to sell nothing within Europe without having to pay for it.

Filed in German · English published by the European Commission

I am a disabled ceramicist working from home in France; I sell my sculptures to customers all over the world. The new PPWR requirements are entirely impossible for micro-businesses to manage, especially as they arrive on the heels of the increasingly complex tariff situation with the US. There is absolutely no way that I can afford the new registration fees.

I understand and support the EUs goal of taking action against large marketplaces such as Temu, Shein and Amazon, and I also understand the need for better environmental standards and fair competition. But I feel that these rules are not suitable for very small businesses and artists.

Ladies and gentlemen, I am not at all satisfied with the new Regulation on the transit of goods within the EU. As an establishment which is currently implementing my business idea in an extreme niche market (sport trophies), I cannot afford to have an authorised representative in all or even in another EU country who is doing the entire paperwork.

Filed in German · English published by the European Commission

Dear Sir or Madam, We remain fully willing to comply with all applicable environmental regulations. However, each additional registration and reporting obligation places a disproportionate burden on SMEs, making it increasingly difficult for small businesses such as ours to operate.

I have a small online shop in the secondary sector. Registering and plenipotentiary in each EU country would cost me more than EUR 8700 per year. There is also then the licensing of the packaging itself in each individual EU country, not to mention the bureaucratic burden and the valuable time that companies have to spend as 1-persons. My pre-tax profit is EUR 20.000 – EUR 25.000/year.

Filed in German · English published by the European Commission

MonXolo Ltd welcomes the Commissions work to establish a harmonised format for registration in and reporting to national producer registers under Article 44 of Regulation (EU) 2025/40. We support the requirements for open standards, machine-readable information, interoperability and data portability without vendor lock-in.

Thanks to the new EU Packaging Regulation, small businesses (especially one-person self-producers) have no chance of remaining competitive on the market! Purely physical sales are not sufficient for specific products because, on the one hand, a far too small group is targeted (especially in Austria) and it is difficult to implement in time – so you are dependent on online sales (in digital times like this).

Filed in German · English published by the European Commission

Splendid isolation. This is a step in a wrong direction for sure. I run a very small online bookstore, ship around 50 small packages/week. Once in a whole theres a parcel for other EU countries but that will have to end immidiately, and many small Companies thinks the same, a counterproductive law, opposite to everything what EU is suppose to stand for; promote and support trade for all EU businesses, a shot in the…

We are a small German retailer and have so far regularly supplied customers in other EU Member States. The new PPWR requirements, in particular the national registration and EPR obligations and the obligation to appoint authorised representatives, have created significant additional costs and red tape. As a result, we had to stop shipping to all EU Member States outside Germany.

Filed in German · English published by the European Commission

To: European Commission Directorate-General for Environment (DG ENV); Members of the European Parliament (Committee on Internal Market and Consumer Protection - IMCO). Dear Sir/Madam, I am writing to you as an independent artisan and sole trader from Portugal, specializing in handmade silver jewelry.

I am the owner of GabiArtwork, a Hungarian micro-enterprise producing handmade premium scenery trees for model railways. My products are manufactured individually in a small workshop in Hungary and sold through my own online shop. I fully support the environmental objectives of the Packaging and Packaging Waste Regulation.

I would like to raise a practical concern about the impact of the PPWR on small e-commerce businesses selling low volumes across several EU Member States. For a small online retailer, the European Single Market makes it possible to sell a few orders per month to customers in many different countries.

This is a terrible implementation. I run a small business which has been selling into the EU, and I reuse all packaging I can. The fees per country are far too high compared to the profit I make from selling there, the total fees would potentially even cost me more than I'd make.

This PPWR law in its current form affects small entrepreneurs disproportionately hard. I am a self-employed entrepreneur in the creative sector and my customer base within the EU is not big but diverse. My work is unique, made with materials produced in Euopa, and is lifelong. It varies greatly from year to year to which country I sell more, but I value each customer.

Filed in Dutch · English published by the European Commission

Exceptionally disappointing way to do things. And it is worrying that all Brussels can not see the mess this creates. Which brings you to think..if same people decide about more serious things - not too hopeful. But the packaging law should be like simple, yearly payment of 60eur for example. Many of us just put out few kg of so to say waste. Should be taxed accordingly.

Honourable Members of the European Parliament, I am writing to you as an small business owner residing in Portugal to request that, on the Omnibus proposal (COM/2025/982), you suspend the requirement for an authorized representative under Article 45(3) of the Packaging and Packaging Waste Regulation (PPWR) until 2035. This goes against the EU "Think Small First" principle.

Hello I have been an artistic activity, a sole trader, for 30 years. MII has been open to the European, American and Asian markets for a long time. Shipments are always an important item for the customer and in any case I pay attention to the use of environmentally friendly and compliant packaging material. Materials which obviously have a higher cost.

Filed in Italian · English published by the European Commission

The PPWR pursues important environmental objectives and is justified in principle. However, its current implementation places a disproportionate administrative and financial burden on SMEs, particularly in cross-border trade. Even small packaging quantities can trigger extensive national EPR registrations and fees, putting European companies and traders at a competitive disadvantage.

I am a freelance artist, and my activity is diverse in the field of painting and a small stationery business that is just emerging. My profession is entirely supported by my forces and this regulation would break her legs in the early days, because it is untenable from an organisational and economic point of view.

Filed in Italian · English published by the European Commission

The PPWR decision does not in any way concern me with the idea of being a micro enterprise, already uses 100 % recyclable cartons and even the idea of participating proportionally in recycling is not an aberration in itself. What is, on the other hand, productive and clearly a death sentence for all small self-entrepreneurs is the disproportionate application of financial and administrative burdens.

Filed in French · English published by the European Commission

As the owner of Willow Tree Reborns, I would like to give feedback from the perspective of a very small UK business. We are a small handmade reborn doll business, currently selling around 12 dolls per year, alongside accessories, and we are hoping to grow. Like many small businesses, we take environmental responsibility seriously.

Dear, As a small bussiness owner from Czech Republic, handcrafting unique items and just planning to expand abroad - as this is the only way to make the bussiness grow into something meaningful, this new rule literary broke our spine.

I'm a hobbyist sewist, and I have a small online shop where I sell handmade veils and mantillas. I frequently use second-hand, reclaimed and deadstock fabric for sustainability. Most of my items are sold to buyers in other EU member states. I only sell several items per month, sent in a simple bubble envelope.

These are regulations to be applied to large companies. I am an artist, my activity could occasionally involve small sales in Europe, and I find the activity totally unsustainable with increased costs on packaging materials. Finds it crucial to oblige the use of fully recyclable materials for packaging, but European small and individual companies must be supported.

Filed in Italian · English published by the European Commission

We have also sold used toys/model railways in transit since 1987. As we also do this to save resources, we usually send the goods with used shipping boxes, which we collect from partners in the neighbourhood. As a small enterprise with eight employees, we are unable to meet the flood of regulations to limit the EU’s internal market, not least the PWWR.

Filed in German · English published by the European Commission

Regulation (EU) 2025/40 has, since 12 August 2026, for all practical purposes brought an end to the functioning of the European Unions Single Market for micro and small enterprises that have until now sold small quantities of their products to customers in other Member States.

The PPWR pursues important environmental objectives, but the national design of EPR/producer registration places a disproportionate burden on German companies when it comes to cross-border trade. Already small quantities of packaging require extensive national registrations and fees, which exceeds the administrative burden.

Filed in German · English published by the European Commission

The implementation of the Packaging and Packaging Waste Regulation (PPWR) creates profound operational burdens for Small and Medium-sized Enterprises (SMEs) while threatening to trigger unintended consequences that could paradoxically increase overall waste across the Union.

I own a small business in Germany, supplying niche industrial electronics for research, development and test/measurement applications where high accuracy is of critical importance. While many products are sold in Germany and abroad to businesses and government entities, it would essentially now be impossible for us to register for PPWR given the overall costs of appr. 20.000 Euro and annual fees at a similar level.

I am a small business owner with a modest turnover. The main reason for starting my own business was because my chronic illness prevents me from working for other people. I have no other means of supporting myself. As a single-person business I cannot afford to register with every country in the EU to handle the proposed rules. If there is no exemption for small businesses I will have to close my operation.

I run a sole trader business in Germany and even before 12 August 2026 I was effectively excluded from the majority of the EU single market, as I was already only shipping to those EU countries where either a de minimis threshold for micro-enterprises applied or where I was already registered.

I am the founder of a Swiss micro-enterprise preparing to sell one small electronics product in the EU. The current system effectively excludes small companies from the EU market. I have received quotations indicating fixed EPR compliance costs of around 15,000 per year for EU-wide Packaging and WEEE compliance (see price list of a trusted compliance company attached).

The PPWR pursues important and correct environmental objectives. However, from the point of view of a German micro-enterprise, the current national design of EPR/producer registration leads to a disproportionate burden on cross-border trade.

Filed in German · English published by the European Commission

You are about to put me and thousands of artits and creatives already struggling out of business with this crazy law! The rules are disproportionately burdensome for micro-businesses, sole traders, independent artists and small creative businesses that sell modest quantities across EU borders.

I'm representing a jewellery gallery in Estonia, representing more than 100 jewellery artists. We plan to increase our exports to other EU member states. We already declare our packages in our local register. If the requirement to register and find local representatives in all member states remains intact, it will significantly hinder our exports and effectively keep the EU internal market closed for single artists…

Hello, I am a manufacturer of shaving planes with my own brand and 125-year-old tradition. I sell b2b goods worldwide. From a dedicated online shop as a ‘producer show window’, I sell the razors across Europe from Estonia to Portugal or Romania. Last year, the volume of parcels we received abroad in Europe was less than 100 parcels per country.

Filed in German · English published by the European Commission

We are a micro-enterprise with fewer than 10 employees and do not have our own production. We act as a fully responsible supplier to our customers. Our manufacturing partners produce the parts ordered, purchase the necessary packaging materials, package the goods and send them directly to our customers. However, it is sent on our behalf, with our labels and delivery notes.

Filed in German · English published by the European Commission

Hello, What is the point of passing a law that will make small and micro businesses unable to sell within the EU? This entire project will make it economically impossible for small businesses to sell to other EU countries which just defeats the entire purpose of a free-trade zone. Companies under a certain revenue should be entirely exempted at the very least and a single unified system needs to exist.

For many craft businesses, cross-border deliveries are not mass market transactions, but individual customer orders or occasional online sales to other EU Member States. If already few deliveries generate high registration and administrative costs, there is a significant barrier to market entry within the European single market.

Filed in German · English published by the European Commission

We fully support the environmental objectives of the PPWR. Producers should take responsibility for packaging waste, recycling systems should be financed properly, and unnecessary packaging should be reduced. However, the current implementation risks undermining one of the EUs most fundamental achievements: the Single Market and the free movement of goods.

Ladies and gentlemen, I am writing to you today with a concern that has become very busy and increasingly burdensome for us as a small German packaging trader. I have already written a letter a few days ago to the relevant Commissioners, which I enclose with this letter. For months now, we have been working intensively on the practical implementation of the PPWR.

Filed in German · English published by the European Commission

Subject: PPWR disproportionate burden on micro-enterprises Dear Sir/Madam, as operator of a one-person e-commerce company, I would like to draw your attention to the PPWR’s completely disproportionate impact on micro-enterprises, in my view. I have been running my business for almost 15 years.

Filed in German · English published by the European Commission

I represent a German micro-enterprise that has also been selling goods to customers in other EU Member States for many years. We support in principle the objectives of Regulation (EU) 2025/40 on packaging and packaging waste, in particular packaging prevention, recyclability and producer responsibility.

Filed in German · English published by the European Commission

Ladies and Gentlemen, We have been a sole trader since 2018 and import and sell goods to Amazon. We have our own small brand. We also produce goods in the third country on behalf of advertising agencies and for their industrial customers. However, our turnover is manageable. As the name (sole trader) says, I handle the import almost entirely on my own.

Filed in German · English published by the European Commission

In my view, the seller of the packaging must pay tax on the packaging. In case of doubt, the product must be appropriately certified for countries. That is how I, as a buyer of packaging, can choose to package in my own country or abroad. The packaging may have a test stamp. Thus, the packaging is taxed, anyone can check the taxation directly.

Filed in German · English published by the European Commission

Ladies and gentlemen, I would first like to point out that the introduction of the PPWR rules is exemplary for many things that are going wrong in the EU and also within the Member States. Once again, it is a highly bureaucratic entanglement, with disproportionate costs for individual traders (authorised representative, minimum fees in some countries, etc.).

Filed in German · English published by the European Commission

We are an open Makerspace in Kaunas, Lithuania. Our goal is to accept everyone from our city into our community to build and learn together. We provide the facilities, tools and equipment, you are welcome to work on your projects. Without a fee. We rely on donations to survive. In the last three years we have started creating electronics projects, all made with the help of volunteers from within the community.

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a particularly critical point of the PPWR: the obligation to appoint an authorised representative in cross-border sales. We have invested a lot of time and money in recent years to expand our webshop for the European market through translations, technical optimisation, better visibility on Google and advertising.

Filed in German · English published by the European Commission

Feedback on the proposed rules for national producer registers under the Packaging and Packaging Waste Regulation I am a small handmade business based in Spain, selling wooden wall décor through my own webshop and online marketplaces such as Etsy and Amazon. I fully support the objective of reducing packaging waste and making producers responsible for the packaging they place on the market.

I have to complain about the PPWR. Not only smaller traders suffer. Also the manufacturing sector, e.g. mechanical engineering. Spare parts are not available to the recipient; machinery stoppages, including in industry, occur simply because there are no spare parts at all, but they would have to be obtained behind the border, but will not come because of the PPWR.

Filed in German · English published by the European Commission

As the Germans say: Gut gedacht, schlecht gemacht. Well thought out, poorly executed. The execution is in direct conflict with the concept of a Single Market, one of the EUs founding principles. I would not be surprised if we see successful legal challenges against this over-bureaucratic monster. You are: Killing small initiatives and making it harder for small businesses to operate across borders.

As a small business owner, I strongly support the goals of reducing packaging waste. However, mandatory EPR registrations, fees and separate administrative requirements in multiple Member States create a disproportionate burden for micro-businesses. For very small sellers, these fixed costs and bureaucratic obligations can make cross-border sales within the EU economically impossible, undermining the Single Market.

I run a one-person registered micro-enterprise in Belgium specialising in handmade marbled paper, serving customers in Belgium, across the EU and internationally. It provides about half my income, and I have invested substantially in a professional home studio. I personally handle production and every aspect of the business. I fully support reducing packaging waste.

I am the owner of a French micro-enterprise selling physical products online to customers in several EU Member States. I fully support the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR) and the principle that producers should contribute to the collection and recycling of the packaging they place on the market.

CCTC contribution to the European Commission’s Have Your Say consultation on the implementing act concerning national producer registers under Regulation (EU) 2025/40 The Croatian Chamber of Trades and Crafts (CCTC), representing more than 148,000 Croatian crafts and small businesses, welcomes the Commission’s objective of establishing harmonised, interoperable and machine-readable formats for registration in and…

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

I am a manufacturer under the Packaging Act because I import well-known branded goods from third countries into Germany and sell them to final consumers. This means, for me, that I must first register all the brand names of the manufacturers in the LUCID register, which I sell myself and which are shown on the packaging boxes. I also need to find out how difficult the sales packaging and padding is for each item.

Filed in German · English published by the European Commission

Ladies and gentlemen, as managing director of a small German e-commerce company which also sells its products across borders within the EU, I would like to draw your attention to what I consider to be a particularly critical point in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

We are an SME online trader based in Germany and sell cross-border to consumers in many EU Member States through online marketplaces, in particular Amazon. We support the objective of Extended Producer Responsibility (EPR) and the ‘pay-as-you-throw’ financing of packaging disposal.

Filed in German · English published by the European Commission

As a small company producing individual packaging, we are particularly affected by the implementation of the PPWR. A large part of our orders consists of very small print runs of only 20 to 50 packages. However, the documentation and administrative burden is almost independent of the level of requirements.

Filed in German · English published by the European Commission

I am a UK-based SME, and have sold my own technology products into the EU for a decade. The products are responsibly packaged in recyclable materials and designed for a long life. The cost of meeting the directive as it currently stands - specifically the cost of registering across all member nations I sell to (the majority of EU members) makes selling into the bloc unaffordable.

We are an online trader in Germany and call us micro-enterprises within the meaning of the PPWR. We are well aware that the PPWR pursues important environmental policy objectives. However, its concrete implementation in the field of packaging, and in particular e-commerce, is unfortunately a prime example of bureaucratic overregulation by the EU; this is particularly true given the administrative burden per unit of…

Filed in German · English published by the European Commission

We are a small company selling natural products with the highest environmental and sustainability standards. In any case, we support the reduction of resources for protection. However, this directive is a red tape with unprecedented costs. In the current economic situation in Germany and Europe, it is another stumbling block to keep the company profitable.

Filed in German · English published by the European Commission

Ladies and gentlemen, as an operator of small online sales, I would like to draw your attention to some of the effects of the PPWR on micro and small enterprises, which in my view are particularly problematic. Selling abroad in the EU has been an obvious growth step for small businesses so far. The obligation to appoint an EPR authorised representative may significantly change this invoice.

Filed in German · English published by the European Commission

As the SCM and procurement manager for a larger, global entity, I have no understanding of the procedure. Please first ensure that European law is transposed into national law, define limit values for reporting obligations and create a central reporting master.

Filed in German · English published by the European Commission

We fully support the environmental objectives of the PPWR. But the administrative architecture risks making cross-border trade economically irrational for micro and small EU businesses. A small EU company wishing to sell throughout the Single Market can face its home-country registration plus up to 26 authorised representatives in the other Member States.

I have a small business in Germany since 1993, since 2003 I have an online shop, selling instructions and craft materials for porcelain doll makers worldwide. Most of my customers are in the US. All went well until Trumps tariffs when DHL stopped shipping Warenpost International up to 1000 grams to the US. I can survive that.

On behalf of D&D Sp. z o.o., a Polish medium-sized printing company operating Printnet.pl, I request urgent simplification of the extended producer responsibility (EPR) requirements arising from Regulation (EU) 2025/40 (PPWR) for SMEs sending small quantities of packaging to other Member States. We send approximately 3,500 consignments annually to 12 EU Member States.

The Packaging Directive violates the EU Constitution as a free trade area. In practice, this means that all smaller companies in the EU are excluded from essential parts of EU trade due to financial and administrative barriers. For my part, I can then only send books within Sweden and to the rest of the world EXPLANATORY FOR the EU.

Filed in Swedish · English published by the European Commission

DREGENO SEIFFEN eG www.dregeno.de Stellungnahme der DREGENO SEIFFEN eG zur Verpackungsverordnung (PPWR) Verhältnismäßigkeit und Belastungen für Kleinstunternehmen müssen stärker berücksichtigt werden Die DREGENO SEIFFEN eG unterstützt grundsätzlich das Ziel der Europäischen Union, Verpackungsabfälle zu reduzieren, Ressourcen zu schonen und die Verantwortung für Verpackungen entlang der gesamten Wertschöpfungskette…

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)

Hip-Hop Enterprise (BE 0690.711.759) is an independent Belgian record label and webshop, active since 2018, with no employees. We release around twenty titles a year on vinyl, CD and cassette and distribute for over thirty other independent labels, selling via our webshop, Discogs, direct mail orders and record shops worldwide. Vinyl is pressed in Portugal, CDs in Poland, our shipping packaging bought in Germany.

Antiquariat [name removed] [address removed] An die EU-Kommission Sehr geehrte Damen und Herren, als Betreiber eines kleinen Online-Buchhandels 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…

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)

— It would certainly be much easier, if at all necessary, to implement rules on the Packaging Ordinance at the place of origin rather than for a company in all EU countries. Of course, this requires trust between the various authorities in the EU countries. Simplification on the basis of the size of the company is not appropriate. If so, it should be tied to the volume of consignment/packaging for each country.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

I think this is a good initiative to protect our continents environment. However, these measures should be realistic and proportionate to businesses of different sizes. It would make sense to enforce stricter requirements on large corporations, given that the amount of waste they produce is significantly greater and not even comparable to that of small businesses like mine.

Ladies and gentlemen, as an entrepreneur of a small business, I would like to give you my personal and honest feedback on the planned implementation of the PPWR. My impression is: In its current form and with the associated requirements, this Regulation risks becoming an existential burden for many small and medium-sized enterprises.

Filed in German · English published by the European Commission

As a small specialist trader in globes (cartographic products), we had an approximate profit of 6000 in the EU. As it is not economically viable to conclude a contract with 27 Member States on this scale, we stopped shipping outside Germany on 12 August 2026. It is all the more annoying that we have already introduced the Wero. The Wero is also a tool for strengthening intra-EU trade.

Filed in German · English published by the European Commission

Esponse to a Verpackungsgroßhandel : Everyone in Europe uses bags that meet all the necessary requirements. Don't assume that bags in Germany are any greener than those in any other country. The real issue is this: the manufacturer of these bags has already paid the so-called "ECO" or recycling fee.

I am a sole trader in France and I manage a small e-commerce business specialising in the sale of miniature collectors’ items on 1/43. The application of the PPWR to micro-enterprises selling in more than one Member State raises a major proportionality issue.

Filed in French · English published by the European Commission

Business profile: Small family-oriented niche e-commerce. Main sales model: Servicing the domestic market and cross-border mail order sales to other countries of the European Union. Market specificities: Offer to a narrow, specialised audience (collective/hobby) for which the purely national market is too small to ensure the viability of the business.

Filed in Polish · English published by the European Commission

Hypocritically, I would write: I support the EU in its efforts to reduce global pollution, but as a micro-level artisan, I feel that my legal access to the single European market is de facto banned, because the financial and administrative requirements set out in this packaging regulation are completely unbearable for me.

Ladies and gentlemen, as managing director of a family business with 11 employees and less than EUR 2 million turnover, I would say clearly: It is enough. The limit of the burden on small businesses due to ever-new rules, evidence and bureaucracy has been reached. We had to create additional human resources only to cope with regulatory requirements such as the PPWR.

Filed in German · English published by the European Commission

As long as system participation and disposal fees for packaging are not uniformly regulated across Europe, there are significant competitive disadvantages for companies that diligently fulfil their legal obligations. As an established company, we buy systemically involved service packaging or, in the case of imported packaging, carry out the required system participation ourselves.

Filed in German · English published by the European Commission

We sell small quantities online and have so far generated around 50 % of turnover in other EU countries. So far, unfortunately, on 12 August 2026 we had to stop this foreign business completely because of the PPWR, as the costs and burden of registrations, proxies, etc. are simply too high and do not bear any costs. For a small company like ours, this law is a complete disaster, and our business model is at risk!

Filed in German · English published by the European Commission

Ladies and gentlemen, we strongly support the European Union’s objective of reducing packaging waste, improving recycling and financing disposal costs in a polluter-pays-friendly manner. What we cannot support, however, is a system in which the management of packaging ultimately costs more than packaging, its disposal and, in some cases, even the turnover it generates.

Filed in German · English published by the European Commission

Micro enterprises can't afford this. You're killing the single market. Why would you implement anything if you don't already have a system designed and ready to go? Do you honestly expect the member states to ever accomplish anything? Look at Germany. It's 2026 and people still use fax machines regularly. Doctors still can't figure out how to send a sick note electronically.

As a small enterprise, the obligation to register in every EU country is a heavy bureaucratic hurdle. This was much better regulated in the case of turnover tax using the one-stop-shop procedure. The additional cost for an authorised agent in each EU country is much higher than the expected gains from selling small quantities. Here too, an OSS approach would be preferable.

Filed in German · English published by the European Commission

Ladies and gentlemen of the European Commission, The PPWR, which has now entered into force, completely runs counter to the idea of free trade within the European Union and impedes small and medium-sized enterprises from offering their goods or supplying them throughout the EU.

Filed in German · English published by the European Commission

Ladies and gentlemen, this type of legislation is EXAKT the reason why the right-wing parties across Europe are growing up. Ideation: good. Implementation: Shake out the child with the bath. Small side effect: Tens of thousands of small businesses are standing at the abyss. Absurd EU bureaucracy and regulatory quest with real, the same consequences for small senders, who have built something out of it in the niche.

Filed in German · English published by the European Commission

I run a small online specialised pet shop. I send several packages per month to retail customers in the EU, ensuring that the waste used is as low as possible and that the packages are filled as much as possible. My clients are often carers of sick and needy animals. The new rules, as presented, will put an end to this possibility for my business, which will be completely uneconomical.

Filed in Polish · English published by the European Commission

This is a really confusing piece of legislation and impossible for small businesses, (one-person-businesses, craftspeople, artisans and artists) to comply with. I will not explain the difficulties as all other respondents have done so very articulately. Why can't a recycling fee be included in the price of the packaging when we get it for our shipping?

Ladies and gentlemen, as managing director of 24/7 Handels GmbH, I have been trading online with EUFORY for many years, having its registered office in Hamburg. We send our goods not only within Germany but also to customers in other EU Member States and already meet the respective national packaging and registration obligations.

Filed in German · English published by the European Commission

I am an Italian artisan working alone, creating original commissioned artworks. Each piece is entirely handmade and every package I ship corresponds to a single artwork. Most of my commissions come from clients in EU Member States, but I don't ship annually to each country, and I rarely ship more than 1 parcel per year to the same country.

We have tried to implement this complex regulation for an industrial company that sends industrial products to the rest of the world. The number of packaging elements was still manageable, with 140 items. 50 % of packaging suppliers did not know how to proceed. We then took them to our hands, explaining everything and creating a form to return to us signed by them.

Filed in German · English published by the European Commission

Our company works exclusively in the B2B business and places transport packaging on the market. The packaging is sorted by our customers, partially reused and otherwise disposed of in a professional manner. The mandatory affiliation to producer responsibility organisations (actually a take-back organisation) upsets the current practice of how companies work with each other and generates disproportionate costs.

Filed in German · English published by the European Commission

It is increasingly clear that this Regulation has been so impractical that nobody knows how to implement it correctly. Even packaging producers do not understand the interpretation. In addition, the burden is also becoming more and more noticeable, especially for small and medium-sized enterprises. Our cartonboard supplier initially explained that it had nothing to do with producer obligations, i.e.

Filed in German · English published by the European Commission

Dear Sir/Madam, I represent the music PR agency Dr Music Promotion, Miriam Guigueno & Torsten Wohlgemuth GbR from Hagen, Germany. Unfortunately, we are also negatively affected by the PPWR Act. To date, we have been testing foreign music magazines and blog editors with promo CDs. For this reason, we would be directly affected by the Act, as for monetary and bureaucratic reasons we simply cannot afford the burden.

Filed in German · English published by the European Commission

Great job, EU! The new packaging waste regulation law is a bureaucratic masterpiece. Under the guise of saving the environment, you have successfully crushed sustainable, small-scale competition and handed a monopoly to global e-commerce giants.

PPWR: 124 pages of bureaucracy have someone actually read it before voting on it? The objectives of the PPWR may be useful. However, implementation works like a real bureaucratic monster: complicated, expensive and far from the reality of small and medium-sized enterprises.

Filed in German · English published by the European Commission

Als B2B/B2C-Mischbetrieb fordern wir dringende Nachbesserungen an der PPWR zur Entlastung des Mittelstands. Die aktuelle Bevollmächtigtenpflicht (Art. 44) erzeugt existenzbedrohende administrative Fixkosten bei Export-Kleinstmengen. Wir schlagen drei konkrete Lösungen vor: (1) Die Einführung mengenbasierter statt umsatzbasierter Bagatellgrenzen pro Zielland (z. B. <250 Pakete/Jahr).

This is murder! I am a solo entrepreneur and artist from Sweden, who sells my locally crafted items online to all over Europe, and one of those who offer customers a sustainable alternative to the giants such as Amazon and Temu. These new rules are devastating to us!

As an operator of a small individual company in the field of personalised textiles, we would like to draw your attention to what we consider to be a serious design error in the planned implementation of the PPWR producer registers: The obligation to appoint an authorised representative for EPR in cross-border sales is disproportionate to what it aims to regulate.

Filed in German · English published by the European Commission

The envisaged PPWR obligation to appoint an authorised representative for cross-border sales in each EU destination country puts a burden on small online traders through disproportionate fixed costs and high administrative burden.

Filed in German · English published by the European Commission

Assessment of Regulation (EU)2025/40 PPWR Bromberger Packungen is family-owned, one-site-company with approx. 100 employees, that is in business since 1904. Having intensively read the PPWR (trying to understand and implement it) and above all having received a lot of consistent input from customers, suppliers, competitors and associations, we would like to shortly formulate our summary and assessment (given the…

As a small German e-commerce company with cross-border shipments within Europe, we would like to highlight significant practical problems with the implementation of EPR for packaging. Some of our packaging and shipping volumes to individual European countries are low.

Filed in German · English published by the European Commission

We would like to express the impractical nature of the PPWR. It is easy for foreign traders to manipulate through an intermediary and puts all small and medium-sized businesses in the EU at a huge competitive disadvantage. Trade in the single market is becoming impossible for many. Even with the licences, there is no sense or transparency.

Filed in German · English published by the European Commission

I strongly urge the European Commission to think about what impact the EPR legislation has on hobbyists such as myself who create products that sell at a small price and volume (mine for instance sells for around 50 and makes about two or three sales per month) that ship around Europe.

Subject: Ref. Ares(2026)7688068 – 06/08/2026 Draft: Commission IMPLEMENTING REGULATION (EU) & ANNEXES Article 44 PPWR expressly provides for national registers of producers in the individual Member States. Accordingly, a manufacturer must register separately with the relevant competent authority of each Member State.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Hello, as a one-woman model-building company (self-employed), the new PPWR hits me hard, and I can no longer simply send it to the EU. My packaging materials used are compliant and I also have the company documentation for this, I am registered with Zentek and Lucid. Costs for proxies and registrations in all EU countries go beyond my business.

Filed in German · English published by the European Commission

It would be much easier to just tax the packaging material itself with an amount or percentage, to be paid directly to the EU by the packaging industry. This gets rid of all the bureacracy. The packaging inductry probably succesfully lobbied against this, leading to this insane solution, but please rethink.

Ladies and gentlemen, as the owner of a small online shop, we would like to contact you regarding an aspect of the planned PPWR producer register that is serious for small businesses: the requirement to have a separate authorised representative for each EPR for cross-border distribution. So far, expanding to other EU countries has been a logical development and build-up step for our business.

Filed in German · English published by the European Commission

Micro and small businesses are the backbone of the EU and the UK. This policy is not only discriminatory against micro businesses, it is discriminatory against buyers. Innovative products designed by families, husbands, wives, will no longer be able to be purchased due to these punitive costs. Entrepreneurs need to be supported, not destroyed. Please stop this madness and help out.

With regard to the typologies of packaging materials: it will be necessary for assistance or a reminder to be provided on the definition of ‘predominant material’. It is not enough to say that this is the material with the highest proportions in the packaging.

Filed in French · English published by the European Commission

Ladies and gentlemen, this is an unparalleled bureaucratic effort, which is exactly the opposite of what we want to achieve. Registering in all national registers because you send goods abroad, which you have to pack for transport, will further hinder internal trade. Regulation is completely weak.

Filed in German · English published by the European Commission

Ladies and gentlemen, this Regulation is once again an example of a good idea: Prevent and recycle packaging waste. However, implementation has once again failed catastrophically. We are a small specialised electrical wholesaler with a webshop. For decades, we have been using cartonboard from our suppliers. Equally old newspapers used as fillers. Both are now more or less impossible with your regulation.

Filed in German · English published by the European Commission

[name removed] [address removed] the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales. As a small entrepreneur for rare motorcycle parts, which no longer exist anywhere in the world, sales to other EU countries have so far been a fundamental building block without a legal department of their own, but with the aim of complying with the law…

Filed in German · English published by the European Commission

Subject: Threat to livelihood posed by PPWR (Regulation 2025/40) Microenterprises in the field of baby handling. As owner-run microenterprises, we hereby submit a complaint against the design of the EU Packaging Regulation (PPWR). In practice, the Regulation has the opposite effect of a free internal market: It forces us to stop EU-wide trade, puts jobs at risk and blocks training in baby care and obstetrics.

Filed in German · English published by the European Commission

This law is not working and it is killing free movement of goods in EU if EU based companies have to get authorized Representative in every EU country. I run a small business here in the EU, and while I completely get why we need better waste management and recycling, the way the current EPR packaging rules work in practice is honestly a nightmare for people like me.

Ladies and gentlemen, as a trader offering a very special range of products, many of which can only be obtained from us throughout the EU, I attach particular importance to cross-border online sales. This is precisely what I see as being jeopardised by the planned obligation to appoint a separate representative for each target country in the implementation of the PPWR.

Filed in German · English published by the European Commission

Together with my wife, I run the small, family-owned online business. We are not a large corporation and do not have our own legal department or the financial and human resources available to major online platforms. In principle, I support sensible measures to reduce packaging waste and improve recycling.

I operate a small online shop in Germany and, honestly speaking, I find the planned rule on the obligation to appoint a representative very problematic, especially for small traders. I would like to continue selling my products to other EU countries. However, the problem is that, with few orders per country, this is simply not expected to happen at some point.

Filed in German · English published by the European Commission

DR. JOHANNES HEIDENHAIN GmbH supports harmonised and interoperable producer registration and reporting under Article 44 of Regulation (EU) 2025/40. However, the draft's level of detail risks creating permanent administrative, supplier-data and IT structures without a proportionate environmental benefit. Recording the weight of every minor component does not in itself prevent packaging waste.

It is dissapinting and utterly exasperating. Small business owners simply cannot afford the cost or the administrative burden of the PPWR regulations. Who comes up with this sort of thing? It is no wonder that the EU is increasingly viewed with skepticism by its 450 million citizens and that support for it is waning.

Packaging rules are implemented from the wrong side, that impose costs on the most vulnerable party, instead of building sustainable base. A great example are plastic straws. They were simply banned and you can't buy them.

The most important problem for Cyprus is that there are no alternative solutions for manufactures and packing. So, though we pay the contribution to the authorized collector (Green DOT) there is no service they provide to us. We have no means to recycle packing from paints (metal drums) or bituminous emulsions (plastic drums).

In my view, the PPWR is hardly surpassed by its weakness! I am an online trader and deliver to more than 20 EU countries – or HIGH I deliver to 20 EU countries! Because thanks to the PPWR, I am now obliged to have an authorised representative for each country, who costs me 299, plus VAT per year. Plus licensing fees for the packaging itself. The plenipotentiaries alone cost me almost 8000, including VAT per year!

Filed in German · English published by the European Commission

Hello, Why is this again a bureaucratic ‘mountain’ of? For years, it was good that the manufacturer of the packaging we ordered paid the royalties. Why is this being made more complicated again? My proposal: Maintain the (German?) rule that we receive the royalties via the actual producer/our supplier. Why should we, as an artisan bakery, do this now, even though it was actually doing well?

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Hurra, the EU Packaging Regulation is there! Finally, another big step to save the world and a small step towards insolvency for small traders. You are a small business and you may send 20, 50 or 100 packages per month? No problem! After all, you have far too much free time.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

This new regulation is an absolute disaster for small businesses and their customers alike. I sell vintage goods around the world, and I expect to lose at least 20% of my total income thanks to these new rules. Which are, once again, perfectly tailored for the needs of major players. Also, especially residents of the smaller EU states will be successfully excluded from the internal market from now on.

I would like to express my strong opposition to the new Packaging and Packaging Waste Regulation. The obligation for companies to register in all 27 EU Member States and comply with separate national systems, as well as the related fees and administrative obligations, are extremely difficult to justify for small companies operating at the level of micro-enterprises.

Filed in German · English published by the European Commission

I am writing as an artist - painting, fibre creations and writing - and a one-person creative business owner. While I support the environmental goals behind the new EU packaging rules (PPWR), I question how micro-enterprises, small studios, solo artists, secondhand sellers of any types of goods can afford to comply, or indeed can even logically think about complying.

Ladies and gentlemen, as the operator of a small online shop, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in cross-border sales, in particular without thresholds.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

We are a very specialised company selling our products worldwide through our online shop. Because our selection of products is very specific, we are not a high volume seller. We ship products to the entire EU region, but depending on economy usually just 2-3 items per year to a single country. The resulting turnover per country is significantly lower than the required registration cost we would need to pay.

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as a traditional business in the field of hat and hood crafts (Germany’s oldest hat specialist business, founded in 1534), characterised by decades of craftsmanship, regional roots and passion for quality, we would like to draw attention in this consultation to a critical misdevelopment for European small and medium-sized enterprises.

Filed in German · English published by the European Commission

Ladies and gentlemen, I operate an online shop and send fewer than 1000 items per year. I would like to draw your attention to an aspect of the planned implementation of the PPWR Producer Register which, in my view, is completely untenable: 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 owner of a small ceramic business based in Poland, having to comply with PPWR would significantly complicate or even make it impossible to sell my works to other EU countries due to high costs. In my opinion, such regulations deny the idea of the European single market

I run a small business with me as the only owner/employee. This law is completely ridiculous for my type of company. I use about 500 worth of packaging material each year. It will force me to end my business. EU solution is way too complicated. For starters, it is ridiculous to have to file your use of packaging in each country you ship to seperatly.

Subject: Practical check PPWR: Red tape for small online traders through the obligation to have an authorised representative. Ladies and gentlemen, as operators of small online sales, I am writing to you today with an urgent request and a practical impulse to the planned implementation of the EU Packaging Regulation (PPWR).

Filed in German · English published by the European Commission

We support the environmental objectives of Regulation (EU) 2025/40 and the improvement of packaging collection and recycling. However, the current draft risks placing a disproportionate burden on small and medium-sized enterprises with pan-European supply chains. It is true that the registration and reporting formats are to be harmonised.

Filed in German · English published by the European Commission

The current packaging rules place a disproportionate burden on micro-businesses and working udr sefl employment status. Many of us are one-person businesses receiving only a few orders per year from each EU country. Requiring separate registrations, fees, reporting and potentially representatives in every Member State makes no financial or practical sense.

Hello, as an individual company, I am a graphic designer usually engaged in the provision of services. In view of my turnover, which is falling freely with the use of AI, I intend to open an online shop with posters or other artistic creations of recycled materials, media and parcels (I intend to upgrade natural plants to make my own paper and make photoengraving with natural pigments).

Filed in French · English published by the European Commission

www.44elfweinspeicher.de 44elf Weinspeicher • Am Königsbrunnen 16 • 99867 Gotha An die Europ. Komission Stellungnahme zur PPWR aus der Sicht eines Weinhändlers 25.08.2026 die europäische Gesetzgebung hat das Ziel, den Binnenmarkt zu stärken und die Umwelt zu schützen. Die am 12.

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)

Absolute absurdity, willingness to fail small businesses. We will no longer be able to trade with either physical or legal partners abroad because the contributions are simply unbearable, most of our businesses will fail, many years of construction and entrepreneurship will simply fail.

Filed in Lithuanian · English published by the European Commission

I am writing as a beginning artist and a one-person creative business owner concerned about the practical impact of the new packaging requirements on very small businesses. I fully support the environmental goals behind these rules. I also try to make my own business as sustainable as possible: I reuse packaging whenever I can, avoid unnecessary materials and carefully consider how each parcel is packed.

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

Filed in German · English published by the European Commission

As a small-scale farmer and food processor, I am concerned that the proposed packaging regulation would create a significant additional administrative and financial burden for small businesses. The new requirements could be disproportionate to the scale of our operations and may discourage small producers from investing, developing new products, and expanding their businesses.

I welcome the European Commission’s aim to harmonise formats and data requirements for producer registration and extended producer responsibility reporting. From the point of view of a small producer, this harmonisation is necessary.

Filed in German · English published by the European Commission

This goes against one of the basic principles of the EU, free movement of goods. The only beneficiaries from this regulation are established multinationals because they have the resources to comply and thus it will limit competition. The consumer will have less choice and there will be less cross border cultural exchange. Not to speak about the footprint of this data and control operation by itself.

I have been selling small spare parts worldwide for 15 years. Above all, of course, also to the EU. It is not reasonable for me as an individual to appoint an authorised representative and to register and report in all 27 Member States alone. Neither the burden nor the costs are in any way proportionate to the size of my business or to the benefits of the new regime.

Filed in German · English published by the European Commission

Good afternoon, I am a retailer (online) and have no employees. As a result of my annual turnover, I am registered as a small businessman. My plan to expand the industry has been set back by the scheme. I had to stop shipping to the EU altogether (approximately 10 % of turnover so far).

Filed in German · English published by the European Commission

As a maker and buyer of products from small independent makers and producers I support Jeanette Koňarčíková`s well formulated feedback on this proposal and I copy her full argumentation and suggestions in support of our common case: To: the European Commission and the European Parliament "The Single Market is broken for small creators.

I support the objectives of the PPWR and the principle that whoever places packaging on the market should pay for its collection and recycling. My concern is that the registration and producer responsibility costs are fixed per country instead of proportionate to volume. For a business of my size they exceed the profit the activity generates.

As someone intending to start a micro business in the EU selling small hardware products, it is completely insane that I have to register with a bunch of different country beurocracies in order to sell a tiny amount of products. It is a fundament violation of the principle of a common market and you should be ashamed of yourselves for failing in your duties to advance the goals of the EU project so comprehensively.