Implementing rules on registering in and reporting to the register of producers
2388 submissions from 2178 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
Who showed up
2312 submissions from industry — companies and their trade associations — against 10 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 231.2 industry submissions for every one from civil society.
Industry 2312Civil society 10Public authorities, academia, other 66
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
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The consultation is open — 11 days leftto submit. It closes on 10 Sept 2026.
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Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a particularly critical aspect of the planned implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales. For small businesses, sales to other EU Member States have been an obvious step forward so far.
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
Feedback on the PPWR: It is not feasible for (micro)enterprises Dear ladies and gentlemen, as operators of small online sales, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of…
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 a particularly problematic point of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in cross-border sales in each Member State concerned. Selling to other EU countries is an important way for small businesses to enter new markets.
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
The current packaging rules place a disproportionate burden on micro-businesses. Many of us are one-person businesses receiving only a few orders per year from each EU country. Requiring separate registrations, fees, reporting and potentially representatives in every Member State makes no financial or practical sense. In some countries, compliance may cost more than the total value of our annual sales there.
As a self-employed micro-business owner in Lithuania, I fully support the objectives of reducing packaging waste and ensuring producer responsibility. However, the regulatory and administrative framework must be proportionate to the actual scale of a business and must take into account the specific situation of very small businesses and consumers in smaller EU Member States.
I send about 160 to 200 shipments per year to almost all European countries. If I had to go further, an intermediary company wants exactly 11,500 euros for the service of representing me, plus each individual recycling fee. There is one catch - in each country there is a minimum threshold and it doesn't matter if you sent 1, 5 or 10 shipments.
The current packaging rules place a disproportionate burden on micro-businesses. Many of us are one-person businesses receiving only a few orders per year from each EU country. Requiring separate registrations, fees, reporting and potentially representatives in every Member State makes no financial or practical sense. In some countries, compliance may cost more than the total value of our annual sales there.
Hello, as an operator of a small online shop, I give up shipping abroad, as for me the bureaucratic burden and costs are disproportionate to the revenue. Badly, the idea of an EU and perhaps the future “United States of Europe” is different.
Filed in German · English published by the European Commission
For micro-enterprises, in particular solo self-employed, artists, creators and one-person companies, the PPWR obligations in cross-border trade are not just an additional bureaucratic burden. You can decide whether a company can still operate economically throughout the EU. I myself run a one-person company and operate a niche market with a community spread across Europe and beyond.
Filed in German · English published by the European Commission
Ladies and gentlemen, as a medium-sized trading company, we would like to draw your attention to a particularly problematic issue in our view regarding the implementation of the PPWR producer registers: the envisaged obligation to appoint a separate authorised representative for the extended producer responsibility in each Member State for cross-border sales.
Filed in German · English published by the European Commission
The PPWR represents a significant bureaucratic and financial burden, especially for small businesses. I think that each producer or producer is willing to take responsibility for the packaging they place on the market. However, this responsibility must not lead to disproportionate administrative burdens and high additional costs, especially in difficult economic times.
Filed in German · English published by the European Commission
Ladies and gentlemen, the Directive is in many ways unworkable for small (online) traders. Small quantities of individual shipping boxes are already becoming the manufacturer with all the obligations. The thresholds for small traders are too low, and they are quickly exceeded in the case of distance selling.
Filed in German · English published by the European Commission
I own a small business and sell second-hand collectors’ merchandise to historical enthusiasts. I am not bringing any new litter to the world, but products that have been seeing life for almost a century. Postita’s products to customers around the globe and I would not like to waste my business to use margins to pay extra fees for mailing packages in each country separately.
Filed in Finnish · English published by the European Commission
Ladies and gentlemen, as a medium-sized German company, we would like to draw your attention to an aspect that we consider problematic in the implementation of the European Packaging Regulation (PPWR): the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border deliveries within the EU.
Filed in German · English published by the European Commission
Ladies and gentlemen, as the operator of a small online shop for vintage perfumes, collectors’ items and other special or second-hand goods, I would like to draw your attention to the disproportionate burdens that, in my view, can be imposed on micro-enterprises as a result of the implementation of the PPWR.
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
With regard to the new PPWR (bureaucratic monster) Regulation, I do not want to go into detail at all about the obligation and costs of an agent in each country, that there will be enough others, and you know yourself what barrier you have created here for shipping within the Union.
Filed in German · English published by the European Commission
Ladies and gentlemen, we are a small family business that has existed for more than 70 years, and we produce and sell organic and special foods through the wholesale, retail and directly to consumers. We have also built up a small customer base in other EU countries. As of 12 August 2026, we are forced to completely stop cross-border trade to most other EU Member States.
Filed in German · English published by the European Commission
Spending money on up to 26 proxies is financially harmful for small and medium-sized enterprises. Sending only 2-3 parcels to the country makes no sense to send them to that country. As a customer, I live in Germany. De is the largest market, so it is most likely that a foreign distributor will appoint the authorised representative, as this will cover costs.
Filed in German · English published by the European Commission
As a small, internationally established trading company with 8 employees, we serve both B2B and B2C customers across Europe and beyond. The VAT scheme (OSS) has already placed a significant administrative and financial burden on our company, requiring registrations, external service providers and considerable additional effort for cross-border transactions.
Ladies and gentlemen, as the operator of a small online shop, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.
Filed in German · English published by the European Commission
I think this is something that needs to be done in a simple way and with as little administrative effort as possible. Lucid receives the notification for Germany from me. There can be no problem that reports can also be filed there for all countries, so that information can then be exchanged between countries. I pay a waste disposal operator in Germany.
Filed in German · English published by the European Commission
The current implementation of the Packaging and Packaging Waste Regulation is unsuitable for micro-enterprises engaged in cross-border e-commerce within the European Union. While reducing packaging waste and improving recycling are important objectives, the present system creates a disproportionate administrative and financial burden for small businesses.
Ladies and gentlemen, as a small CD-DVD distribution company, I would like to take this opportunity to draw your attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.
Filed in German · English published by the European Commission
I am a small business owner based in Lithuania, selling handmade products online to customers across the European Union. I fully support the environmental goals behind packaging waste regulation. However, the current implementation creates a disproportionate administrative and financial burden for micro and small businesses engaged in cross-border e-commerce.
Ladies and gentlemen, as an operator of online small and medium-sized businesses, 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
Dear Sir/Madam, I am the managing director of Burkhart Engineering GmbH. We sell vehicle parts and accessories from Germany via our own online shop worldwide, supplying almost all the Member States of the European Union. In the course of the PPWR, we have worked intensively on the new obligations and have already engaged a specialised service provider.
Filed in German · English published by the European Commission
Dear EU, the U stands for Union. But with the new PPWR, the EU is going back several steps away from what it actually means. Each country is now back on its own, at least when it comes to the online trade of SMEs. I sell used spare parts for E-Pianos/Keyboards/Synthesisers, so far shipping to the EU has accounted for 40 % of my turnover. This is no longer the case.
Filed in German · English published by the European Commission
As a medium-sized trading company (11 employees), we are internationally established and address B2B and B2C customers. The VAT scheme (OSS) has already required us a lot and led to high costs (contracting of service providers for EU countries, registration, etc.). The tightening of product safety standards and registrations has continued to hit us hard.
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 an operator of (very) small online sales, I would like to draw your attention to a particularly problematic consequence of the planned PPWR implementation: the obligation to appoint an authorised representative for the extended producer responsibility in each relevant Member State 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 draw your attention to what I consider to be a 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 system in its current form is absurd and will produce the opposite of the intended result. I sell reclaimed used laptop parts and pack everything in used boxes whenever possible, thereby helping to reduce the carbon footprint that the European Union is fighting so hard to lower. Thanks to my work, customers can repair their damaged equipment instead of buying new hardware.
As a small e-commerce owner, I generally welcome the objective of harmonising registration and reporting formats across the EU. However, from the point of view of a small enterprise, I would like to raise the following concerns: 1.
Filed in German · English published by the European Commission
In principle, we welcome the objectives of the PPWR, but we are critical of the planned obligation to appoint a separate authorised representative for extended producer responsibility in each EU Member State 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 (Kleiderkabine GmbH), 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
Ladies and gentlemen, the objectives of the PPWR, in particular the reduction of packaging waste and more effective producer responsibility across Europe, are in principle to be welcomed. However, when it comes to practical implementation, care should be taken to ensure that the resulting administrative requirements remain economically viable, especially for small businesses.
Filed in German · English published by the European Commission
My company has existed for 23 years, but we have never faced such a bureaucratic monster. For small and medium-sized enterprises, under the labelling requirements of the Product Protection Act and now also the EUDR, it is simply no longer manageable and we are serious about ceasing to exist. We have already rejected orders because we have not yet been able to respond so quickly and comprehensively to PPWR.
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
Dear European Commission, Unfortunately, the new rule is far from well thought out and leads not only to immense disadvantages for businesses, but also for EU citizens from small Member States and for the environment as a whole. A few examples: 1. Completely different practices in different Member States: Spain needs Hague Apostille (bureaucratic) and Italy needs a local address, which again costs extra each year.
Filed in German · English published by the European Commission
As the sole owner and operator of a micro-enterprise manufacturing guitar effects pedals in Belgium, I sell directly to customers across the EU through my own e-commerce website. I want to flag how the current approach to national producer registers under Article 44 PPWR is creating a disproportionate burden for very small, cross-border sellers like myself.
Thought we had open trading routes and almost same rules with all eu countrys. This new PPWR has forged to stop selling trough the whole eu. What idiot forges a registration rule without a central system like the OSS. And idiot part you have to pay for almost 20 countrys 500 euro to get the license? Come one stoopit EU! Hope allot of companys are giving a big finger too this rule and wont pay any penaltys.
These rules may create a disproportionate financial and administrative burden for micro and small businesses. Many of us receive only a few orders from other EU countries, yet would have to deal with registration requirements in each country. Please consider a simple, harmonised EU system or an exemption/simplified regime for very small businesses and low-volume sales.
I am already registered for packaging compliance in Germany and have been complying with the system for the past two years. At present, I pay approximately 20 per year because the amount of packaging I actually place on the German market is extremely small. Under the new system, the minimum cost would already increase to around 75 per year, even though I do not sell enough in Germany to justify such a fee.
The PPWR risks creating a disproportionate administrative and financial burden for small businesses while adding another layer of bureaucracy to waste management and recycling systems that already exist. Waste collection, sorting and recycling systems are already in place and businesses and consumers already pay for these services.
I am a one-person small business owner based in Lithuania, selling handmade products mainly through Etsy. I already comply with packaging requirements in Germany through LUCID, because Germany is my largest EU market. But almost half of my EU sales come from customers scattered across other Member States. In many countries I receive only 1-20 orders per year, and in some years none.
I am surprised how I can have easy access to the markets in the USA, China, Canada, Brazil, Great Britain, Switzerland and 150 other countries and at the same time have an unbearable financial bureaucratic burden to my neighbors France, Germany and 24 other EU member states. There is something rotten and smelly at the base of everything. And it is not recyclable. It is not repairable.
Ladies and gentlemen, the new EU regulation may be a good idea, but it is not feasible for me as a small businessman. The PPWR declaration of conformity is not a problem for me, as I know where to buy my packaging and filling materials.
Filed in German · English published by the European Commission
Dear Sir/Madam, My company Iko Audio is still in the process of being set up. We sell high-quality loudspeakers that can be produced independently at home using a 3D printer. This requires materials such as seals, frequency softeners, etc. We intended to sell this product to the EU far and even globally. The new Packaging Directive makes it impossible to sell in the EU, at least in the initial phase.
Filed in German · English published by the European Commission
We support the objectives of the PPWR: reducing packaging waste, improving recyclability and harmonising packaging rules across the EU. However, its current form risks creating an administrative burden disproportionate to its environmental benefit, particularly for SMEs.
I am a self-employed artist and designer based in Austria and I run a one-person microbusiness. Until now, I have been able to sell small quantities of my products directly to customers across the European Union. These are not mass-market goods: they are limited-edition art products, prints, postcards and other small creative products, often sent only occasionally to an individual customer in another Member State.
The problem is not fair for all, artists and creators are faced with a fait accompli to go through a paying agent, of course, but not all have so much financial means to do so, it is like e-invoicing, the EU is becoming a mafia. To be able to work, you have to pay and go to the cash office. This is against the free trade market, people want to siphon money for their own interests.
Filed in French · English published by the European Commission
The PPWR, if it remains valid in the current version, will severely restrict the barrier-free movement of goods in the EU. This is for a number of reasons: 1. Distributors will supply selective markets, if at all. 2.
Filed in German · English published by the European Commission
PPWR of 12.082026 Dear Sir/Madam, the EU Packaging Regulation has been applicable since 12 August 2026. As the operator of a newly established, small online retail business, I am particularly critical of the introduction of the planned implementation of the PPWR producer registers.
Filed in German · English published by the European Commission
As the owner of a small business that has been manufacturing natural wooden toys in Germany for over 30 years, I am significantly affected by the new European packaging regulations. I fully support environmental protection, recycling, and the responsible use of resources in general! In my specific case, over 90% of the cardboard boxes I use for shipping are second-hand, collected for me by various local retailers.
Hi, I'm Cristina and I want to join all the small entrepreneurs who are crying out for help and support from a community that should have protected our small businesses and stimulated the entrepreneurial environment. I'm from Romania and I have a small handmade jewelry and mandala painting business. I only have a few orders a year in the EU but little by little it adds up and for a small business it means a lot.
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 for the extended producer responsibility in the case of cross-border sales.
Filed in German · English published by the European Commission
Years ago, Italy had a huge problem with the mafia and garbage. Which was solved with exceptional political will. Back then, countries like Germany, France, Belgium, the Netherlands, Sweden pointed the finger at us, the Italians, that we were a mafia state. Today, however, the perception is different. These same countries have been taken over by the same garbage mafia.
Ladies and gentlemen, as a small commercial operator, I would like to express my concerns about the new EU Packaging Regulation (Regulation (EU) 2025/40). I engage in a small commercial trade in second-hand goods, in particular LEGO, Playmobile, toys, records, cassettes, tools and various vintage items. My turnover, and in particular my turnover with customers abroad in Europe, is very low.
Filed in German · English published by the European Commission
I believe that small business ownerssuch as eBay sellers, Kleinanzeigen sellers, Catawiki sellers, small online shops, and artistsshould not have to make payments to the European Union. This is because their shipping volumes are lower compared to giants like Amazon, Bol, and AliExpress, which ship far larger quantitiesand do so less efficiently.
These new rules are completely unfair and unsustainable for small businesses. Recycling and packing rules are great but it's the big companies that need to be stepping up, not the little grass roots businesses that are trying to be innovative, and create work in a world that's increasingly difficult to live in.
Ladies and gentlemen, as the operator of a small online trade in ceramics, 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
Comments on the PPWR National Register of Producers I expressly support the objectives of Regulation (EU) 2025/40. Reducing packaging waste, improving recycling and making producers more accountable. However, the specific design of Extended Producer Responsibility (EPR) and national producer registers risks becoming disproportionately burdensome and costly for micro-enterprises selling small quantities across…
Filed in German · English published by the European Commission
I am writing on behalf of Skånes Hemslöjdsförbund, a non-profit organisation in southern Sweden working to preserve, develop and disseminate traditional handicrafts and cultural heritage. Our organisation operates a small shop selling Swedish and regional handicrafts, as well as material kits for traditional embroidery techniques that are part of Sweden's cultural heritage.
I urge the European Commission to take the impact of the PPWR on micro-enterprises seriously. As a micro-entrepreneur, I was genuinely shocked when I realised that selling goods across borders within the EU Single Market can require separate registrations, reporting, contracts, fees and, in some cases, authorised representatives in different Member States.
This regulation is a straightforward disaster for small businesses (with little or no staff). Individual registration in up to 26 countries, each with its own system, its own costs, its own rules, its own thresholds: it is impossible for an individual entrepreneur to understand without legal help.
Filed in Dutch · English published by the European Commission
Ladies and gentlemen, as the operator of a small specialised online shop for Bonsai, Bonsaischalen and accessories, we would like to draw your attention to a particularly critical point in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border sales within the EU.
Filed in German · English published by the European Commission
Hello, we are a family business from Germany with 12 employees and sell our articles across Europe. Our customers from Germany account for around 80 %. The remaining 20 % will be distributed among Austria, France, Belgium, the Netherlands, Italy and Spain.
Filed in German · English published by the European Commission
Hello, we are a German SME called Leenskleidung (www.lebenskleidung.com) selling sustainable fabrics B2B and B2C across the EU. We minimise packaging and are willing to pay the actual EPR costs generated by our packaging. However, the fragmentation into national registrations, reporting systems, minimum fees and authorised representatives makes cross-border trade economically disproportionate.
Submission to PPWR consultation (Initiative 15352) I am writing as a disabled DIY musician based in Wales, UK. My project, tAngerinecAt, operates entirely independently no label backing, no booking agent, no PR budget and has run for years on direct online sales of CDs, vinyl, and merchandise to a small, dedicated audience across the EU and UK.
My business ships maybe 50 parcels a year into the EU from the US. Each one is individually packaged as custom order. The products we sell are used in research and development, science, and engineering labs, government entities, etc. We sell enough in the EU that it will be painful to both our business and our EU customers if we have to cease shipments.
Ladies and gentlemen, as a sole trader, I operate a goldsmith without an employee. My customers come mainly from Germany, but I have occasional international customers. I was very sorry last year that I had to exclude Austria from my online shop, as the costs for the authorised representative there are disproportionate to the volume of orders, and now I also had to exclude the other EU countries.
Filed in German · English published by the European Commission
Ladies and gentlemen, as an operator of online sales, 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 for the extended producer responsibility in the case of cross-border sales.
Filed in German · English published by the European Commission
Ladies and gentlemen, I run a goldsmiths’ artisanal business in Germany with an employee. In the past, we have also supplied individual customers from other EU Member States, in particular Austria and France. This does not involve large-scale mail-order sales, but rather a small number of high-quality jewellery items and correspondingly small quantities of packaging.
Filed in German · English published by the European Commission
I run a small book publisher in the UK. This legislation will kill my entire EU business which I have run for almost 20 years. I ship books to customers across the EU in cardboard packaging. To comply with the new rules will cost me thousands of Euros, making it impossible for me to send books to my small number of specialist customers. You are killing trade and killing businesses.
I have a micro business in Ireland making handmade ceramics and the new PPWR rules will completely shut down my sales outside Ireland to other countries in the EU. I only have a handful of sales to different EU countries and I use recycled boxes and recycled newspapers for packaging. Also because my handmade ceramics are fragile I need to use a larger amount of recycled paper than the PPWR allows.
Normal development of environmental torture in Europe - small businesses have easier access to world markets and a restriction to the single European market. The unthinkable is a fact - the basis for the existence of the European Union no longer exists and no one believes in the tales of free movement of goods and people, the principle of "small business has priority and equality" or the rosy single market in which…
Ladies and gentlemen, as the owner of a small Austrian online trading company supplying customers in many EU Member States, I am directly concerned by the provisions of the PPWR. I warmly welcome the objective of reducing packaging waste, conserving resources and promoting reuse.
Filed in German · English published by the European Commission
How should onlineshops with sales of 1000-5000 euro to different kind of countries survive. As a matter of fact you cant sell to these countries anymore and the loss of missed taxes will be x-times what EU are thinking to make. Our products are sold just by us for while Europe but now must seize down to maybe 3-4 main countries. Total the opposite what the EU stands for .
As a small company this regulations seems way too heavy. We ship sometimes 0-2 parcels of sustainable fashion to other eu countries. With paper hangtag and reused paper envelope made of recycled paper. All is easily recyclable and very minimal. Still we should registrate 27 seven times and update information to manage sometimes 2 paper envelopes sent to one country.
Ladies and gentlemen, as the operator of a small online shop, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.
Filed in German · English published by the European Commission
For more than two decades, I have been marketing a dongle for my software products worldwide. Within the EU (with the exception of my home country), I sell around 10-20 units per year to customers in different EU countries. Compliance with the PPWR would exceed the yield of the individual sales. I therefore currently feel compelled to restrict sales within the EU to Germany (my home country).
Filed in German · English published by the European Commission
I have been in the e-commerce business for 28 years, specializing in handmade goods. Last year alone, I shipped around 60 kg of postal envelopes within the EU, with my annual average ranging between 50 and 65 kg. Today, simply to retain access to the European single market, I am required to pay a private firm around 9,800, plus additional recycling fees for each individual country.
Ladies and gentlemen, drum-tec (www.drum-tec.com) is a highly specialised retailer of electronic percusses, unique in the world. We provide advice, products, solutions and services that large market players cannot afford in this depth and specialisation. It is precisely such specialised companies that ensure diversity, innovation and a much better product world for private end-users.
Filed in German · English published by the European Commission
I run a small independent antiquarian bookshop in Sweden, selling new and second-hand books. Occasionally, we send a single book to a customer in another EU country, usually in a cardboard envelope or small box purchased from a Swedish supplier. In some countries, we may have only one or two customers per year. I support the environmental aims of the PPWR.
I am from Romania and I have to hire a company in Germany to count how many packages I have sent. Then I have to pay another company (affiliated organizations, as far as I understand) to do the work and profit from the work done. What is this strange job? What is this scandalous policy of subsidizing working and profitable business models? Is this the EU? Is this the free single market?
The cost for small and micro businesses to register individually in every EU state is a disproportionate burden. The cost is also prohibitive- costing a huge amount before a sale has been made. It will also hinder the cost and availability of buying materials from other small EU based businesses.
Ladies and gentlemen, since 2001 we have been operating a small, specialised online shop for merchandise made from pure silk (www.silknature.de). Naturally registered with LUCID in Germany, all packaging is licensed in Germany. For some time now, due to the costly obligation to appoint authorised representatives, we have had to stop sending our silk materials to end-users in Austria and some other EU countries.
Filed in German · English published by the European Commission
Ladies and gentlemen, Zeitauktion GmbH is an online retailer specialising in high-quality second-hand watches. We also sell our products cross-border within the European Union. We would like to draw your attention to a particularly problematic aspect of the implementation of the EU Packaging Regulation (PPWR): the obligation to appoint an authorised representative for the extended producer responsibility in each…
Filed in German · English published by the European Commission
These rules – if I interpret them correctly – make it impossible for me to continue my current secondary profession. I sell LEGO parts across the EU, which would now mean that I would have to make a special arrangement for each EU country that would cost me a relatively large amount of money and would make it impossible in practice to continue my trade.
Filed in Dutch · English published by the European Commission
I am submitting this feedback on behalf of an SME established in Germany that sells goods cross-border to customers in several EU Member States. We fully support the environmental objectives of Regulation (EU) 2025/40 and agree that producers should contribute fairly to the collection and recycling of packaging.
Ladies and gentlemen, as a digital print shop (micro-entrepreneurs for very high-quality micro-conditions), 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, not only does the implementation of the PPWR promote a significant increase in bureaucracy, but it is the small things that are almost incomprehensible to traders. The recycling rate is to be increased, but it is no longer possible to use used cartons, as these declarations of conformity are also needed, for example.
Filed in German · English published by the European Commission
How bitter should micro-enterprises like us bear this additional (after REACH and many more) administrative burden? Unfortunately, the EU officials in Brussels – who are completely alienated from the practice of a small company – are only able to destroy the EU and are now so far away from the original idea of a free internal market that it is hoped that the whole shop will soon break completely together or finally…
Filed in German · English published by the European Commission
From the point of view of a small online trader based in Germany, I would like to draw your attention to the considerable practical burdens arising from the current design of extended producer responsibility for packaging. I sell predominantly already fully packaged branded products, which I regularly buy within the EU and resell unaltered.
Filed in German · English published by the European Commission
Dear Sirs, this is biggest bullshit regulation thought out by political amateurs who never worked in private industry let alone were responsible for a small business. we had to stop any deliveries to any EU country as it is not justifiable to spend hundreds to thousands of Euros for bueraucratic nonsense to legally ship small parts to countries which only occassionally buy small parts.
I am writing as the owner of a small B2B company in Germany. We sell industrial transport equipment through our own online shop and ship to commercial customers in Germany and, where it is still economically possible, in other EU Member States. We support the environmental objectives of the PPWR.
The PPWR Must Not Turn the EU Single Market into 27 Separate Markets Pharmabinoid B.V. Response to the implementation of Regulation (EU) 2025/40 Pharmabinoid B.V. supports the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR) and the principle that companies should contribute fairly to the recycling and waste-management costs of the packaging they place on the European market.
I welcome the European Commission’s objective of standardising the requirements for national producer registers under Article 44 of Regulation (EU) 2025/40. However, from the point of view of a small B2B trading company, the specific situation of en-route transactions should be explicitly taken into account. My company is almost exclusively active in the line business.
Filed in German · English published by the European Commission
This proposed implementing regulation is like painting the window sill on a burning house instead of calling the fire brigade. (EU)2025/40 is completely dysfunctional, a serious violation of the common market, and must be scrapped. There is no chance of salvaging this ill guided regulation. The rules for registration and marking of the packaging materials miss any contact with reality.
as an operator of small online sales, I am very critical of the planned obligation to appoint an authorised representative under the PPWR in the case of cross-border sales. Individual sales to another EU country may require an authorised representative to be appointed and paid for there.
Filed in German · English published by the European Commission
Subject: Feedback from a small business operator on the PPWR/harmonisation of packaging registers Dear Sir/Madam, as a small business operator from Germany, I would like to speak out strongly against the unacceptable bureaucratic and financial hurdles of the new EU Packaging Regulation (PPWR).
Filed in German · English published by the European Commission
The PPWR jeopardises the free movement of goods through disproportionate bureaucracy and costs. As an entrepreneur and a lawyer, I am deeply concerned about the current design of the EU Packaging Regulation (PPWR). The free movement of goods is one of the fundamental principles of the European Union.
Filed in German · English published by the European Commission
Ladies and gentlemen, as a small German online trader, we would like to share our views on the planned rules on national producer registers under the PPWR. In principle, we expressly welcome the objectives of the PPWR. Reducing packaging waste, promoting the circular economy, and improving the re-use and recyclability of packaging are important and useful objectives that we support.
Filed in German · English published by the European Commission
I am self-employed individual hand making and selling guitars and accessories. I recently took the difficult decision to pay for an authorised EU representative to ensure compliance with GPSR and enable me to sell to the EU once again, considering I already operate at a loss. This new directive fully prevents me from selling to the EU due to the cost of registering with an appropriate representative.
Hello, I am an internet retailer, a small business. My customers are record collectors from all over the world. The US is already a catastrophe because of Trump's customs. I was always glad that we have the EU. I appreciate that you want to reduce waste. But with the PPWR you will miss the target. You make the European market weaker. A handful of people work here.
Ladies and gentlemen, as a small owner-run company with its own development, production and online sales, we are directly affected by the planned PPWR rules on extended producer responsibility. Our company is a micro-enterprise according to the European SME definition: less than 10 employees and no more than EUR 2 million in annual turnover or balance sheet total.
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
Dear European Commission, I am writing to share my concerns regarding the Packaging Waste Regulation (PPWR) and EPR, particularly its impact on micro-enterprises selling across the EU. I run a very small business with just 1.5 people, including myself, and relatively small revenues.
We are a small German company and plan to expand our sales to other EU Member States. We take it for granted that we will contribute to the costs of collecting and recovering the packaging we place on the market. However, the administrative and financial burden involved is problematic.
Filed in German · English published by the European Commission
Ladies and gentlemen, as the operator of a small online shop, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.
Filed in German · English published by the European Commission
As a sole trader in the field of model building, I am affected by the PPWR, as are many traders in my area. I cannot afford the costs in terms of time of reading 26 different sets of rules in 26 different languages and implementing them in 26 different countries. I need this time for my actual business.
Filed in German · English published by the European Commission
Ladies and Gentlemen of the EU. Directly in advance. As a child of the 1970s, who was still acquainted with East/West Time, borders, individual currencies and even reunification, I am fundamentally a supporter of the European idea. The euro, invisible borders, free movement... wonderful. The ‘we’ instead of the national ‘I’, which the EU also wants to portray, is standard for me.
Filed in German · English published by the European Commission
I am preparing to launch Shaka Digz, a registered Swedish micro-enterprise and online clothing brand. I support reducing packaging waste, but the proposed national registration system is disproportionate for micro-enterprises. One sale to another EU country could require separate registration, reporting and an authorised representative.
The Federation of Finnish Woodworking Industries supports a genuinely harmonised and automated format for national producer registers. Four amendments are needed to prevent double reporting and disproportionate burdens for wood and transport packaging. Cross-border movements and reimbursement.
From the point of view of a small and medium-sized enterprise, the PPWR is becoming a considerable administrative burden, which is difficult to implement, especially for SMEs. A harmonised directive is a long way from being achieved. Instead of uniform rules, national one-size-fits-all solutions continue to emerge, with different registration, reporting and proof obligations.
Filed in German · English published by the European Commission
Concrete impact on our operations: We are massively losing turnover, as we can only send it to consumers in Germany and all other EU citizens must be excluded from our product. As a small shop with only a few kg of packaging (all of which we have already registered in Germany), we cannot afford the costs and effort involved! This law contradicts the idea of the EU as a single market.
Filed in German · English published by the European Commission
We are a small online shop from Austria and supply customers in Germany. Further expansion into EU markets is not possible: on the one hand, the costs for an authorised representative (per country!) are too high; on the other hand, the bureaucratic burden is indisputable. We want to develop our business further by using our resources rather than satisfying the wishes of bureaucrats.
Filed in German · English published by the European Commission
Ladies and gentlemen, as an operator of a small online shop, I unfortunately had to give up selling abroad in Europe as a result of the introduction of the PPWR. Above all, the obligation to appoint an authorised representative for extended producer responsibility in the case of cross-border sales is unaffordable for my company with few sales abroad.
Filed in German · English published by the European Commission
Good afternoon, this new regulation is a blow to the face of all micro-entrepreneurs who, for example, run a business as a side business and also supply neighbouring countries to the EU. The EU has allowed free travel to all EU countries and is now preventing free trade. I am a one-man show that manufactures and distributes electronic systems for model building.
Filed in German · English published by the European Commission
Dear Sir or Madam, Did anyone consider small businesses when the authorised representative obligation was designed? I run a one-person online shop selling vintage and second-hand clothing in Germany. I ask because from where I sit, the answer looks like no. Under the PPWR producer registers, a single sale into another Member State can trigger the duty to appoint and pay an authorised representative in that country.
As an operator of small online sales, I would like to draw your attention to a particularly problematic consequence of the PPWR: the financial and administrative burden of cross-border shipments within the EU, in particular through the obligation to appoint an authorised representative for the extended producer responsibility. In principle, I support the objectives of the PPWR.
Filed in German · English published by the European Commission
I am a very small one women business, seling my crafts on Etsy for 14 years. I agree, that I should pay for the waste I create and have absolutely no problem with that. But paying for the environmental impact of my packaging and maintaining a separate national compliance structure simply to be allowed to pay for that packaging are two very different things.
In addition to my actual profession, I practise a small-scale farming of discus fish in Germany. I sell my offspring to private customers and specialist retailers in Germany and many other European countries via my own online shop. I strongly support the idea that companies placing packaging on the market contribute adequately to the costs of collection, disposal and recycling.
Filed in German · English published by the European Commission
Dear Members of the European Parliament, I'm writing as the owner of a small online shop for board games. I founded the shop in 2024, with the hope of eventually being able to live from its earnings. In the meantime, I have spent countless hours, besides my day job, bringing my shop to its current state and being able to ship within Europe and the UK.
As a sole proprietor with an annual revenue ceiling of EUR 10,000, I find it practically impossible to comply with the PPWR requirements when shipping products to customers in other EU Member States. The requirement to appoint local legal representatives can result in costs of several thousand euros per country, which is completely disproportionate for a micro-business with such a limited turnover.
We are a family-run medium-sized enterprise. The obligations to which we are subject as soon as the PPWR enters into force represent a huge additional burden for us. All the tasks (authorisations, declarations of conformity, etc.) carried out by an entire department in the case of larger firms will be carried out by two members of our staff. This takes a long time.
Filed in German · English published by the European Commission
I am concerned about the impact of the new packaging rules on small, traditional and artisanal businesses like ours. Craftsmanship, authenticity and the way products are carefully made and presented are an important part, and these new requirements can have a disproportionate effect on us.
Ladies and gentlemen, as **fejn GmbH**, a small e-commerce company, would like to draw attention to the considerable burden 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 contacted the Swedish Environmental Protection Agency (Naturvårdsverket) just over a year ago to proactively find out which rules applied, or were going to come into effect. I was told to check the information on their website, but the problem was precisely that their website contained no information at all.
The economics of recycling in the EU: regulations, fees and corporate profits Under European Union directives mainly the Waste Framework Directive and the upcoming Packaging and Packaging Waste Regulation (PPWR) the burden of waste management has shifted to the private sector through Extended Producer Responsibility (EPR).
Since 2001 I have run an online shop for remote-controlled model cars, from which I enjoy young and old. With the new PPWR Directive, it is no longer possible for me to send it to the EU countries, which account for just over 20 % of my turnover, as it is not worth defining an authorised representative even in the top five countries.
Filed in German · English published by the European Commission
The regulation tramples on many of the EU's uniform laws. This is an indisputable fact. But we should not blame the green policy. It is not the policy that exports the production of European business outside Europe. It is not the policy that destroyed agriculture and made it dependent on subsidies. It is not the policy that stops the existence of small producers and replaces them with non-European production.
The EU should be one of the world's most prosperous and competitive regions, yet growth and competitiveness are increasingly falling behind. Instead of removing barriers and unleashing European businesses, Brussels keeps adding layers of regulation and bureaucracy that make it harder to invest, innovate and grow.
As a small business owner, I support the goal of reducing packaging waste and making producers responsible for the packaging they place on the market. However, the administrative burden should be proportionate to the size of the business.
The EPR regulations will effectively kill cross-community business for micro-enterprises and sole traders, particularly artists and makers. The need to have separate arrangements for every member state to which art is shipped with set-up fees that can be up to 50% of the cost of an artwork is unsustainable. Most artists will ship one or two artworks to a given country a year, to maybe have 3 or 4 EU countries.
As a UK based small business owner, I am shocked that the EU has devised such a disproportionate, destructive and ill thought regulation. Not only will these new rules change the way many low volume operators do business, it will stop the majority of small business EU trade that this nonsensical ruling is looking to benefit from.
Subject: Violation of the EU Single Market and the "Think Small First" Principle by Regulation (EU) 2025/40 (PPWR)As an EU citizen and micro-entrepreneur, I submit this formal contribution to denounce the brutal violation of the foundational pillars of the European Union by the new Packaging Regulation (PPWR).
Are not the small traders, in the sum of those who pay the most VAT? If almost all traders have half or more of their turnover missing because most cannot afford to implement the PPWR, the turnover tax revenue of the individual EU countries is also likely to fall significantly. To remain silent on the additional bureaucratic burden.
Filed in German · English published by the European Commission
Small businesses face a disproportionate administrative and financial burden from these new rules. For a small business with only a few dozen shipments per year, registration, reporting requirements and potentially the need for a local authorised representative leeds to punitive costs far above the actual packaging and recycling fees.
All European consumers, businesses and farmers should know the most important thing. Germany, France and several other countries have introduced this regulation in its most cruel version. In these countries, consumers are burdened three, four or more times with eco-taxes for the same item or its production. In these countries, green policy has reached levels of super-profit from recycling.
Ladies and gentlemen, as a small owner-managed handmade company, we would like to draw your attention to a particularly critical point of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border sales within the EU. With Noraya, we handmade and sold dog collars, lines, crockery and dog brands through our own online shop.
Filed in German · English published by the European Commission
Ladies and gentlemen, I am a jewellery designer and have been operating as a small/women’s enterprise since 2014, selling only handmade jewellery and brute hair jewellery online. Since the EU set financial requirements for each Member State, I have sold only in Germany. In particular, transactions with customers from Austria and Switzerland have broken down.
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
Feedback from the public consultation Draft legal act Implementing Regulation on the harmonisation of producer registers (Extended Producer Responsibility for Packaging, PPWR) Committee: C37000 | Category: REFIT feedback deadline: 6 August 2026 10 September 2026 Dear Sir/Madam, as the operator of a small online shop, I am writing to you with a specific concern about the planned implementation of the PPWR producer…
Filed in German · English published by the European Commission
The new PPWR Regulation (EU 2025/40) and the blind application of the Producer’s Wider Liability (EPR) constitute a direct violation of the fundamental principle of free movement of goods. Under the guise of a green policy, this text destroys the fabric of cross-border micro-producers, craftsmen and sellers (on eBay, Etsy, Amazon), while enriching private waste management structures.
Filed in French · English published by the European Commission
Good afternoon. In principle, I support the objective of reducing packaging waste and making companies responsible for the packaging they place on the market. However, the new requirements in their current form pose a hardly solveable problem for small online traders and should be urgently revisited. We send most of our orders within Germany. Other EU countries sometimes receive only one or two packages per month.
Filed in German · English published by the European Commission
In principle, we welcome the objectives of the new EU Packaging Regulation (PPWR), in particular reducing packaging waste, improving recyclability and promoting a functioning circular economy. As a small Austrian company, we already support these goals today and deliberately invest additional time and financial resources in more sustainable solutions.
Filed in German · English published by the European Commission
The corrupt politicians in Brussels have destroyed small businesses in Europe and given full advantage to the big traders of goods from China. They deserve to become honorary residents of China, to catch planes there and never set foot in Europe again. And we in Europe will use goods made in China from here to the end of the world.
Exclude small and micro businesses from the A.R. Rule as it is disproportionate towards micro businesses! We Cant afford it, our shops would have to close. Is this what is being in the EU means? Try no free movement inside EU anymore, which is what EU is all about right?!
Filed in Portuguese · English published by the European Commission
I am the founder and sole operator of a new micro leathercraft business established in Greece. I design, manufacture, package and sell my products myself. My business currently receives approximately one or two orders per month and is still trying to become financially sustainable. Access to customers across the EU is essential for its growth and survival.
These new PPWR rules are beyond absurd for micro 1 person creative businesses like mine. I sell to on average 6-8 other EU countries and have little time for admin as I am making my craft. The majority of businesses like mine already use recycled packaging and are very conscious of waste and recycling but to have to register and pay in each country will kill my intra EU sales. This is the opposite of a common market.
The new rules will lead to significant cost increases for SMEs and individual entrepreneurs, with significantly increased costs. There is an urgent need for exemptions for companies below a certain turnover threshold. Unfortunately, we will only be able to sell within Germany and outside the EU.
Filed in German · English published by the European Commission
I am 100% pro waste reduction and management. But not in such an uncoordinated way. This law is effectively endangering my business that i built for 10+ years. The whole law is not thought through properly. Create a law that can be implemented ONCE in the EU and combine it with the fee systems already in place (i.e. German Lucid) to create A SINGLE central instance for packaging registrations and fee payments.
This law is grossly unfair to small businesses. The fees and admin is disproportionately onerous and small owner-maker businesses are not the ones causing threat to economies or ecosystems. Small businesses famously source low impact packaging and pride themselves on caring for the planet. This law is stifling creativity, culture and diversity.
As a small family business with fewer than 10 employees, we have fought over the last decades to build a name with our niche product on the European market. Avoiding packaging and reusing packaging material is not just a heart issue, but simply a business imperative.
Filed in German · English published by the European Commission
This is absolutely horrible and will directly destroy my small family business. There must be comprehensive exemptions for micro and small businesses! This regulation needs to be re-created from the bottom up, to be proportional and to not create administrative weight or financial burden for Micro-businesses and SMEs - how is the EU business supposed to grow if we adopt regulations that crush small businesses and…
I am a very small. sole proprietor business in France, as such the new rulings will make it impossible for me to continue. It is simply not economically feasible, the costs far outweigh any profit I currently make. I find it ironic that this legislation effectively will make it easier for me to sell items & send them to Countries outside the EU than within it, which seems to be against everything the EU stands for.
In recent years, new obligations, rules, laws have been constantly added. Every month it becomes more complicated, difficult, time-consuming and expensive for traders. The PPWR puts the crown on the whole. I really wonder if anybody is concerned about what this means for small businesses or retailers like me. I wonder even more whether MPs really think about it or simply agree because they expect the party to do so.
Filed in German · English published by the European Commission
Ladies and gentlemen, in connection with the planned implementation of the PPWR, we would like to draw attention to one particularly problematic point in our view: the obligation to appoint authorised representatives for extended producer responsibility in cross-border sales. So far, we are shipping our goods to more than 20 countries and we wanted to further develop our international business.
Filed in German · English published by the European Commission
Dear Sir/Madam, In principle, I support the objectives of the PPWR. However, for small and medium-sized online traders, the administrative burden is very high. The requirement to register in each EU Member State and, if necessary, to appoint an authorised representative is particularly difficult.
Filed in German · English published by the European Commission
In principle, I support the objectives of the PPWR: less packaging waste, more recycling and more reuse are right and important. However, what I consider disproportionate is concrete implementation to the detriment of micro and small enterprises. I am a sole trader and, for example, send only around 2050 parcels per year to Austria.
Filed in German · English published by the European Commission
As an EU-based company and resident, it was an odd feeling indeed to disable all EU sales from our web shop. What happened to free trade between the EU states? We've survived a lot of things in our 30 years as a company: new rules, new regulations, the covid lockdowns, Brexit, USA tariffs, our distributors dying out, bricks-and-mortar shops going under etc., but we have managed to set up a thriving mailorder…
Where are we talking about cutting red tape for years? The PPWR is another example of how European regulation is burdening small and medium-sized enterprises with ever-increasing red tape and documentation requirements, without creating corresponding practical or environmental added value.
Filed in German · English published by the European Commission
Dear Sir/Madam, I run a small webshop in second-hand books. I would like to give an example: in 2025 i shipped just over 3 kg of packaging material to Belgium. With the currect rates that should cost 2,60 euro EPR tariff (fair enough) + 330,00 euro (excl. VAT) for handling and representation in Belgium: 332,60 euro for just over 3 kg of packaging material.
Ladies and gentlemen, I have been self-employed for 27 years and run a small brick-and-mortar shop, including a small online shop. I do not have a legal department, a compliance department or a staff. I am an ordinary micro-entrepreneur who tries to run his business through increasingly difficult times.
Filed in German · English published by the European Commission
As a small e-commerce business for 20 years, I would like to raise the following concerns: Delegates in each EU country: Organisationally hardly feasible for micro-enterprises Additional costs for external service providers Not proportionate to low turnover abroad Risk that small traders no longer supply certain EU countries More rather than less red tape: The PPWR, however, creates additional registration, evidence…
Filed in German · English published by the European Commission
Dear Sir/Madam, Thank you very much for the opportunity to comment. The implementation of this Regulation in its current form is a major constraint on intra-European trade. Small businesses are actively prevented from sending goods to other EU countries because, on the one hand, registration and the appointment of authorised representatives in other EU countries often suffer from language barriers and, on the other…
Filed in German · English published by the European Commission
In principle, we welcome the objective of increasing transparency by recording packaging volumes and providing a reliable data basis for European packaging policy. However, the draft requirements impose a disproportionate administrative and financial burden, especially on small and micro-enterprises. We are particularly critical of the obligation to appoint an external representative in each Member State concerned.
Filed in German · English published by the European Commission
After reading about this stupidity I tried to find or comprehend the information on the available websites. This is impossible, it is as clear as mud. According to info from other sources I have to register and pay fees for every country I ship to. The countries I ship to change per year and can be as little as 40,-- per country per year. These are replacement parts that only I make.
I am registered in LUCID and I submit my volume declaration there. Why can I not simply say x kg of packaging, of which x kg to other EU countries or x kg by country and country? Simply a central point as in the case of OSS. I report to LUCID and the countries then make it themselves. Would this be too simple and implementable for SMEs?
Filed in German · English published by the European Commission
Subject: Disproportionate impact on individual artists and micro-producers I am an independent artist who occasionally sells an original artwork to a customer in another EU Member State. I fully support the objectives of reducing packaging waste and producer responsibility, but I am concerned about the disproportionate impact of national registration requirements on very small-scale sellers.
This has devastated my EU Sales. we are a small business with only 3 staff, all EU sales have had to stop. This legislation is favouring big businesses that can pay and deal with these complicated expensive registrations, small business cannot. You are supporting the likes of Amazon and big business not small business. Please make this exempt for smaller sized or smaller turnover businesses.
Ladies and gentlemen, we are a small company (GbR, 2 business partners, 1 x mini-jobber, without our own legal department, etc.) from Germany and we sell our goods almost exclusively via online sales. We would like to take this opportunity to draw attention – from the point of view of a small enterprise – to a particularly critical point in the planned implementation of the PPWR producer register: The obligation to…
Filed in German · English published by the European Commission
Hi, We are a small business in Ireland manufacturing and distributing products for small independent artists to fans across the EU. This regulation essentially places us behind all the major manufacturers and distributors both inside AND outside the EU.
I just want to remind you that a micro-business often has an annual income only about 40 000 euro. A micro-business is often made up of ONE person who does all the work. The proposed new regulation will, in practice, destroy businesses like this. I sell my work online. At most, 250 shipments go to the European Union around 50 to Germany and France, and the rest only a few items per country.
the new laws regarding PPWR are far too expensive for most small and micro businesses. reduction of plastic and waste is massively important, however having to register for each separate company and pay extortionate fees to the random and unregulated companies that individuals is unworkable. Most companies offering this service charge between £300 to £2000 per year per country.
I am the owner of Nifty Needles, a micro craft business based in Northern Ireland. I design and sell my own embroidery, quilting and textile craft patterns, kits and notions. I am a sole trader and my business operates on a scale vastly smaller than the large companies these regulations also affect. Until now I have been able to sell occasional orders to customers in EU Member States.
Ladies and gentlemen, I am appalled by the implementation of the PPWR. We are a small business and the red tape and costs are huge. After consulting five different providers (Landbell, Interzero, etc.) for packaging waste, we can expect almost 1000/per country/year. Although these agents are required at 12.8, this service is not yet offered at all.
Filed in German · English published by the European Commission
Ladies and gentlemen, I am writing as a sole trader regarding the requirements for the national producer registers. I produce biocertified natural cosmetics in Austria from domestic medicinal plants, by hand and in small batches, certified in accordance with AT-BIO-501. My annual turnover is around EUR 13.000, and my products cost between EUR 7.9 and EUR 34. I have no employees.
Filed in German · English published by the European Commission
Ladies and gentlemen, I am pleased that the Packaging Ordinance is intended to prevent waste and to do something for the environment. But the Packaging Ordinance in its current form goes beyond the objective, as you completely miss the reality.
Filed in German · English published by the European Commission
We support the objective of improving transparency and producer responsibility across the EU. However, the proposed system of national producer registers risks creating a disproportionate administrative and financial burden for businesses. Companies operating in several Member States may have to deal with different registration systems, reporting requirements and procedures in each country.
Ladies and gentlemen, as operators of small online sales, we would like to take this opportunity to draw attention to what we consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.
Filed in German · English published by the European Commission
As an individual small business, I see my future under threat. It is impossible for me to pay one agent per country, so I am forced to abandon sending my creations by parcel because of a lack of means. As a result of this new law, I therefore separate part of my income, including income in my own country, because I send too few parcels to make it profitable to pay an agent.
Filed in French · English published by the European Commission
In our company we produce handmade wigs, beards and silicone prosthetics. Our annual turnover is around 15.000 and, as a rule, the prices of our products range from EUR 15 to EUR 300. We sell our products both at trade fairs and through online shops.
Filed in German · English published by the European Commission
I run an Irish e-commerce business, retailing almost exclusively on eBay. The business has one employee - me! Whilst the new regulations are difficult to understand, the biggest difficulty is the question of scale and minimum scale of registration. My product is niche (2nd hand collectables) and approximately half of the EU countries I ship to have less than 10 orders per year.
I was born in the EU. I grew up in the EU. I still live in the EU. I own a one woman micro business based in the EU and do everything that comes with it all by myself. I create one of a kind, handmade, wearable art that I package in 100% recyclable, 0% plastic, partially recycled packages, and sent them to people all over the world throughout the past 7,5 years.
Good afternoon, as an operator of a small online shop, I see my existence at risk, as I rely on orders from abroad for my one-woman business. Nor can I simply pass on the costs incurred here for the five main countries to my customers, as this is no longer worthwhile for my customers. As a result, unless a micro-enterprise scheme is used, I can see that my business has not lasted for a long time.
Filed in German · English published by the European Commission
For many smaller companies, the current set-up is unstoppable. This affects not only the companies themselves, but also companies that rely on smaller suppliers and may even have concluded framework contracts. It is unacceptable that this law completely breaks down the basic idea of the EU. The free trade area has been ad absurd.
Filed in German · English published by the European Commission
Having ran my small business since 2012 with very few issues shipping into the EU the new PPWR regulations are going to finish off any chance of shipping to customers in Europe. I am one single person running a small business from home, a business that has paid my bills for the last 14 years, turnover is diminishing due to more and more fees being thrown at small business owners that cannot be absorbed other than…
This new law is a crucial point for my little business. I sell vintage clothing during 15 years. The last year my business went down the hill by many reasons, including the whole economical situation, inflation, new shipping regulations to ship to the United states as well, I found myself with many debts to URRSAF, that I can not pay, I hardly pay my living.
Ladies and gentlemen, the idea for the EU is that everything should be made uniform and, above all, simpler. At present, it is exactly the opposite: As a small business with an online shop for very specific custom-made products, I need 26 individual authorised representatives and 27 different packaging licences.
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 an aspect of the planned implementation of the PPWR producer register which, in my view, can have significant practical and economic implications, in particular for small and medium-sized enterprises: the obligation to appoint an authorised representative for the extended producer responsibility in the case of…
Filed in German · English published by the European Commission
Ladies and gentlemen, as micro-entrepreneurs and online traders, I have been monitoring for several years with increasing concern how the regulatory and administrative requirements for small businesses trading cross-border within the EU are constantly increasing. However, I consider the new requirements of the EU Packaging Regulation to be the culmination of this failure so far.
Filed in German · English published by the European Commission
Ladies and gentlemen, I sell online as a sole trader. The sale takes place both within Germany and in almost all EU countries. However, the volume differs significantly, with a large focus within Germany. Sales to other EU countries amount to a small number of letters and/or parcels per year.
Filed in German · English published by the European Commission
Ladies and gentlemen, I operate a small handmade business in Germany and sell mainly through my online shop. I send an average of 40 packages per year to mainly six other EU countries. My turnover from these countries ranges from EUR 1900 to 2100. I would probably have to pay EUR 895 per year to register and appoint representatives in these countries.
Filed in German · English published by the European Commission
Small traders, online shops and importers are disadvantaged by the PPWR. This Regulation effectively abolishes the internal market and promotes only large companies. I strongly support the intention to make packaging materials more environmentally friendly and to save resources.
Filed in German · English published by the European Commission
As small e-commerce, we would like to comment on the obligation to appoint an authorised representative for EPR in cross-border sales. We sell in a small sector as a small family business without a legal department but with the ambition to abide by the law. The PPWR poses significant problems here: However, we often sell only a few parcels per year to many different EU countries.
Filed in German · English published by the European Commission
Ladies and gentlemen, we run a small business [industry, country] and would like to raise three issues that put a particular burden on us in the implementation of PPWR: No minimum threshold for the obligation to act as an authorised representative: Even a single consignment to another EU Member State requires a paid agent to be appointed in the destination country, regardless of how small the turnover there is.
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
This proposal is ridiculous for ALL small businesses across the EU - I have no employees and post very little (due to the Trump admin killing my USA trade and La Poste refusing to send small packages to the USA indefinitely. I cannot guess where my next client may live, I cannot afford to register in every single country - the cost is prohibitive and the administration is as well.
Ladies and gentlemen, as small enterprises [industry, country], we would like to draw your attention to the following problems in the implementation of the PPWR: 1. No de minimis limit for the obligation to appoint a representative: Even a single package to another EU Member State triggers the obligation to appoint a paid agent there, irrespective of the actual turnover.
Filed in German · English published by the European Commission
Ladies and gentlemen, as a result of the EU Packaging Regulation, which entered into force on 12 August 2026, we, a stationary and online specialist watch shop, lose approximately 40-60 % of our turnover in the short term. We are not able to register and provide assistance in individual EU countries in terms of staff and costs.
Filed in German · English published by the European Commission
I sell IT hardware to EU countries worth approximately 5001,000 per month (Id need to calculate the exact figure)all via eBay. Over the last few years, Ive shipped to virtually every EU country, though the frequency varies by destination. I generally reuse the plastic packaging from my suppliers, but I could switch to using exclusively paper or cardboard packaging for EU shipments in the future.
The act feels like it was made with money in mind above all else considering how much it costs to apply for each individual country. There should be something like an annual payment of very low cost for micro businesses who don't send out much packaging. Not hundreds - going into thousands - no matter the size of your business.The stress of this new act is far too much.
For micro-enterprises, whose turnover is made up partly of individual consignments to different EU countries, it is equivalent to a sales ban that a separate appointment of an authorised representative and sometimes very high payments are now required in each EU country in order to send even a single parcel to that country via a sales platform.
Filed in German · English published by the European Commission
The company shares the environmental objectives of Regulation (EU) 2025/40 (PPWR). However, the way the implementation is currently unfolding in particular the fragmentation of producer registration and documentation duties across 27 Member States generates a level of administrative burden that is disproportionate to its environmental benefit.
Ladies and gentlemen, I operate a small online shop and would like to tell you about a point from the planned implementation of the PPWR which is of great concern to me in practical application: the obligation to appoint an authorised representative for the extended producer responsibility in the respective target country for cross-border sales.
Filed in German · English published by the European Commission
While I'm very supportive of using recycled or recyclable packaging, I'm an extremely small business (non profit) that sends less than 50 orders abroad per year, so extra costs and admin are just completely impossible for me both financially and work load wise. There's no one employed by the non profit, just one freelancer who works a few days a month.
For a newly started small business like mine, these new packaging requirements could have a serious impact on my ability to grow and sell to customers across the EU. Every additional registration, fee and administrative requirement creates a significant financial and bureaucratic burden when you are operating with very small quantities and limited revenue.
We are a German company that develops and manufactures electronic components for the B2B market; we are classified as an SME. We sell our products worldwide, but with a particular focus on the EU. The new Packaging and Packaging Waste Regulation (PPWR) imposes a massive administrative burden on us.
While the intention behind these regulations reducing packaging waste and encouraging more sustainable practices is admirable, the current one-size-fits-all approach is completely disproportionate and risks seriously harming small and micro businesses. Many small, artisan businesses are not the source of the packaging waste problem.
Ladies and gentlemen, as an operator of growing online trade, I would like to draw your attention to what we consider to be a critical point in the implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the Extended Producer Responsibility (EHR) in the case of cross-border sales. For us, selling abroad in the EU was an essential building block of our business.
Filed in German · English published by the European Commission
Ladies and gentlemen, the planned implementation of the PPWR register of producers, in particular the obligation to appoint an authorised representative for extended producer responsibility in cross-border sales, contradicts everything that a united Europe should stand for. If it is easier and cheaper for a small business in an EU country to export to a non-EU country, the EU becomes absurd.
Filed in German · English published by the European Commission
Ladies and gentlemen, as the operator of a small online trading company, I would like to take this opportunity to draw your attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.
Filed in German · English published by the European Commission
We fully support the objective of reducing packaging waste and strengthening producer responsibility, especially given the enormous volume of packaging generated by large e-commerce companies. However, the proposed registration and reporting requirements risk becoming disproportionately burdensome for microbusinesses.
Dear Sir/Madam, Thank you for giving small businesses the opportunity to comment on the PPWR rule. I have a turnover of around 10.000 a year from my products. On average, I send 25 parcels per year to neighbouring countries. Searching for and paying for a representative in each case far exceeds the budget and I consider it to be absolutely disproportionate.
Filed in German · English published by the European Commission
Ladies and gentlemen, as a small business, we must draw your attention to what I consider to be particularly critical points in the implementation of the PPWR: — Obligation to appoint an authorised representative for extended producer responsibility in the case of cross-border sales – Declaration of conformity must be drawn up in the languages of the Member State(s) to which the packaged products are delivered – In…
Filed in German · English published by the European Commission
Unfortunately, we have now had to stop sending event tickets and suitable merchandising articles to the EU countries, to the detriment of EU citizens, as we do not have authorised representatives in other EU countries and it is not currently economically and bureaucratically possible to present this. Very bad for the idea of a big market in the EU!
Filed in German · English published by the European Commission
I am 9 years into running my small business, I have navigated many hurdles along the way. The PPWR is the only one that is so unreasonable, I have chosen NOT to navigate it in all countries, I will simply withdraw the sale of goods there. What happened to encouraging businesses to grow?
I operate a letter shop in Erfurt under mailing pressure24.de In addition to advertising mail, I occasionally send goods such as individual printed matter. From now on, even in the case of small quantities (e.g. an order with a value of 85.00 from Austria), we will have to make a cautious effort to supply a customer. Registration for Austria costs from 295,00 onwards – this is disproportionate to the revenue.
Filed in German · English published by the European Commission
these new regulations are obscene to micro-businesses and new startups like myself. I believe this system would benefit by being tiered, including a minimum threshold. many small business owners care deeply about their packaging and choosing eco-friendly materials.
Ladies and gentlemen, I am writing to the European Commission because, as a solo self-employed person or micro-enterprise, I am directly affected by the new rules on packaging and packaging waste. I send only a comparatively small number of parcels to other EU Member States. Nevertheless, I face registrations, notifications, fees and other requirements.
Filed in German · English published by the European Commission
As a small German e-commerce company, we sell our products to customers across the EU. Requiring us to register, report packaging volumes and potentially appoint representatives separately in every Member State creates disproportionate bureaucracy and costs. Our bigger (international) competitors (e.g. from the US) get a clear advantage as they can cope easily with the new impediments and rules.
We are a small business and supply the whole world. Now we had to stop shipping to the EU. However, we must not be allowed to supply the entire world to our neighbouring countries, as an authorised representative does not expect to be economically viable for 10-20 parcels a year. How to make such a decision? Why is there no small flat rate for micro-quantities?
Filed in German · English published by the European Commission
Ladies and gentlemen, as the operator of 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 planned obligation of authorised representatives for extended producer responsibility disproportionately affects small traders in cross-border sales through separate contracts, fees and reporting channels per destination country. Our Consequences: we no longer supply end-users in EU markets. Fixed costs per country act as a market entry threshold and hinder/prevent the European single market for small traders.
Filed in German · English published by the European Commission
How can this be adopted? They destroy hundreds to thousands of small businesses, including myself, with a single rule. The single market has once been the EU’s flagship and now it is no longer possible to participate as a small business. One could call it the enshittification of the EU.
Filed in German · English published by the European Commission
Hello, this new packaging regulations is causing unprecedented disruption to free trade in EU . As an owner of micro business, as many other small companies, I will not be able to continue shipping my handcrafted items outside of my country.
Ladies and gentlemen, as the operator of a small online shop, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.
Filed in German · English published by the European Commission
I am writing as the owner of a UK micro-business that has previously sold products to customers throughout the European Union. I fully support the environmental aims of the Packaging and Packaging Waste Regulation.
Dear Members of the European Parliament, I am writing about the new Extended Producer Responsibility (EPR) rules coming into effect on 12 August. I fully understand the goal: reducing unnecessary packaging and improving recycling. My concern is the disproportionate burden these rules place on very small businesses. I run Liquid Disco, a one-person creative business that is both my dream and my only source of income.
As a small online trader, I also sell my products in several EU Member States. The obligation to appoint an authorised representative for each country generates significant running costs and additional administrative burden. Especially in lower-turnover countries, these costs are disproportionate to the revenues generated there.
Filed in German · English published by the European Commission
As a medium-sized industrial supplier, we are already working intensively on the practical implementation of the PPWR and the development of corresponding packaging data. In particular, the division of responsibilities between the manufacturer and the EPR producer, the multiplicity of different packaging variants and nationally differing registration and reporting requirements require considerable clarification.
Filed in German · English published by the European Commission
I understand that Europe has not enough money to support refugees, the war in Ukraine and other fertilisers, but this is already too bad. I am a taxable person for VAT and I pay all taxes fairly, but this is already too much! As a small businessman, I turn up to 20000 a year and cannot afford to pay this squeeze-out fee.
Filed in Latvian · English published by the European Commission
I am the owner of a U.S.-based micro-business producing handmade jewelry, and I am writing as a directly affected small business owner. I support the European Unions objective of reducing packaging waste and promoting greater environmental responsibility.
While the idea behind this is good on paper, in practice this will kill every micro business shipping internationally in the EU. It is next to impossible to manage registrations for 27 separate countries as a one-man business, and it is also completely economically unfeasible if you are only shipping a small amount of parcels annually. Please consider adding exemptions for small/micro businesses.
While I wholeheartedly agree with the overarching purpose of the initiative - plastic waste is a curse and should be eliminated - the process around this is completely unworkable for micro and small businesses. I do think micro and small businesses should look to use sustainable and minimal packaging but the true culprits in the waste creation problem are large companies such as coca cola not one person micro…
The objectives of the EU Packaging Regulation to reduce packaging waste, conserve resources and promote the reuse of packaging are strongly welcomed. However, I consider the implementation currently envisaged to be disproportionate for micro-enterprises and one-person enterprises, impractical and unlikely to be acceptable in this form.
Filed in German · English published by the European Commission
I am a tiny one-woman micro business. I have been running my jewellery online store for five years in Germany. I try to minimise my impact on the environment in every possible way. I only use recyclable cardboard packaging, and very minimally too.
I strongly support the EUs goal of reducing packaging waste and protecting the environment. However, I am deeply concerned about the impact that the implementation of PPWR and national EPR requirements will have on micro-businesses and start-ups selling small quantities across EU borders.
I represent a Portuguese micro-business that designs and manufactures dog accessories in-house and sells directly to consumers across the EU. We support the environmental objectives of the PPWR and the principle that producers should contribute to the management of the packaging waste they generate. We already aim to minimise packaging and use responsible materials.
Hello, unfortunately, the basic idea of the EU is that the Regulation has completely failed. SMEs can only give up. The first thinkers of an open market, Robert Schuman, Konrad Adenauer, Jean Monnet, etc., were keen to strengthen the idea. Modern politicians such as François Mitterrand, Helmut Kohl and Jacques Delors then perfected it.
Filed in German · English published by the European Commission
s a very small EU-based business selling handmade products online, I fully support the objective of harmonising Extended Producer Responsibility (EPR) schemes across EU Member States. However, the current situation can place a disproportionate administrative and financial burden on micro-businesses that make only occasional cross-border sales.
Ladies and gentlemen, as the operator of a small engraving workshop with an online shop in Germany in the countryside, I would like to take this opportunity to draw attention to what I consider to be two particularly critical points in the planned implementation of the PPWR producer registers: (1) the obligation to appoint an authorised representative for extended producer responsibility in the case of cross-border…
Filed in German · English published by the European Commission
Soy responsable de una pequeña empresa familiar en España que vende principalmente a clientes particulares. Apoyo plenamente el objetivo de reducir los residuos de envases y fomentar un sistema más sostenible. Sin embargo, la obligación de registrarse y cumplir diferentes sistemas de responsabilidad ampliada del productor (EPR) en cada Estado miembro supone una carga administrativa y económica desproporcionada para…
To whom it may concern, I run Tama Spa & Repair, a micro-enterprise based in Germany. I design and manufacture small electronic accessories for Tamagotchi and similar virtual pets and offer specialist repairs. I aim to make my own products repairable, publish schematics where possible, reuse packaging and avoid unnecessary plastic.
If a small enterprise sends a few parcels per month to Belgium, this is not possible. The costs are then much higher than what the profit on sun packet can be. The big boys, bull, joke amp, etc., will have no trouble with this. This is detrimental to small businesses.
Filed in Dutch · English published by the European Commission
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.
