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

PPWR urgent need for a micro and small business exemption from national packaging EPR registration I am writing as a micro-business owner in Estonia who designs and makes jewelry and sells directly to consumers through an online shop.

The new PPWR rules are catastrophic for small businesses. How on Earth can we be expected to comply with such complicated and costly regulations to abide by? Did anyone even consider small businesses? It's hard enough as it is, trying to navigate the various VAT rules (designed with Amazon in mind in singularity), US tarrifs and individual marketplace rules, and now this added on top!

This regulation is creating a market where only the giants can afford to remain. Large corporations have the money, legal teams and lobbying power to absorb the administrative burden. Small businesses do not have 20,000+ per year to register separately across EU countries, appoint representatives and manage compliance in every Member State where they might deliver even a single parcel.

I am a ceramist and craftsman, and the vast majority of my turnover is sold directly in France. However, he married to sell abroad, particularly at a distance, by sending my creations by post. I fully understand the purpose of the European PPWR rules and I am fully in favour of making a greater contribution to the protection of the environment and better management of packaging.

Filed in French · English published by the European Commission

Dear reader, rulemaker, I have heavy concerns on how this regulation is being carried out and how heavy the effect is on especially micro businesses. Myself, a small independent retailer in textile garments, am already receiving messages from the independent makers I work with from outside the EU that they don't understand what this setup is.

I strongly oppose the planned implementation and the increasing requirements of the Packaging and Packaging Waste Regulation (PPWR) in its current form. While I fully support the goal of reducing packaging waste and promoting recycling, I believe the PPWR goes too far and does not sufficiently take the reality of small and medium-sized enterprises into account.

I own a micro-business that sells online in the majority of the member states. I have spent the whole day trying to register to the PRO's of each member state I sell and it is a nightmare. Many do not have translation or are poorly translated. In multiple of them there is no way to register immediately, you have to contact them via email. Some are on holiday, some do not work.

Ladies and gentlemen, we are a small online trader, but the exclusive general importer of non-competition medical protective masks for pets. We are actually obliged by the manufacturer to supply the whole EU. In addition to Germany, our main market is Austria, Italy and France. Demand from other EU countries ranges from 0-5 sales per year due to slow market development.

Filed in German · English published by the European Commission

Dear EU Commission and Dear members of the EU parliament ! Much has been written on yearly costs for obligatory EPR representatives for each separate EU country. What embarrasses me is that it takes thousands of Euros before we can participate in each separate national market. Its disproportionate. Bureaucracy costs outweigh recycling costs for a small company by far.

It is made impossible for a small enterprise to continue to exist. We urgently need a central body with a de minimis threshold, otherwise the new regulation will put an end to some of the small and medium-sized enterprises. And small and medium-sized enterprises are responsible for this country (still).

Filed in German · English published by the European Commission

As the owner of a small e-commerce business, we support the environmental objectives of the European Packaging Regulation (PPWR) and the Packaging Law Implementing Act (VerpackDG). We need to reduce packaging waste and close material loops.

Filed in German · English published by the European Commission

Dear EU Regulator, I'm the responsible for a e-commerce business in Canada, that sells mainly to Canadians and people in the US. However, we have some very loyal clients in Europe from different countries who order from us for about 40,000 euro per year. It's not a crucial part of our business, but we've been happily serving those clients in the past 10 years.

An incredibly bad and ill-thought-out regulation that benefits only the big ones and by putting the small ones at a fair disadvantage, or even destroying them, helps the big to achieve even more turnover and more packaging. I have been a self-employed artist for over 18 years. I work with love for people and the environment and I send them worldwide.

Filed in German · English published by the European Commission

Subject: Feedback on the PPWR Massive Disadvantage of small businesses due to the obligation to have an authorised representative and unclear definition of the manufacturerDear Sir/Madam, as owner of a small online trading company, I expressly support the environmental objectives of the new EU Packaging Regulation (PPWR).

Filed in German · English published by the European Commission

We are now seriously wondering how such a regulation could be adopted at European level in the first place. How can we create such an absurd bureaucratic monster and at the same time talk about strengthening the European single market?

Filed in German · English published by the European Commission

I run a micro business in Ireland that sells a few handmade products a year. I also sell games that I produced 10 years ago and am just selling slowly (maybe 5 or 10 a year). I us a lot of recycled packaging from packages I received. I don't import packaging or buy it. Amazon is asking me to provide all sorts of information that I can't comply with. I have email Repak (the Irish recyclier) and I have heard nothing.

Dringender Handlungsbedarf bei der PPWR Kleine Unternehmen ziehen sich aus dem EU-Binnenmarkt zurück ​Sehr geehrte Frau Kommissarin Roswall, ​ich wende mich kurz vor Anwendung der neuen Packaging and Packaging Waste Regulation (PPWR) mit großer Sorge an Sie. ​Das Ziel, Verpackungsabfälle zu reduzieren und Hersteller an Recyclingkosten zu beteiligen, unterstütze ich ausdrücklich.

Ladies and gentlemen, as the operator of a small 1 man 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 actual impact of this rule is dramatic: Small European traders and manufacturers are de facto excluded from the EU single market. Particularly in the case of highly specialised products, the national market is often too small. A small manufacturer or specialist dealer may have a turnover of between EUR 1,000 and EUR 3,000 per year in each EU country.

Filed in German · English published by the European Commission

To the European Commission and the Committee on Petitions:As a German citizen living and operating as a micro-entrepreneur based in Switzerland, I am writing to express grave concern regarding the practical enforcement of the Packaging and Packaging Waste Regulation (PPWR) and national Extended Producer Responsibility (EPR) requirements for cross-border e-commerce.While the environmental objectives of the PPWR are…

As a part of a small family business from Bulgaria that regularly sells products in Romania and Greece and want to expand further into the EU, this legislation makes it too expensive and hard. This law antithetical to how the EU as a economic entity should operate.

This law makes small businesses not viable while doing nothing to stem the massive packaging waste from the likes of Temu, Amazon & AliExpress. There needs to be a small business carve-out, a minimum threshold of sales to a country / total sales or an exemption for fully sustainable packaging. With every new law I see it's clear that the EU has been taken over by the corporations and lobbyists.

To whom it may concern. I fully support the goal of reducing packaging waste and making companies responsible for the waste they create. But I think the way this is being implemented risks creating another barrier for small companies trying to sell across the EU.

Ladies and gentlemen, I have run an online shop for 8 years on a secondary basis. I am a sole employee with a legal background. Since the introduction of EU packaging laws, I have had to stop shipping to an increasing number of EU countries, piece by piece, because of the various EU rules that each country interprets or implements differently.

Filed in German · English published by the European Commission

We are a small company with 5 employees and we depend on our online sales to survive during the winter months. We cannot afford to meed the requirements for packaging and packaging waste as compliance in all 27 member states would cost more than our turnover As a result we can no longer afford to ship to other EU countries We use less than 10kg of packaging a year and all of it is reused amazon or wine boxes This…

As a very small business just trying to get our footing, these new regulations will completely stop any dreams we may have of selling to other EU countries. We are already using doing everything we can to ship in the most sustainable packaging possible by reusing shipping boxes whenever possible and not including any plastic in our packaging aside from the tape used to seal the box...

There's no sense in any of this activity of yours. You're killing the operations of small businesses within the EU. Pure madness. On top of that, you'll lose VAT revenue when we small entrepreneurs stop sending packages within the EU area. You're idiots!

I am a small independent creator/business owner selling products across EU borders from Austria. The current EPR requirements create disproportionate costs, registration fees, and administrative burdens for micro-businesses that simply do not have the resources or infrastructure of large companies.

To whom it may concern, Many other respondents have already pointed out the insurmountable hurdle that the new EU PPWR poses to small (family, I should rather say) businesses across Europe, in regards to the requirement to register, often appoint a representative, and pay significant fees in every EU country even if only a few parcels would be sent there in a year.

The requirements of the PPWR impose a disproportionate administrative and financial burden on small and micro-enterprises shipping goods across borders within the European Union. We are a small business and so far we also send our products to customers in different EU Member States. However, sales in the individual countries are comparatively low.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the owner of a very small online shop, I would like to provide feedback on the PPWR. 1. I often reuse the packaging from suppliers and from my private household. For example, I use cut cartons of supermarket packaging and newsprint to package parcels.

Filed in German · English published by the European Commission

OPEN LETTER TO THE EUROPEAN COMMISSION AND EUROPEAN POLICYMAKERS Stop Making the Single Market Harder for SMEs We are not against protecting the environment. We are not against recycling. We are not against responsible packaging. We are against bureaucracy that is making it increasingly difficult for European SMEs to survive and compete.

Ladies and gentlemen, the scheme poses insurmountable obstacles for small traders like me and makes cross-border trade within the EU more difficult. About me: I am a self-employed author and artist, running a small shop offering signed books (including high-quality special editions) and painted images. My main source of income is the royalties I receive for my breadwinners via Amazon or my print-on-demand provider.

Filed in German · English published by the European Commission

I find the new packaging regulation completely immature. Attempts have been made to place packaging, parcel volumes, dispatching and recycling under a regulatory roof, with strict control requirements, at the expense of small businesses being able to send only a few parcels, making this unaffordable.

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 critical point in the 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. For small businesses, selling abroad in the EU has been an obvious step forward so far.

Filed in German · English published by the European Commission

Hi, the PPWR/PRE is absolutely terrible for micro enterprises like the one from me and my wife. Helping out with the recycling cost is something I can fully get behind, even if it is just for a couple kg per year, but having to appoint (and pay for!) an authorized representative for each EU country we ship to is a HUGE investment of both time and money that we just can't deal with.

I have just registered my small perfume brand, created one perfume, collect the feedbacks and prepare for CPSR. I do not sell anything yet, posting my samples for free to get to know if people like the fragrance. And I usually get good feedbacks and there are several people from different EU countries that would like to buy a full bottle. So they are waiting for the launch.

As a small startup, its impossible to register in every EU country separately. The administrative load and costs would kills my business. In the end it would result in less sales since I have to make a selection of which countries to sell to. I already use recycled materials in all my packaging and I have no issue reporting on this. I also make sure I dont send half empty packages to clients.

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

Filed in German · English published by the European Commission

I am a sole trader making handmade jewellery in Ireland. I employ no one. My total packaging placed on the market is approximately 40 kg per year across all EU markets combined, which is 0.4% of the ten-tonne threshold used in this draft. At my current volume it would take roughly 250 years to place ten tonnes of packaging on a single national market.

As a small business owner I can state with certainty that the implementation of this law makes no sense for small businesses that ship 20-30 parcels per year to all of the EU. The profit of my business for the past quarter from EU shipments is 180. This was for 5-6 parcels/sales.

Moin, PPWR was the last drop to overflow the barrel. As a small online trader, we cannot afford the fixed costs and expenses per EU country. We are still going to send from Germany to Austria, but we are reducing the offer and presumably stopping altogether because we cannot afford fees and expenses per country with so little turnover. EU only thinks of big companies and lobbyists, people have to capitulate.

Filed in German · English published by the European Commission

We do not agree with the current approach of maintaining separate national producer registers and EPR requirements in every EU Member State. As a Dutch SME selling products throughout the European Union, we fully support the objectives of recycling, waste reduction and producer responsibility.

As a micro-entrepreneur, I cannot afford to spend hundreds of euros per year and per EU country in order to be able to send goods there. The alternative of no longer supplying the countries concerned would mean for me an estimated drop in turnover of around 40 %. As a result, I would in future be dependent on State support due to the additional burdens imposed by the new Regulation.

Filed in German · English published by the European Commission

After 15 years of insolvent guarantees for the disposal of ‘Electrical Devices’ (EAR) amounting to EUR 5 over 20 years, we have reported 0.0001 tonnes per month and wasted around EUR 400 per year in fees, we are now following the EU’s next environmental warfare. We sell around EUR 15.000 per year to the EU and will now pay EUR 15.000 per year for registration fees and proxies for PPWR.

Filed in German · English published by the European Commission

Ok, so this law would make sense if it was imposed in acceptable terms and directed to those who ship above a certain threshold. This is obviously a law that will end small business and creators. I consider that it runs counter to the principle upheld by the European Union that states that the EU Internal Market operates as a single market; that it ensures the free movement of goods, services, capital, and people…

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 concept of this law is a complete destruction of any small business in Europe. It can not remain like it currently is. There are thousands of small business with only small amounts of deliveries to other EU countries. Bureaucracy and costs will destroy them, they will leave to Ex-EU countries where possible or just instantly stop EU business as we did. If THAT is EU I don't want it and I don't need it.

The proposed packaging and packaging-waste requirements risk becoming a serious burden for small businesses across the EU. For a large company, registering in multiple countries, monitoring different national requirements, maintaining records, filing reports and managing compliance may simply be another administrative function.

Ladies and gentlemen, as the operator of a small shop for children’s furniture for disabled children and young people, 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…

Filed in German · English published by the European Commission

What this legislation has done is essentially shut down small business owners. Businesses that send out maybe 3 packages a month to one or two countries. Businesses that barely make a profit but do it out of love, and sharing their craft. But now have to register with each country, often needed an advisor for each location.

I understand the need for the regulation of packaging placed into EU countries, however as a micro online business, myself and my husband, the proposal will have a negative impact. We are self employed and sell Vintage products, so we are supporting the circular economy. All our packaging is reused and we use no plastic. We have been LUCID compliant since opening our online store, a cost of 49 per year.

As the owner (49 years) of a family farm with a long tradition in the sector of spreadable instruments (violine, cello) and accessories, I am working in the fourth generation. After my parents withdrew from the farm, I currently have 1 full-time employee. We have an annual turnover of around 1 million. As we are positioned as wholesalers, our customers are predominantly commercial resellers.

Filed in German · English published by the European Commission

The new EPR rules are destroying the single market and causing considerable financial and cultural damage while giving multinational corporates an incomprehensible advantage. The administrative requirements and annual basic fees do not reflect sales volume or business size.

I own a small German fair fashion company with brick-and-mortar retail and online sales. We produce exclusively in Europe and also purchase our shipping packaging exclusively from European suppliers. I strongly support the PPWR’s objectives of reducing packaging waste, strengthening the circular economy and making producers more accountable.

Filed in German · English published by the European Commission

Ladies and gentlemen, I would like to express my strong support for this draft, while drawing attention to the specific situation of the smallest companies. I own a small ceramics company in Austria. As a one-woman company, I am solely responsible for production, as well as for all administrative and legal tasks.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a trader who has made use of the small traders scheme and wishes to send original packaged toys from the 1980s and 1990s to loved ones and collectors throughout the EU and the world, unfortunately I do not understand at all why the new Packaging Ordinance (PPWR) does not exempt these small traders. 300 per country per year + additional red tape due to registrations, etc.

Filed in German · English published by the European Commission

This is yet another proof of the extremely rotten and inefficient bureaucracy in Brussels. An elementary solution like collecting a recycling fee, calculating it in the price of transport (transport companies raise the price for the service and pay the necessary amount to the local budget). But the bureaucrats clearly do not want business to have it easy.

I do not think the new PPWR is inclusive; as always, small businesses are overlooked. The costs a micro-business faces are truly prohibitive relative to the amount of packaging it produces. This new regulation will drive many small businesses like mine, which are already committed to reducing waste into bankruptcy.

However, as an operator of a small specialist drinking water filter shop in Berlin, in addition to running customers, we have only 0-5 parcels per country and per year for online customers across Europe, with total turnover in the EU below 10.000! Nevertheless, this turnover helps us to survive. The cost of registration and authorised representatives for 27 EU countries is around 6000.

Filed in German · English published by the European Commission

Absolutely ridiculous law for small businesses that already struggle to keep afloat. We already pay enough in taxes to cover the costs of recycling- something that the GOVERNMENT should be doing not our responsibility. Instead give us incentive to use sustainable packaging and other a tax cut or money back. To pay upfront for something we may never use or use one time a year is cutting us off at the legs.

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 an absolutely 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 the sole proprietor of a very small lego reseller business in Belgium, the costs associated with maintaining EPR registration in every EU country (+/- 5000-7000EUR cost while my yearly sales are +/- 25.000 EUR / Year ) that I sell to will effectively price me out of being able to continue to sell my goods to EU customers.

As the sole proprietor of a very small leather craft business in Ireland, the costs associated with maintaining EPR registration in every EU country that I sell to will effectively price me out of being able to continue to sell my goods to EU customers. I may only sell one or 2 pieces a year to customers in any given country.

Small business will already have some excemption hopefully from the AR rules, that is my main concern -> It must remain viable for a any one man show to operate in more than their home country, even if its just 1 or 2 sales annually. Another huge missed opportunity lies in the re-use of packaging materials however.

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

EU - PLEASE ACT FAST! For me EU stands for free movement and free trade, which in my eyes a beautiful. EU does the total opposit right now. Im running a webbshop with my sister and we have 8 employees. We ship from Sweden and our most important market is the EU. 90% of ours sales is outside Sweden and without the EU market we will have to shut down immediately. We sell B2C only.

The PPWR makes intra-EU trade unnecessarily complicated and expensive for small and medium-sized enterprises. Instead of strengthening the European single market, SMEs are being overburdened with ever-increasing requirements, registrations and bureaucratic obligations. Many small traders cannot afford this effort either financially or in terms of staff.

Filed in German · English published by the European Commission

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

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.

However, when implementing the rules on cross-border sales, I see a significant problem for micro-enterprises. For example, a small vineyard can send only a few parcels per year to a specific EU Member State. Nevertheless, registration, reporting and, where applicable, authorised representatives may be required under the respective national rules.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as micro-enterprises concerned, I would like to draw your attention to what I consider to be a problematic consequence of the new extended producer responsibility schemes under the PPWR. As a sole trader, I carry out a small online sale of interlocking building blocks. My sales are mostly individual building blocks or spare parts worth a few euros.

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

As an operator of a small German online shop, I also sell cross-border within the EU. The PPWR obligation to appoint an authorised representative for each individual EU target country and to make separate registrations, fees and notifications is disproportionate for small businesses. Fixed costs are incurred regardless of whether a country sells only a few or several hundred items per year.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Hello Reiter, small businesses will be burdened with red tape and costs that jeopardise the continuity of operations or restrict customers. My 14-year-old business, which I run as a solo self-employed person, has an annual turnover of around 80000. This is enough to live. I occupied an old craft as a leather for medieval, larvae and costume equipment. I send around 100 parcels a year abroad in the EU. No longer.

Filed in German · English published by the European Commission

Good afternoon, for years I have been sending my goods completely in paper. I have only smaller orders of up to EUR 50. As a small entrepreneur, I cannot pay these additional costs. It is all the more annoying that Germany is flooded every day with Chinese orders, which are always packed in plastic. Your regulations only empower Chinese traders and European small businesses. Is that your goal?

Filed in German · English published by the European Commission

I whole heartedly agree with the environmental aims of the EU packaging and waste rules. As a business we have been using recyclable and environmentally friendly packaging for years. However, my small business doesn't have the time, or finances available to register in every country.

PPWR for small traders. The time required is already indisputable, then the costs will also be incurred. Approx. 10 – waste collection charges with tens of thousands! of fees for authorised representatives, so you can only shake your head, which is a fee waiver for a few kilos of cardboard. I have already been downsized because of PPWR and my small business is being cut back. I can also give up full self-employment.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

The PPWR rule for small companies must be declined. A small company that sells only few packets per month will not be able to continue the selling as the fees are too big. All companies that sell under 250 000 yearly must be kept aside from this rule.

The PPWR, in its current form, risks destroying the very European businesses that the European Union should be encouraging and protecting. How can the EU seriously promote entrepreneurship, competitiveness and the Single Market while creating a regulatory framework in which a European SME selling cross-border may face registration, compliance and representation costs in multiple Member States?

Ladies and gentlemen, the new rules applicable from 12.8.2026, which require an agent for each country and exclude de minimis thresholds, force me to stop shipping (plalately, historical postal history) to the EU.

Filed in German · English published by the European Commission

Hello, I am a small business owner. I sent around 500-600 packages a year. Half of them to my home country the other half spread out over Eu countries mostly. I used to celebrate having a sale from a country i didnt have before. Now i have to choose: loose around half my turnover or spent 75% of my turnover on fees and representatives to even be able to sell in the EU.

The new PPWR was likely to reduce packaging waste. This is also likely to happen because we small traders and craftsmen cannot afford to supply it to all EU countries. On the one hand, the costs of the authorised representative in each EU country and, on the other hand, the additional bureaucratic burden. For us one-person companies, this means ruin.

Filed in German · English published by the European Commission

The idea behind the regulation is good, but no company can pay a proxy in any EU country. Neither I nor any other trader will deliver goods within the EU. Conversely, I can no longer source from within the EU. This is increasingly destroying the EU’s idea. Solution suggested: A declaration of conformity in one’s own country should be sufficient. Authorities abroad can request any evidence from the consignor.

Filed in German · English published by the European Commission

As an independent online seller, the current implementation of the Packaging and Packaging Waste Regulation (PPWR) and Extended Producer Responsibility (EPR) is completely unviable for small-scale operations. This regulation fails to distinguish between multi-million euro corporations and small, independent handmade creators and vintage resellers worldwide who are already driving a sustainable global economy.

Dear Members of the European Parliament, ​I am writing to express my deepest concern regarding the trajectory of recent EU trade and environmental compliance legislationmost notably the implementation of the Packaging and Packaging Waste Regulation (PPWR) alongside fragmented Extended Producer Responsibility (EPR) requirements.

An investigation needs to be conducted into who is behind the extermination of small businesses... I haven't sold a thing since August 12th. Next month, there won't be money to pay for my daughter's university studies or other bills. The EU is going to drive us into bankruptcy...

I would like to extend my online sales to the whole of Europe again, but this chaos in the regulations is unacceptable! It is a barrier to competition to the detriment of very small providers like me. A single account for all EU countries would have to be enough? The EU is making life difficult and hindering business development in the free market

Filed in German · English published by the European Commission

Good morning, I don't want to use any prepared text and just copy and paste it here. We are a wine merchant selling small quantities of very and highly specialized wines produced throughout Europe and we sell them to customers throughout Europe. In many European countries we are the only one providing these wines. It is very hard to comply with all the regulations concerning excise and duties.

Prueba irrefutable de la mala gobernanza europea. Vivimos en una época en la que los países pobres o en vías de desarrollo recaudan impuestos a través de servicios de mensajería, y el gobierno europeo ha decidido imponer una carga insoportable a las pequeñas empresas vinculadas a intermediarios. Incluso la total antipatía de todos los ciudadanos europeos hacia el terror ambiental es sorprendente.

As a micro-entrepreneur running a small independent business (selling second-hand or flea-market goods), I wish to express my deep concern regarding the disproportionate impact of current rules and national producer registers associated with the PPWR.

Die Pflicht für einen lokalen Bevollmächtigten pro EU Land sprengt jedes Umsatzverhältnis. Wir mussten unseren EU-Versand stoppen, weil wir ihn uns schlichtweg nicht leisten können. Warum gibt es keine Bagatellgrenzen? Warum schnüren wir v.a.

Regulations like this will further destroy small European businesses. Large businesses including foreign ones like Temu, Shein etc can easily fill in the forms and pay the fees. But a small business like us is supposed to bear the same costs as a large business? This is ridiculous.

To the European Comission, PPWR Implementation is failing the SMEs the EU claims to protect. We are one of the businesses the EU champions in every speech about growth and entrepeneurship, yet I discovered a regulation carrying fines up to 200.000 through instagram posts from other small business owners, not through any official channel.

We are a showroom representing small sustainable fashion brands from around the world. We absolutely agree with sustainability but this proposed PPWR system does not protect small businesses it destroys them. Firstly, it should be explicitly banned for any EU country to charge a fee to register, making it easier for small brands to access the markets they've been selling to all along.

Dear ladies and gentlemen, thank you for the opportunity to give feedback to the new regulations that have been put forth. I totally understand the need for stricter rules on packaging in this world, and now within Europe. As companies like Amazon made their way into most EU countries, we started to receive massive boxes filled with plastic to send one single item.

Rückmeldung zum Entwurf des Durchführungsrechtsakts nach Artikel 44 Absatz 14 PPWR Sehr geehrte Damen und Herren, als Inhaberin eines kleinen Schweizer Unternehmens mit Direktversand an Endkunden in der EU begrüsse ich die Vereinheitlichung der Melde- und Registrierungsformate sowie das vereinfachte Format unterhalb von zehn Tonnen jährlich.

Ladies and gentlemen, I would like to inform you at the outset that it is hardly sustainable to send online within the EU. It would be highly desirable to have a central point at OSS for packaging costs. As there are no tariffs within the EU, countries are building barriers to protect their own market. Selling outside one’s own country is not becoming more uniform, but increasingly difficult and expensive.

Filed in German · English published by the European Commission

As a small independent manufacturer based in Germany, I fully support reducing packaging waste and taking responsibility for the packaging I use. However, having to register and comply separately in every EU country I ship to is simply not manageable for a micro-business like mine. I send only a handful of orders per year to many EU countries.

Se o objetivo deste regulamento é angariar fundos para a reciclagem, basta aumentar o custo do transporte. É evidente que o objetivo deste regulamento é servir os interesses comerciais de diversas empresas e intermediários. E as pequenas e médias empresas de toda a Europa têm sofrido com isso.

Ladies and gentlemen, I sell small online and make individual jewellery. So far, I have sold these individual items to the EU and also worldwide. As a small businessman, selling abroad in the EU is no longer affordable or threatens my existence due to the PPWR. I would have to appoint and pay plenipotentiaries for each country.

Filed in German · English published by the European Commission

As a very small niche web store for analogue cameras, we are disproportionately affected by the new PPWR rules. In practice, we risk having to completely stop selling to customers in other European countries. The main problem is that each country has its own registration procedures, rules, systems and competent authorities.

Filed in Dutch · English published by the European Commission

A catastrophic prerequisite for the expansion of my and many other small businesses. You do not know which countries will go to Meike goods and all countries make no financial sense to declare a flat-rate amount. The law is abolished or made widely available free of charge, at least through a free EU General Portal, in order to register waste. Please don't take us for granted!

Filed in German · English published by the European Commission

Although it makes sense overall, these rules are a legal bomb that has already pushed many small businesses across France and Europe to stop sending them across the various countries of the European Union. Many of us are unable to bear the financial burden of the EPR component of this regulation, of registration in each EU country, in addition to the need to have a legal representative in some of these countries…

Filed in French · English published by the European Commission

Ladies and gentlemen, I have been operating a small online retail business in Germany for over 20 years, selling craft materials and my own products. Customers from many European countries are in principle part of my market.

Filed in German · English published by the European Commission

I am a small independent business owner/creator selling handmade goods in Portugal, with the potential to sell across EU borders through online platforms. The current requirement to register separately for Extended Producer Responsibility (EPR) in each Member State, each with its own fees, forms, and administrative processes, makes cross-border selling within the EU single market impractical for a micro-entrepreneur…

PPWR. I understand that we cant have these massive amounts of packing. Sellers need to take responsibility for their waste. But please understand that the bureaucracy and expenses that follows will be the end of us small companies. We have enough on our plate.

Ladies and gentlemen, we operate a small family-run winehouse in Wesel with a specialised brick-and-mortar shop and complementary online sales. As a micro-enterprise, we would like to draw attention to an issue of great concern in the new EU Packaging Regulation: the obligation to appoint an authorised representative for extended producer responsibility in cross-border shipments within the EU.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a solo self-employed, internationally operating music label (since 2001, Lower Saxony), I am strongly affected by the authorised representative obligation under Article 45(3) of the PPWR both as a manufacturer of its own releases and as a distributor of third-party goods, since both roles are equally regarded as ‘producers’ in the case of direct dispatch to EU customers…

Filed in German · English published by the European Commission

Ladies and gentlemen, I run a small online shop for Asian cooking ingredients and recipes with asiastreetfood.com. As regards the planned implementation of the PPWR Producer Register, I would like to draw your attention to an issue that disproportionately affects small traders: the obligation to appoint an authorised representative for the extended producer responsibility in each destination country for cross-border…

Filed in German · English published by the European Commission

Ladies and gentlemen, since I am now ceasing to sell a regular part of my online trade, which is putting every quantity of customers in difficulty, I would like to allow you at least to take part in my tour. Background: I sell thread and handloom equipment online. An absolute niche market with a manageable share of customers. There are also correspondingly few suppliers, so we have so far supplied Europe-wide.

Filed in German · English published by the European Commission

As a business start-up, I am now confronted with the European PPWR/EPR regulations applicable from 12 August 2026. The rules and costs are the same for both large and small businesses. However, it is impossible for me, as a sole trader, to register me in each EU Member State, pay a fee, appoint a representative. I can only pause shipments to other EU countries until there is more clarity or simply stop them.

Filed in Dutch · English published by the European Commission

Ich betreibe als Einzelunternehmerin ein kleines Kunsthandwerksgeschäft und bin als deutsche bzw. EU-Bürgerin im Ausland tätig. Daher kann ich nur schwer nachvollziehen, wie ein derart komplexes und bürokratisches System entstehen konnte. Als Ein-Personen-Unternehmen werde ich schlichtweg nicht in der Lage sein, die umfangreichen Dokumentations- und Verwaltungsanforderungen für jedes einzelne Land zu erfüllen.

## 1. The design of the PPWR does not in any way match the ambitions for a simple EU internal market! ## 2. Why do we create a waste administration? Materials that can be recycled (paper, cardboard, glass, metal, plastic, etc. – and are collected separately in the EU countries) should be completely excluded from the Directive, as disposal companies already collect and sell these materials separately.

Filed in German · English published by the European Commission

Feedback on the EU EPR Initiative I strongly support the environmental objectives behind Extended Producer Responsibility (EPR). However, for companies operating across several EU countries, the current approach is unnecessarily fragmented, bureaucratic and expensive.

I would like to take this opportunity to draw your attention to what I consider to be a particularly critical point in the planned implementation of the PPWR Producer Register. the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

I am an artist and sole proprietor of my art business in the Netherlands. EPR compliance and bureaucratic requirements make it impossible for me to sell my artwork across EU borders. Putting this burden of compliance on individuals and small businesses makes zero sense, when it is the giant corporations that produce most of the waste and pollution, and who can easily absorb the costs of compliance, while individuals…

Ladies and gentlemen, the idea of reducing packaging waste is in itself a good idea, but if even a manufacturer such as REPACK decides to leave the shop with its shipping bags on the basis of new directives, everyone with a spark of common sense doubts the meaning of a new regulation which only creates new jobs for notaries or the like and imposes even more costs on the economy.

Filed in German · English published by the European Commission

Comments ON THE PROJECT FOR A COMMISSION IMPLEMENTING REGULATION (EU) ESTABLISHING RULES FOR THE IMPLEMENTATION OF Regulation (EU) 2025/40 ON INSCRIPTION AND INFORMATION SUPPORT TO THE ASINCA PRODUCT REGISTER shares the objectives of harmonisation, traceability and effective compliance with extended producer responsibility that inspire the project.

Filed in Spanish · 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 idea of better monitoring how and where packs of materials are used in shipping is logical and good in its essence. But this is very hard for small businesses who previously sold individual goods to several different countries over a year.

Filed in Swedish · English published by the European Commission

Dear Sir/Madam, We operate a small online shop specialising in the supply of spare parts in the vintage sector. We support the European Union’s objective of reducing and preventing packaging waste. In our opinion, the implementation of the PPWR for small businesses cannot be financed by the 10-20 packages per EU country.

Filed in German · English published by the European Commission

I am a self-employed Spanish businesswoman selling my handcrafted products both within and outside the European Union. My turnover is small. My income is just enough to live on. How is it possible that there is no exemption for micro-enterprises or self-employed individuals with low turnover? How can my activity and obligations be compared to those of large companies?

I support the goal of reducing packaging waste, but the rules need to be proportionate. For a small business selling across the EU, having only a few customers in another Member State can still mean registration, reporting and other compliance costs in that country. This creates a problem because the administrative burden does not always match the actual amount of packaging waste created.

The new regulations are, in general, a good idea, but poorly executed. As a small EU based business owner, I will now have to stop exporting, as the costs of an authorised representative in each company isnt economically viable due to low sales volumes spread across most EU countries. A bill of circa 20,000 per year for this means that sales to other EU countries will not be profitable.

Hello, The new law is killing the free market of European countries. This is giving a very bad example, so that each country will put whatever tariffs against fellow european countries. European Union promises free market. Small businesses cannot pay hundreds and thousands of euros just to ship to Germany, France, Spain etc.We had to face the huge USA tariffs, now this, what happens next, total chaos?

Ladies and gentlemen, with this Regulation you have practically rendered trade in the EU internal market absurd/impossible for small businesses. Unfortunately, it is disproportionate to the costs and effort involved to join this bureaucratic scourge, even though the intention behind it – to prevent packaging waste – is perfectly understandable. We have drawn our conclusions and completely stopped internal trade.

Filed in German · English published by the European Commission

This law is absolutely horrendous for small businesses. I am a doll artist. I was just about to start a business selling my dolls online. I would make only a few sales per year at first, as is the nature of that niche. The profit per sale would already be extremely low and would certainly not cover the cost or registering in my own country, let alone every other EU country.

I strongly support the European Union’s objective to reduce packaging waste, promote recycling and strengthen producer responsibility. For many years I have operated a small, owner-run German online shop with specialised niche products. In total, my company only places around 120 kg of packaging on the market per year. Around 150 consignments a year go abroad, some of them to Switzerland.

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 key criticisms of the planned PPWR implementation, in particular the obligation to have an authorised representative in the case of cross-border sales. As a small businessman, selling abroad in the EU has been an obvious step forward so far.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of an online shop in Germany, 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 under extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop for Glitzer, 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 support the objectives of reducing packaging waste and ensuring producer responsibility. However, the proposed system is disproportionate and risks becoming a serious barrier to entrepreneurship in the EU. In my view, micro-enterprises and small businesses should be exempt from these registration and reporting obligations altogether.

As a micro-enterprise and independent artisan producing hand-made, limited-run goods (including fragile botanical items, glass diffusers, and ritual kits), I am writing to express grave concerns regarding the disproportionate impact of the newly applied Packaging and Packaging Waste Regulation (PPWR).

This law makes it economically unviable for micro and small businesses based outside of the EU to sell to European customers. The cost and the complexity required to comply with this regulation don't match the current or potential sales volume a small business generates in the European market.

Dear Commision, my feedback for the regulation and especialy the 27 different processes (costing me roughly 20.000 Eur/year) is the death for my home business I now hate the EU and as we say in my country: "Eich homs ja gewaltig ins Hirn gschissen" which means that for the rest of my life I will vote only for parties destroying that beaurocrati monster the EU has grown into.

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop for design objects (farobjects.de), 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 PPWR, as a company with 22 employees, we face very serious challenges. So far, we send only a few consignments per year with a volume of < EUR 1000 per year to many EU countries. This simply becomes unprofitable as a result of the licensing obligation. We also buy goods from outside the EU. As we do not purchase large quantities, we will not be able to enforce compliance obligations vis-à-vis our suppliers.

Filed in German · English published by the European Commission

For me, this is the end of the EU’s single market and also for small and medium-sized enterprises: Why do we stop EU transit? The free movement of goods in Europe now exists only on paper. Cross-border shipping has become a bureaucratic trap for small and medium-sized online traders. The reality: Red tape kills the single market.

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 extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

HEGA GmbH · Am Mittelfelde 45 · 30519 Hannover EU-Kommission Hannover, den 14.08.2026 Beschwerde PPWR Sehr geehrte Damen und Herren, als Betreiber eines kleinen Online-Handels möchte ich die Gelegenheit nutzen, auf einen aus meiner Sicht besonders kritischen Punkt der geplanten Umsetzung der PPWRHerstellerregister hinzuweisen: die Pflicht zur Bestellung eines Bevollmächtigten für die erweiterte…

Filed in German · English published by the European Commission

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

I am a small online retailer of model construction products in Germany. My share of turnover for deliveries to the EU is 15 % of my total turnover for 100 to 150 parcels per year. Registering in each EU country is far too expensive and burdensome for me.

Filed in German · English published by the European Commission

In principle, we welcome the European Union’s objective of reducing packaging waste and creating uniform environmental standards throughout Europe. However, the specific design of the new requirements leads to considerable practical and financial burdens, in particular for small and medium-sized enterprises. Our company also sends goods from Germany to end customers in other EU Member States.

Filed in German · English published by the European Commission

As one of the founders of AQL & NAFS, a small two-person business based in UK/Germany I am deeply concerned about the impact these new regulations will have on small-businesses like ours. We founded AQL & NAFS with a very specific mission: to work with women and artisans in Afghanistan, provide them with paid work and give their incredible craftsmanship access to a global audience.

At Gartenfrische Kosmetik (www.gartenfrische-kosmetik.at), we built our micro-business on a simple, genuine promise: clean, fresh, natural cosmetics created with passion right here in Austria. We are micro-scale, local, and as close to nature as it gets. And yet, we are currently facing a terrifying reality: We may have to close our doors for good. Not because our customers don't love our products.

I am a small independent business owner based in Portugal, selling handmade ceramic decorative products directly to consumers across Europe through an online shop. My business is very small compared with the companies that these regulations are primarily intended to regulate. I sell relatively small quantities, often individual pieces, to customers in different European countries.

I am a solo entrepreneur based in the UK, with customers in a few EU countries. I completely support the concept of this legislation and the need to reduce packaging waste and to do more for the environment (something most small businesses strive for already).

The new regulation prevents us from shipping to EU countries. More than one third of our turnover is generated via shipping to the EU’s internal market. It is very damaging to our small business. I would ask you to reconsider this. Small and medium-sized businesses are particularly affected.

Filed in German · English published by the European Commission

Dear sir/madam, This regulation might be the end of my one man boutique guitar business that I have been grinding on for 12 years and that is my only source of income. I ask you to please make an exception for small companies. I am a luthier and I build about 25 guitars a year in my workshop in The Netherlands, and ship around about as much parts (hand wound guitar pickups).

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 Extended Producer Responsibility (EPR) in cross-border sales – another pointless bureaucratic monster that deprives us…

Filed in German · English published by the European Commission

Comments from a small German commercial company (GmbH, luminaires and luminaire accessories, shipment to several EU Member States) We oppose the current draft. It falls short of its stated objective of harmonisation and increases the burden on small businesses at precisely the points where relief was promised. 1. The Commission does not respect its own deadline, but we are being penalised.

Filed in German · English published by the European Commission

Ladies and gentlemen, I run the knowledge page Zunbe.de with a small, connected online shop. It will only be launched in the next few days. I would therefore like to inform you of my view on the planned PPWR producer register: My website is German-language, so Germany, Austria and Switzerland are the most suitable markets.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop in a very limited niche, I would like to point out an existential point for us in the 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 I, as a one-person company, engage in small-scale e-commerce mail order sales of small-label phonograms for special music products, some of which appear only in very small print runs and are not available in regular trade. My international customer base has grown for decades. Around 500 of my packages go to other EU countries every year; this gives me almost a third of my turnover.

Filed in German · English published by the European Commission

I am a micro-entrepreneur running a one-person handmade jewellery business in Finland, selling online across the EU since 2011. I support the underlying goal of this regulation: reducing packaging waste and making producers accountable is a good and necessary aim. My concern is with how disproportionately it falls on micro-enterprises.

Hi, I run a one-person handmade craft shop in Germany, selling online (mostly through Etsy) to buyers across Europe and beyond. I already registered with Germany's LUCID system, no problem. But here's what's stressing me out: I have no idea which other EU countries I'll end up selling to in the future.

Ladies and gentlemen, as the owner of a small online shop, I would like to draw your attention to what I consider to be 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.

Filed in German · English published by the European Commission

We are a small microenterprise from Slovakia producing original handmade porcelain jewellery and ceramics. We approach both our work and the environment responsibly. We avoid unnecessary waste, recycle materials during production and packaging, reuse packaging whenever possible, and choose recycled or recyclable materials. Recently, our sales to customers in other European Union countries began to grow.

The new Packaging Act hits me hard as a woman undertaking. I do not have the time and financial capacity to arrange for one to two broadcasts to each European country. Why is there no central regulation for all countries, instead of 27 different ones, why are small businesses not excluded from the claims? I have so far collected and reused every cardboard box I receive, and I can no longer do so in the future.

Filed in German · English published by the European Commission

As a registered micro-business in Germany, I can no longer sell to any EU country except Germany since the PPWR entered into application on 12 August 2026. Registering a national representative and PRO contract in every single member state, with no minimum threshold, is financially impossible for a business my size.

Ladies and gentlemen, I would like to make it clear at the outset what practical consequence the increasing EPR requirements already have for me as a small online trader: I can no longer afford selling to other EU Member States economically. I am therefore now limiting my sales to Germany and to countries outside the EU.

Filed in German · English published by the European Commission

As a small e-commerce operator, we would like to express our firm opposition to the planned implementation of the PPWR and the associated packaging rules. In particular, the extensive registration, reporting and evidence requirements, as well as the obligation to appoint an authorised representative in cross-border sales, place a disproportionate burden on small businesses.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small business, 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 independent business owner and creator based in the EU. I run a one-person microbusiness selling small-batch paper goods directly to customers across Europe. I support the goals of the EU packaging rules and the principle that businesses should contribute to the recycling and proper management of their packaging.

Ladies and gentlemen, as a small online colour trader, I can only agree with previous comments. The requirement for authorisation per Member State is almost impossible for small businesses and still applies, in particular, where, according to the quantities supplied, registration with the Land’s packaging register is not even necessary. The business case for small deliveries abroad is then no longer worthwhile.

Filed in German · English published by the European Commission

Dear ladies and gentlemen, For an e-commerce company using on average less than 25 kg cardboard (PAP20) and 5 kg LDPE plastic for shipping products per country, the costs for the entire registration per country are disproportionately high. Certainly in relation to the costs of recycling the waste itself. Quite apart from the difficulty of having to register with at least 2 authorities per country.

Filed in Dutch · English published by the European Commission

Comments on PPWR producer registration Dear Sir/Madam, as the operator of a German online shop for gluten-free foods, I would like to draw your attention to a point of PPWR that I consider particularly problematic: the obligation to appoint an authorised representative for cross-border sales within the EU.

Filed in German · English published by the European Commission

Hello, it’s a sacrifice. We are already brutally affected by the reluctance to buy. We have shrunk from 3.5 million turnover to just under 1 million. We have reduced dramatically, from 22 employees to 8 and from 800 m² of goods in three bushes to 250 m² in one building. Otherwise, we would not have survived the last three years in MINUS. We fight for every cent and we save on everything we can.

Filed in German · English published by the European Commission

This year, I dared to take the step and set up my own business with a small retailer. I run my business on my own and currently without any employees. To give me a chance to dream, I have started to offer my products online directly to end customers. It is a beginning in which I spend a lot of time, blood and savings every day. For me, as a micro-entrepreneur, the Austrian home market is simply too small to live on.

Filed in German · English published by the European Commission

Ladies and gentlemen, as operators of online sales, we criticise this law in particular for the obligation to appoint an authorised representative for extended producer responsibility in the case of cross-border sales as completely unrealistic. It is used only for the recruitment of EU staff. For us, as online traders, selling abroad in the EU has so far been merely an ancillary transaction.

Filed in German · English published by the European Commission

I operate a small commercial eBay shop and deal exclusively in second-hand porcelain. So far, we have in principle customers from different EU countries. Around 200 parcels per year are expected to be available in EU countries. The content is very diverse, usually 1-6 or more articles are sent.

Filed in German · English published by the European Commission

I expressly reject the planned design of national producer registers under the PPWR in this form. For small and medium-sized enterprises selling cross-border within the EU, this creates a bureaucratic and financial burden that is disproportionate to the quantities of packaging actually placed on the market.

Filed in German · English published by the European Commission

Ladies and gentlemen, I run a small brand of packaged food and also develop software with which small businesses draw up their PPWR documentation. I am therefore affected twice by the Regulation: as a producer and as someone who speaks with others on a daily basis. I very much welcome the proposed harmonisation of register formats.

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

Good afternoon, We are a small business with a turnover of just under 1 million. We are strong advocates of the EU and a single market in which consumers in every country can shop easily and securely from suppliers large and small, regardless of national borders. Unfortunately, but we have been forced now to suspend all exports to other EU countries.

Filed in German · English published by the European Commission

I'm a strong supporter of environmentally-friendly solutions. However, I believe that the new policy poses a serious threat to micro industry both within EU and beyond. I run a micro business, selling handmade items online. The amount and the destinations of the parcels I send vary month to month.

Hello, I find that this new law completely fails to take into account the fact that many craftsmen will just stop doing business within the EU, and this is the linverse roof that should be done, trading as much as possible locally between us, the member countries and ENSUITE trading what we need with abroad. The ecology is a matter of great reflection and, above all, of experience on the ground.

Filed in French · English published by the European Commission

Ladies and gentlemen, I operate a small German online shop for LEGO sets, individual parts and mini-figures. As a single undertaking, I process around 600 to 800 orders a year. I also sell to other EU Member States through various platforms. However, the quantities ordered vary greatly: While I sell regularly in some countries, in others I receive only a few orders per year.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, As Klein Bean to Bar Schokoladenmanufaktur with two brick-and-mortar shops and 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…

Filed in German · English published by the European Commission

Ladies and gentlemen, I operate a small German online shop for LEGO sets, individual parts and mini-figures. In two, we process around 1000 to 1600 orders a year. We also sell to other EU Member States via Bricklink. However, the quantities ordered vary greatly: While in some countries we regularly sell (10-20 items per month), in others we receive only a few orders per year.

Filed in German · English published by the European Commission

Dear Sir/Madam, as a member of a small online trade (modular camping accessories, direct mailing from Germany, no separate legal department), I would like to comment on the draft national producer registers. On the practical issue, we meet our EPR obligations and are currently registered in five registers in four Member States for a single range of products.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

This PPWR law has fundamentally good objectives, which have been destroyed by the almost non-distinction between billions of euros of companies, which can easily take care of such legislation with legal teams, and micro-enterprises, which not only have a huge additional bureaucratic burden but are unable to pay for the respective taxes and representatives of each EU country due to financial limitations.

Filed in German · English published by the European Commission

I am a small, one-person board game publisher and creator. I support the environmental goals behind EPR. I understand that packaging creates waste and that producers should contribute to its proper collection and recycling. I am not opposed to paying for this responsibility.

Ladies and gentlemen, we are a small direct sales company for accessories in the campsite sector, which currently employs four full-time workers and generates an annual turnover of around EUR 1 million. Germany is our main country of sale, accounting for around 85 % of our turnover. Austria and Switzerland account for a further 9 %. The remaining 6 % is distributed among customers across the EU.

Filed in German · English published by the European Commission

Ladies and gentlemen, my name is Jens Schulz, and together with eight other employees I run a small online shop for used model railways. I am writing to you because the planned implementation of the PPWR producer registers for companies such as ours is not a regulatory adjustment, but an existential threat. The basic idea of the European Union is the free movement of goods across borders.

Filed in German · English published by the European Commission

Hello, unfortunately, the good will has fallen completely into red tape and extreme costs. We send around 1000 consignments abroad in the EU, with a turnover of around 30.000 a year, and would now have to pay 13.600 for standing charges and proxies before offering the goods. This would not only be 13.60 per shipping bag/carton, but would completely destroy the profits.

Filed in German · English published by the European Commission

As a small company, it is very burdensome for me to draw up a declaration of conformity for each packaging, which is already accompanied by a declaration of conformity, simply because I fill a glass and make the lid on it and add a label for it. It is perfectly sufficient for the first distributor to be in conformity. The mere fact that three elbows are put together does not change the conformity.

Filed in German · English published by the European Commission

As a very small online shop (I do it on my own), the new legislation means that I will not be able to sell within the EU. So far, I have had some customers within the EU who have regularly ordered from me. In my shop, there are spare parts and special tools that are not available everywhere. My intra-EU sales in recent years have been between 15 and 20 consignments, many of them very small.

Filed in German · English published by the European Commission

It is really good that EU take action on packaging and environmental impact. However as a small business it is absolutely impossible to find the time, economy and skill to be able to do everything right. We ship all over the world but to some EU countries we only send a handful of orders per year. So to register and pay for our packaging in each EU country is impossible.

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 aspect of the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

As online shop owner with one employee, 40% of overall turnover are at stake. For the majority of EU countries, it is a loss to offer shipping in comparison to cost/bureaucrazy for PPWR for each country. Stop the clock for small companies and provide an OSS like System.

Ladies and gentlemen, as a small online trader, I would like to draw your attention to a significant problem in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in each EU Member State for cross-border shipments.

Filed in German · English published by the European Commission

Ladies and gentlemen, I thought the EU would be borderless. But what do you do in the European Parliament? They create barriers for all small e-commerce businesses. My shop just pays EUR 100.000. About 25 % of them are abroad in Europe. How should I pay these fixed fees in the 27 Member States? I lose at least 25 % of my turnover if I work only nationally and have little chance of growing.

Filed in German · English published by the European Commission

Ladies and gentlemen, This is the complaint against this completely unnecessary Packaging Ordinance, which pushes small businesses entirely into ruin. Who, if he sells in the European single market, should be able to pay these horrific costs for each individual EU country? Only the administrative burden of writing to all countries and finding a sponsor is an act of impossibility.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a trade in biological building materials with associated online trade, I would like to draw your attention to a number of points which, in my view, are particularly critical with regard to the planned implementation of the PPWR: the obligation to appoint an authorised representative for extended producer responsibility in the case of cross-border sales with the appointment of…

Filed in German · English published by the European Commission

I am writing to you on behalf of the company JOSKA Kristall GmbH & Co. KG (shop.joska.com), as the operator of a small online shop, to express my urgent concerns about the planned implementation of the PPWR (Packaging Regulation). The obligation to appoint an authorised representative for each EU country to which supplies are made represents a massive barrier for micro-enterprises.

Filed in German · English published by the European Commission

ladies and gentlemen, as an 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

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to one aspect of the planned implementation of the PPWR producer register, which can have a significant impact on small businesses involved in cross-border trade: the obligation to appoint an authorised representative for the extended producer responsibility in other EU Member States.

Filed in German · English published by the European Commission

I am a sole trader in Sweden selling self-manufactured and imported products. EPR and PPWR make it virtually impossible for me to sell to other EU countries and make it difficult for me to import goods, spare parts, materials, etc., as an increasing number of foreign companies, within and outside the EU, have stopped or paused business with the EU following the change to PPWR on 12 August.

Filed in Swedish · English published by the European Commission

Ladies and gentlemen, In this situation with the new law, it is economically impossible to send it to the European Union. My proposal; and that’s how all the traders I’m in contact with see it: Introduction of a total quantity of cartonboard for the whole EU in relation to merchant size/turnover/staff. E.g. 1 000 kg in 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 draw your attention to a point in the planned implementation of the PPWR producer register, which can quickly become a real hurdle for small traders: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Hello, for 16 years I have run a company with now more than 20 employees in Germany. We are also active across Europe, generating around 25-30 % of our turnover. I think it is very important that the European single market grows together in order to have an opportunity at all worldwide and to be able to survive. Unfortunately, European bureaucracy often proves to be a barrier.

Filed in German · English published by the European Commission

What has happened to cross-border trade within the EU, why is it now easier to supply only outside the EU? Why are small companies being excluded from fair internal trade as a result of increasing bureaucracy? Why do we make laws and regulations that only large companies can comply with, thereby excluding smaller companies from European internal trade? And why not make a central register.

Filed in German · English published by the European Commission

Ladies and gentlemen, we conduct family-run online sales in Germany and also send our goods to private customers in many other EU Member States. We are a strong supporter of the European Union and the single market. For SMEs in particular, the ability to reach customers in other Member States without artificial national hurdles is a major advantage of European integration.

Filed in German · English published by the European Commission

Ladies and gentlemen, the use of an authorised representative to comply with the provisions of the Packaging Ordinance is for me, as a small trader, an extraordinary hardship. Because of the disproportionately high administrative costs, the regulation forces me to stop shipping to other EU countries. In my view, this is contrary to higher-ranking EU law: 1.

Filed in German · English published by the European Commission

Ladies and gentlemen, as owner of Chic & Licht, a small online shop for quality Italian luminaires, 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

As a small business in Ireland (artist) I appeal to the EU lawmakers to consider the detrimental effect this new legislation in packaging will have on my business. I am trying to build an international brand but now since 12th Aug I feel I need to shut down ordering options on my website from EU countries as I cannot afford the fees and possible penalties for non compliance. This will kill micro industry in Europe!

Ladies and gentlemen, we started a small online shop in 2018. We have come without financial support from the pandemic, have survived the crises through various wars in the world so far, and now the PPWR comes. We are now forced to limit our actions to Germany in already difficult economic times, as we can no longer afford EU-wide shipping.

Filed in German · English published by the European Commission

I am a one-person artisan workshop based in Switzerland, selling handmade guitar plectrums directly to customers across Europe. I fully support the environmental objective behind Extended Producer Responsibility and I have no objection to paying a reasonable contribution for the packaging I place on the market. The problem is proportionality.

Filed in French · English published by the European Commission

I am a smaller online retailer and currently sells in several EU markets. The planned structure of the obligation to act as a representative under the PPWR directly affects my business model and I would like to draw attention to a critical point from the practice of a medium-sized cross-border trader: the obligation to appoint an authorised representative for the extended producer responsibility in each individual…

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

I am a solo entrepreneur and I sell my photo boards on my website. I have just translated the site into English to get a bigger client base. The next step would be to invest in marketing. These are major contributions to a small factor. The costs of maintaining a website, etc., alone are already high in relation to income.

Filed in Finnish · English published by the European Commission

Subject: Concern about the impact of the new packaging rules on small businesses I support stronger packaging rules and better environmental standards. However, for a small independent business like mine, this new framework risks making cross-border sales within the EU financially unsustainable. For example, when I send a single order to another EU country, the logistics cost is only part of the equation.

Ladies and gentlemen, I operate a micro-enterprise within the meaning of the EU definition in Frankfurt am Main: Gift paper, greeting cards and originalami paper sold through a dedicated online shop, Etsy and B2B platforms. The company consists of me and an aid. My annual packaging volume is in the double-digit kilogram range, i.e.

Filed in German · English published by the European Commission

I own a small entrepreneur in Croatia. I opened it at the end of 2023 and finally started selling online last year (2025). Now with this new law, I am limited to selling local only. I am in favour of checking waste and used items when sending/receiving domestic and international parcels. But tariffs are very high and difficult to cope with for a small entrepreneur. This significantly limits our growth.

Filed in Spanish · English published by the European Commission

Ladies and gentlemen, the use of an authorised representative to comply with the provisions of the Packaging Ordinance is for me, as a small trader, an extraordinary hardship. Because of the disproportionately high cost of bail-out, the regulation forces me to stop shipping to other EU countries. In my view, this is contrary to higher-ranking EU law: 1.

Filed in German · English published by the European Commission

As an operator of small 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

I find the increasing national rules and producer registers for packaging and packaging waste highly problematic, especially for traders selling their goods to several EU countries. In principle, it is of course correct that packaging should be properly recorded and recycled. However, in my view, the current implementation results in a significant additional bureaucratic and financial burden for businesses.

Filed in German · English published by the European Commission

Hello, I really am per EU, but the PPWR has failed in its implementation. Small traders like us stop shipping to another EU country because an authorised representative in each country of destination is economically disproportionate.

Filed in German · English published by the European Commission

Ladies and gentlemen, we are an SME focused on the free movement of goods in the EU, with a small profit centre operating as a separate department. We have not yet fully covered the EU27 target markets and are planning further growth through the free movement of goods in the EU.

Filed in German · English published by the European Commission

The whole law is an absolute catastrophe for small and medium-sized online traders like me. It is simply not feasible to register in 27 countries. There should be one free-at-frontier per country if the licence fee does not exceed four times the estimated administrative cost of running a business. In such cases, a registration should be discontinued.

Filed in German · English published by the European Commission

Ladies and gentlemen, as micro-enterprises selling toys online and a small turnover in the EU country, as well as trading with other micro-enterprises from the EU surrounding area, I am no longer able to continue trading online. The high costs of PPWR in the EU countries are not economically feasible for a micro-enterprise.

Filed in German · English published by the European Commission

I sell to approximately 15 EU countries. However, I only sell a few packages per country per year. This is completely disproportionate to the legal requirements. Sales in the EU account for approximately 30-40% of my total sales. I cannot cover the costs for all the necessary EU countries from my sales. The registration, implementation, and documentation create an insane amount of work that I cannot manage alone.

Ladies and gentlemen, as the operator of a small auction house, I would like to take this vital 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

phiin studio is a one-person independent fashion label based in Switzerland, selling directly to customers in the EU in very small quantities. We fully support the objectives of the PPWR and the principle that businesses should take responsibility for the packaging they place on the market.

Ladies and gentlemen, I operate a small German online shop for LEGO sets, individual parts and mini-figures. With four employees, we process around 1200 to 1500 orders a year. We also sell to other EU Member States through various platforms. However, the quantities ordered vary greatly: While in some countries we sell regularly, in others we receive only a few orders per year.

Filed in German · English published by the European Commission

As medium-sized B2B and B2C traders in IT hardware placing packaging on the market in several EU Member States, we would like to make the following comments on this Implementing Regulation. We expressly welcome the objective set out in recital (2) of the PPWR to lay down rules that contribute to the efficient functioning of the internal market by harmonising national measures”.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

The current implementation of the Packaging and Packaging Waste Regulation is completely impractical for small and medium-sized businesses selling across the EU. My company has annual sales of approximately EUR 500,000 and sells products to customers in several EU Member States. The actual packaging fees generated by these sales are very low.

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a particularly critical point of the planned PPWR implementation: 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 operators of smaller online sales, I take this opportunity to draw attention to a particularly critical point in practice regarding 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 PPWR, I call on the European Commission to adopt the power of attorney rule and to register for companies with fewer than 10 employees and less than 2 million employees. Annual turnover. From me, a central EU registration of the company with a total lump sum for all EU countries of max. 500 per year.

Filed in German · English published by the European Commission

IMPLICA, an EPR scheme for commercial and industrial packaging, welcomes a single harmonised format for the register of producers and submits seven observations on the draft Implementing Regulation (Article 44 of Regulation (EU) 2025/40): We support identifying each separate system (household, commercial, industrial) and ask that the format allow placing-on-the-market and costs to be allocated among competing…

In our view, the planned rules jeopardise the European single market for small traders. Without real de minimis thresholds and a simple one-stop-shop solution, many small businesses will have to stop shipping to other EU countries. This not only leads to a loss of turnover and tax revenue, but also puts jobs at risk among small traders, manufacturers, manufacturers and shipping companies such as DHL, DPD and others.

Filed in German · English published by the European Commission

Ladies and Gentlemen, Last year I took tens of thousands of euros to sell my products in 6 European countries, now I can consider whether I put the money into the window! I have been self-employed for 19 years, and over the last 5 years so many laws have come to light that, as a small enterprise with 2 employees, it is only necessary to implement and comply with the laws.

Filed in German · English published by the European Commission

Ladies and gentlemen, I am a self-employed artist, illustrator and designer from Aachen, Germany. All my self-employment is based on international business. And the EU is my largest buyer market. I send to end customers all over Europe, directly from Aachen. With the introduction of the PPWR, I will lose around 60-80 % of my revenue at an already economically difficult time.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop with two shops, 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