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

Ladies and gentlemen, Modern Eves is a small jewellery boutique in the heart of Munich & distributes self-designed & made jewellery in small series. Our store has been in existence for over 20 years & employs 2 people.

Filed in German · English published by the European Commission

I would appreciate an exemption for small business to this ruling. It isn't feasible for me to register and pay fees to every country I may ship an order to, as there may only be a handful every year. I am already operating my business to reduce waste material as much as possible and package my orders with recyclable or compostable materials.

Call for reducing the burden on micro and small enterprises in the implementation of the PPWR. As a small business, we generally support the PPWR’s objectives of reducing packaging waste and promoting the circular economy. However, the envisaged registration, documentation and reporting obligations place a significant economic and time burden on micro and small enterprises.

Filed in German · English published by the European Commission

Our client number in the Transparency Register is: 7700812346 (but cannot be encoded)! Ladies and gentlemen, as a German manufacturer and a dynamically growing start-up, we would like to draw attention to a particularly critical point in our view regarding the planned implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border…

Filed in German · English published by the European Commission

We do job processing in the semiconductor industry. Our customers (national, EU, third countries) send good to us for processing, we re-use the packaging for sending the good back to their origin. However we do add small amounts of packaging material (like packaging tape or zip-ties) to re-seal parcels or re-usable boxes. The total amount of newly added material sums up to way less than 100 kg per year.

I am a small Dutch entrepreneur and sell my own books and card decks online. A small proportion of my orders go to consumers in Belgium. My company concerns only a few kilos of packaging material per year. Since 12 August 2026, I have completely halted my sales to Belgian customers as a precautionary measure due to the new PPWR/EPR obligations.

Filed in Dutch · English published by the European Commission

In the context of the consultation on the planned requirements for national producer registers under the PPWR, I would like to draw your attention to the burdens this may entail for small online traders. I am a small e-commerce business and would like to sell my products to customers in other EU Member States. However, I am deeply concerned about the registration and reporting obligations associated with the PPWR.

Filed in German · English published by the European Commission

The new PPWR makes us, as small traders, more difficult than difficult. The workload and bureaucracy are almost impossible for us to grasp and do. Today, 25 % of our working time is spent on bureaucracy. The huge costs incurred by the new PPWR have forced us to stop shipping to EU countries, which means a sudden loss of turnover for us.

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

IGEPHA welcomes the objective of an EU-wide harmonised format for registration and reporting under Extended Producer Responsibility (EPR). A uniform system should lead to a reduction in red tape for companies with cross-border activities.

Filed in German · English published by the European Commission

I am a sole trader without employees and operate an online shop for amateur accessories from my own 3D-printing production. By 12 August 2026, I had delivered to final consumers across the EU. Since that date, I have only been delivering to Germany. The reason is Article 45(3) PPWR.

Filed in German · English published by the European Commission

As a small business, we recognise the importance of EU regulations in bringing fairness and reducing barriers to trade, not just for big corporations, but also for small businesses like ours. Therefore our overarching feedback is that the implementing rules should ensure compliance costs are proportionate for micro and small businesses placing only small quantities of packaging on the market.

As much as I approve of the objective of the Packaging and Packaging Waste Regulations, they are simply impossible to follow as a small business owner. I just started my one-person business including an online shop for handmade and small quantity manufactured design products.

This Regulation is neither financially nor administratively affordable for any small manufacturer. Their ideas and regulations have in the past been more than inconsistent and incoherent, e.g. the imprudent VAT method of distribution in the EU, a procedure for declaring a few boxes to each individual EU country puts the crown on this list.

Filed in German · English published by the European Commission

Good afternoon at the new PPWR, I am extremely disturbed by the fact that, as a small consignor for a few parcels per year, I have to register in different EU countries. The administrative burden is far too high and too expensive: Authorised representatives, provide all information, etc. This costs a lot of time and – the authorised representatives do not work for money.

Filed in German · English published by the European Commission

As a solo entrepreneur who has only just launched a business in Portugal, I am worried that these new regulatory burdens have killed it before it has even begun. While I strongly support the idea of creating a more sustainable environment for handling packaging waste, I absolutely cannot afford the costs necessary to register in even a handful of EU countries, nevermind all of them, when my EU-wide revenue is a…

As much as we support the European idea and also the objectives of the Packaging and Waste Management Regulations – the current version of the PPWR makes it completely uneconomic for small and micro-enterprises to act within Europe. Why is there no EU-wide scheme or at least ONE declaration of quantities to a central body, which then redistributes, similar to OSS tax processing?

Filed in German · English published by the European Commission

Dear European Commission, Unfortunately we too had to stop trading in other European Member States. As a result, we lose around 30 % of all sales. We have every day enquiries from customers who ask us to resume sending them. We too cannot afford this from an economic point of view and small businesses cannot afford it.

Filed in German · English published by the European Commission

This is still a beurocratic burden which drastically affects small entrepreneurs. The main issue in my opinion is: - countries being able to add burden to companies - not abstract the different rules away from the company - the local country laws should be the abstraction layer for the entrepeneur.

Small trader stops EU transit: fixed costs per Land are the problem We are an online specialist trader for soil care products from Baden-Württemberg with fewer than 10 employees. We strongly support the objectives of the PPWR. With regard to the design of the national registers of producers, we would like to draw attention to a consequence that we have just carried out ourselves. 1.

Filed in German · English published by the European Commission

I run a one-person business selling a niche product online to customers all over the EU. In a whole year, everything we ship adds up to about 112 kg of packaging across every country combined. Our biggest market is 36 kg. To be allowed to keep doing that, I would have to register as a producer in 25 separate countries. The quotes I have seen come to around 7.5% of our turnover.

With the help of the employers’ association Druck und Medien Baden-Württemberg, we are trying to comply with the PPWR. Our 25-strong company has long exceeded the frustration threshold. Hours are spent without knowing whether what is being done is right. The question of whether it makes the same sense and could lead to success seems to us to be completely abstract.

Filed in German · English published by the European Commission

I fully share the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR) and the need to reduce packaging waste, improve its recyclability and incentivise the use of more sustainable solutions.

Filed in Italian · English published by the European Commission

For us as a small business, the costs are prohibitive. As a result, we unfortunately had to stop all our foreign shipments to the Ei Länder. Our Austrian customers in particular regret this very much. Every household already pays its rubbish! And we are already packaging very sustainably. Thank you for doing small business. Yours sincerely, [name removed]

Filed in German · English published by the European Commission

Hello, too often, too many monsters will be created here in a bureaucratic way. As small businesses with six sales outlets, we have to make huge efforts to cope with ever-increasing documentation requirements. In addition, it makes no sense at all. Who is helped when we buy a licence, our bags are disposed of by the end customer and not by the licensor.

Filed in German · English published by the European Commission

I just opened a small makerspace and collective in Lisbon with a few of my friends. Our primary objective is to have fun and experiment, but we also had plans to develop art pieces and helpful items and sell them online. For now, thats definitely on hold and we dont have the time or income to pay these fees to ship throughout the EU. We will limit our market to Portugal only.

We welcome the objective of harmonising producer registers and reporting formats within the EU. However, from the point of view of a German micro-enterprise in cross-border online trade, the draft is not sufficient to remove the considerable administrative burden. Our company sells food and products for Japanese cuisine to several EU Member States through its own online shop and online marketplaces.

Filed in German · English published by the European Commission

The European Commission’s dearth, the creation of another database for entrepreneurs in each EU country is an additional burden for entrepreneurs who already have to comply with a number of obligations imposed by the European Union when operating in the EU. Each country has different bases to fulfil, slightly different rules and requirements despite uniform legislation, and different obligations to fulfil.

Filed in Polish · English published by the European Commission

Dear Sir/Madam, I operate a small online shop and am very critical of the obligation to appoint an authorised representative for EPR in cross-border sales. Until now, I have always been overwhelmed by the EU and the simplified Single Market. But the new PPWR law is radically changing this attitude, as it runs counter to the very objective of the EU’s internal market!

Filed in German · English published by the European Commission

I operate a small online trade in second-hand toys. To date, I have been able to send to the EU, accounting for around 20 % of my turnover. As my business is carried out on a secondary basis and rather as a hobby, I have neither the capacity nor the financial resources to meet the requirements of the PPWR. I have therefore restricted my dispatch to Germany and non-European countries.

Filed in German · English published by the European Commission

As a small European entrepreneur, I strongly support reducing packaging waste. But PPWR should not make cross-border trade so complicated that small EU businesses are effectively discouraged from selling to customers in other Member States.

The objective of harmonising packaging rules and funding collection and recycling is sound. The current national registration model does not achieve it proportionately for micro-enterprises selling cross-border. A producer placing under a kilogram of packaging per year on the market in a given Member State faces registration fees, scheme participation and, in most cases, an authorised representative.

Ladies and gentlemen, as an operator of small online sales, the obligation to appoint an authorised representative for extended producer responsibility in cross-border sales poses a threat to my livelihood. Up to now, as a small entrepreneur, selling to other EU countries has been an obvious step forward without a legal department of my own, but with the aim of complying with the law in force.

Filed in German · English published by the European Commission

Comments from an online trader in Germany Dear Sir/Madam, in advance: The objective of the Regulation is correct. Anyone who places packaging on a market should pay for its disposal there. We do not dispute this and we are already paying. Our criticism concerns only implementation from our point of view, and it costs the Union more economic output than it generates in terms of environmental benefits. 1.

Filed in German · English published by the European Commission

I am a small independent business owner, creator, and seller. Mandatory EPR registration fees and the complex bureaucracy required for cross-border sales make it extremely difficultand often economically impossiblefor micro-businesses to sell across EU borders.

If the EU is of the opinion that small traders should continue to be burdened, then it is only at a cost and not with red tape. A small levy charged per parcel via the shipping service provider or when purchasing the shipping packaging via the manufacturer would not impose a bureaucratic burden on the small trader, fraud and checks would not be possible or necessary.

Filed in German · English published by the European Commission

Unpackt e.V. welcomes in principle the objective of harmonising registration and reporting under extended producer responsibility across Europe. Uniform digital procedures can reduce administrative burdens and make the implementation of the PPWR more transparent. At the same time, more attention needs to be paid to small and micro-enterprises and business models that avoid packaging at source.

Filed in German · English published by the European Commission

The PPWR is in itself a beautiful thing, but for micro-traders the costs involved exceed the profit. I have been running a small mail-order shop with special articles for years, which I will no longer send to the EU, and the rules should not be reduced to a simple and tolerable level. I have been contributing to the disposal of waste in Germany and Austria for years, as these are my main destination countries.

Filed in German · English published by the European Commission

As a Swiss micro-enterprise, it is unfortunately no longer financially viable to supply potential customers in neighbouring countries. The bureaucratic and financial hurdles of the new rules far outweigh the benefits. Ordering from abroad is much easier, cheaper and easier. The basic idea of reducing packaging and ensuring its cost-covering disposal makes sense.

Filed in German · English published by the European Commission

Comments on the PPWR Dear Sir/Madam, I operate the MS-KristallGlanz online shop in Germany as a small entrepreneur and sell predominantly selected precious stones, minerals and special individual items. I would like to draw your attention to the concrete impact of the PPWR on very small online traders. To date, I have also sold my products to customers in other EU Member States.

Filed in German · English published by the European Commission

I would like to ask the European Parliament to review the impact of Regulation (EU) 2025/40 on packaging and packaging waste on micro and one-person companies and to advocate for a genuine de minimis rule. I run a small publishing and crafts company in Germany that produces science-based and partly manually colored signage for zoos, animal parks, falconries and similar establishments.

Filed in German · English published by the European Commission

The rules proposed here, while good in intention, add friction and make it hard for small businesses to be compliant. That's the wrong move for multiple reasons: 1. it widens the gap between the capex necessary to compete in EU-markets. Small businesses that are just starting will find it hard to do this cheaply compared to big ones. 2. it adds complexity to something that could be made super easy.

Ladies and gentlemen, the new Packaging Regulation has simply gone too far. The idea behind this is certainly understandable, but its implementation does not correspond to my definition of debureaucratisation and burden reduction. It is precisely at this time that small businesses should be supported and not ruined! Their decision costs livelihoods. This is simply no longer sustainable!

Filed in German · English published by the European Commission

Hello together, if you want to ruin small companies with up to 40 employees and manageable turnover, please continue. We are a European Union, why we are making life difficult for each other. Please simply put the draft regulation in the trolley! Best regards, [name removed]

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 your attention to a point which, in my view, deserves particular attention 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

Why will we no longer be able to supply all EU countries in the future? Is this rule particularly harsh for small traders? From our point of view, it is clear: yes. A large international trader can spread registration, advice, agency and administrative costs over millions of orders. We cannot. If there are five orders in a country, there is nothing to distribute.

Filed in German · English published by the European Commission

Ladies and gentlemen, I have been running a goldsmith for 13 years. We hand-operate to create pledging rings and marital rings. Although we work primarily for German customers, we also often have customers from abroad, e.g. Austria. The duty of plenipotentiary and the PPWR in general hit us hard. We are a small craft business and therefore do not have a legal department.

Filed in German · English published by the European Commission

I completely get what you are trying to achieve but I don't think the current solution is fair to small businesses within EU. It could cost 20k EUR even before the first package is sent, this nonsense makes it that the only sensible thing is to suspend all EU activities and only do non-EU businesses.

Ladies and gentlemen, as the operator of a small factory with distribution mainly via my 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

leading to new product ideas and innovation. The EPR regulations threaten the existence of this innovative space in the EU. EU policymakers keep sounding the alarm about Europes lack of innovation, but seem hell-bent on making it as hard as possible for innovation to emerge at all, with regulations that create a disproportionate barrier to entry for micro-enterprises and SMEs.

By imposing this law on small traders you are in effect banging the last nail in to many of our coffins. It will prohibit us from free trade throughout Europe. Many small traders make a hand full of sales per year in different countries and this law will effectively prohibit that due to the registration fees required in each country.

Merchandise Number 1 Weight per Content Total Weight Value per Content Total Tariff No: 39269097 Description of goods: styling accessory for cars Germany Export supply under Section 6 of the Turnover Tax Act/Exempt under Section 4(1a) of the Turnover Tax Act As I am delighted to see that you have the opportunity to do so, I would like to point out that, with regard to the planned implementation of the PPWR producer…

Filed in German · English published by the European Commission

Greetings to all who read this. I am a small, in-home manufacturing business based in Ireland. Before the new packaging rules I was able to send the odd order that would come in from other EU states without worry or extra cost to me. I barely run at a profit and to even get registered with a single other EU nation for sending anything would wipe out almost all of my net profits for the year.

We are a small independent retailer based in Greece, operating since 2005 and selling directly to consumers across the European Union. We support the environmental objectives of Regulation (EU) 2025/40 and the principle that businesses should take responsibility for the packaging they place on the market.

The objectives of the PPWR and the polluter-pays principle are reasonable. Companies that place large quantities of packaging on the market should contribute to collection and recycling costs. However, the current cross-border EPR architecture is disproportionate for micro-enterprises and small online retailers and risks undermining the EU Single Market.

I own a small ceramic studio in Poland, and I am the only person working there. I send no more than 30 packages per year to different countries across Europe. It may not seem like much, but these sales are an essential part of my income. With this new regulation, it is becoming impossible for me to sell to customers in other European countries.

Ladies and gentlemen, we are a company with 10 employees which imports products and sells them under its own brand within the EU. In lengthy and burdensome tests, we have provided these products with various certificates from various laboratories and institutes in order to confirm quality, usability through compliance with European standards and much more.

Filed in German · English published by the European Commission

As small business I feel that the burden this law creates is too great compared to what I'd like to do which is occassional trading with goods that I purchase online. I see customers outside my country by I don't bother filing documents and paying fees and risking making a mistake somewhere which could lead to potential fines. I will just not sell abroad.

Ladies and gentlemen, as the operator of a small 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

As the owner of an artisan micro-enterprise based in the EU, I wish to express my deep concern regarding the disproportionate administrative and financial burden that the Packaging and Packaging Waste Regulation (PPWR) and Extended Producer Responsibility (EPR) schemes impose on small producers.

Ladies and gentlemen, as the operator of a small label, 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 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 a small organic farming and food business in Bavaria, we would like to draw your attention to one of our most critical points in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Ladies and gentlemen, with whom the PPWR is interfering with the obligation to appoint an authorised representative for extended producer responsibility in the case of cross-border sales. For many SMEs, this is simply not economically feasible, so cross-border sales will be avoided. This runs counter to the idea of the EU single market.

Filed in German · English published by the European Commission

It is necessary to group the individual authorised representatives for each country and the individual licences. None of my colleagues can participate in a proper movement of goods in this way. This is where the major mail order companies, such as Amazon, etc., are given more. A united EU also requires a united movement of goods.

Filed in German · English published by the European Commission

Nexperia B.V. is a semiconductor manufacturer. Our packaging is industrial and goes into business-to-business channels. We support a single harmonised format. The points below are where the draft creates recurring work without better data. 1.

Ladies and gentlemen, as the operator of a small online shop, I would also 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

In Germany, we operate the micro-enterprise RBcurrency Germany with two persons and sell collector banners exclusively to private end-users via our own online shop and marketplace. Our goods are small and light; as shipping packaging, we mainly use commercial paper envelopes.

Filed in German · English published by the European Commission

Ladies and gentlemen, I hereby lodge a formal complaint against the extended producer responsibility (EPR) scheme and the associated obligation to appoint national authorised representatives under the EU Packaging Regulation (PPWR).

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Dear Sir or Madam, As the operator of a small e-commerce business, I would like to take this opportunity to highlight a point in the planned implementation of the PPWR producer registers that I consider particularly critical: the obligation to appoint an authorized representative for extended producer responsibility when selling cross-border.

Dear Sir/Madam, With the entry into force of the PPWR, I was forced to stop shipping throughout the EU and will now have a serious loss of turnover. I am solo self-employed and I can live on my income in this way. I cannot finance the funds for authorised representatives in several EU countries and the additional high fees for packaging licences. On the other hand, I depend on every euro of turnover.

Filed in German · English published by the European Commission

**Subject: PPWR Articles 44 and 45(3) per-Member-State registration and representative duties are pricing small sellers out of smaller EU markets** **Provision.** From 12 August 2026 Regulation (EU) 2025/40 applies in all 27 Member States.

Good afternoon, if that remains the case, it will be cheaper and easier for me to deliver only to Germany, the USA and Canada. I have a small business to deliver for the costs in each EU country.... For this I would work Jannuar and February Completely for free to pay the costs for the PPWR. mfg

Filed in German · English published by the European Commission

Ladies and gentlemen, as a small company with 18 employees, we would like to draw attention to a particularly problematic point in the implementation of the EU Packaging Regulation (PPWR): the obligation to appoint an authorised representative for the extended producer responsibility in case of deliveries to other EU Member States.

Filed in German · English published by the European Commission

Please can we find politicians that have at least a basic understanding of business? This will KILL innovation in Europe unless its harmonised to allow small business owners to at least ship with someone who takes care certifications across Europe, at a minimum?

Ladies and gentlemen, as the owner of a small German handmade company, I would like to address you, as I am directly concerned by the new requirements of the European Packaging Regulation and in particular the extended producer responsibility schemes for cross-border shipments. I operate a small online shop alone, through which I sell, package and ship self-sealed products.

Filed in German · English published by the European Commission

Hello, I am the manager of a French microenterprise created less than a year ago and I support the objectives of Regulation (EU) 2025/40. JAI also chose from the start of my activity to limit packaging as much as possible: my products do not have individual sales packaging and my shipping packaging is plastic free.

Filed in French · English published by the European Commission

Ladies and gentlemen, we are a small German publisher and, in addition to subscriptions to periodicals, we also send books and other publishing products directly to our customers. Until the entry into force of the new PPWR rules, this included customers and subscribers in different EU Member States. Since 12 August 2026, we have stopped shipping to the EU countries concerned.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

The objectives of the PPWR in terms of recyclability, resource conservation and more uniform regulation within the European Union are in principle understandable. However, concrete implementation poses significant problems, especially for small businesses.

Filed in German · English published by the European Commission

Subject: PPWR = Repealing the EU’s internal market Good day, we operate a small online shipment for party decorations and cladding. We only started to sell our own mail order a few years ago, but we have been aware of this business for many years, from another company. We know how important cross-border shipping is for the growth of a young business.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop via Ebay, 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

It is very difficult to remain civilised in the tone if I imagine that more than 30.000 bureaucrats with monthly salaries corresponding to my annual profit impose such regulations on us. I have disabled all EU Member States as sending destinations in my webshop. I am now sending only to non-EU countries. As a German company. Misrepresentation.

Filed in German · English published by the European Commission

As you know, from many other small business owners, these new rules are killing us. Some already have established costumers in other countries, others have plans to start to expand. But common for us all, we simply do not have funds to comply with the new rules. It's not that we don't want to, but we can't afford to.

I love the EU and I love the possibibilites all EU citizens have. But what you put up with PPWR is a full blown mess ️ As a small business owner (one-man show) who ships items within the EU it won't be possible for me to conform with the PPWR meaning I'd have to cancel all sales to other EU countries than my homecountry. It's a good thing to cope with too much waste and increase recycling within all EU states.

I am a micro-business in Malta selling greeting cards direct to consumers, posted in paper envelopes. Annual volumes are roughly 1000 orders in Malta and 10 cards to Ireland about 7 kg and 0.07 kg of packaging respectively. The tiering in Article 2(1)(b) and Annex II Part B is a genuine improvement. Four points where the draft could go further without any loss of data quality: 1.

Ladies and gentlemen, we would like to provide feedback on the extended producer responsibility requirements under the EU Batteries Regulation and the PPWR. As a German company, we supply, among other things, replacement batteries to commercial customers in other EU Member States, such as industrial companies, hospitals, fire brigades, police authorities and technical service providers.

Filed in German · English published by the European Commission

Europe promised a more unified market. Europe promised less bureaucracy and fewer regulations. Yet the reality increasingly appears to be the exact opposite. These EPR regulations risk becoming the death blow to free trade within Europe for many small e-commerce businesses.

Our French micro-business (4 employees) sells dust cyclone filters across Europe via an online store. While we support the EUs sustainability goals, the EPR and PPWR requirements impose unsustainable costs on small businesses like ours, threatening our ability to trade across borders.

Ladies and gentlemen, I am an optician and craftsman with a small shop and my customers are mainly nearby. However, most of my product comes from other European countries, mainly from small spectacle manufacturers and manufacturers. Their products are usually preferable to larger manufacturers in terms of sustainability and durability.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in Slovak · English published by the European Commission

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

Filed in French · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in Italian · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

Filed in Spanish · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in Estonian · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in French · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in French · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

Filed in Dutch · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

The current packaging rules place a disproportionate burden on micro-businesses. Many of us are one-person businesses receiving only a few orders per year from each EU country. Requiring separate registrations, fees, reporting and potentially representatives in every Member State makes no financial or practical sense. In some countries, compliance may cost more than the total value of our annual sales there.

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in Czech · English published by the European Commission

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

Filed in Italian · English published by the European Commission

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

Filed in Danish · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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