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

# GEMA GmbH’s comments on the EU Packaging Regulation and the European Single Market **Subject: PPWR and national EPR registrations of the European single market must not stop at administrative borders for SMEs** Dear Sir/Madam, the European Union rightly refers to Europe as a single market.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a particularly problematic aspect of the planned PPWR producer register: the mandatory appointment of 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, we run a small online shop, previously sent to many EU countries. Unfortunately, due to the obligation to appoint an authorised representative in each supplier country and the resulting costs, we will no longer be able to offer this in the future. An exemption for small businesses or a de minimis threshold should be created as a matter of urgency.

Filed in German · 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 serious burdens this entails, in particular for solo self-employed persons and micro-enterprises. I sell small online and would like to continue selling my handmade products as an individual to customers in other EU Member States.

Filed in German · English published by the European Commission

Remind yourselves of the main ethos of the EU! To create the world's biggest free trade market! So why are you dividing us all up and expecting small businesses to navigate 27 different sets of legislation and pay 27 different annual fees. It's completely crazy. I'm a small vintage seller in France, so effectively selling old household items such as vases and plates often over 100 years old.

Ladies and gentlemen, I do not want to tow you with a model letter, but to draw your attention explicitly to wide-ranging inconsistencies. A brief explanation of the classification: for more than 20 years, I have been trading in second-hand goods and using used packaging out of conviction. I am not alone in this approach.

Filed in German · English published by the European Commission

Dear Sir/Madam, I run a small nursery in Germany. It is a micro-holding for the preservation of rare old fruit varieties, some of which are threatened with extinction. Full transit within the EU at the lowest possible cost is essential for me.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a critical point in the planned PPWR producer register: the obligation to appoint an authorised representative in the case of cross-border sales. For small businesses, even a single sale to another Member State means that an authorised representative has to be appointed and paid for.

Filed in German · English published by the European Commission

Ladies and gentlemen, we operate a small online and stationary shop with canoes and paddle accessories, i.e. a niche market. Today, I would like to take this opportunity to draw attention to what I see as a particularly critical point in the implementation of the PPWR: the obligation to appoint an authorised representative in the case of cross-border sales.

Filed in German · English published by the European Commission

Dear Sir/Madam, this significantly restricts internal trade. As a small business, we send small quantities of parcels to different EU countries. The cost of doing so would increase enormously, which would no longer be sustainable. Some larger companies in different EU countries use our products on offer. Some of these are niche products, but they ensure our survival.

Filed in German · English published by the European Commission

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

Ladies and gentlemen, the abolition of the plenipotentiary alone would not change anything for us at all. This is not just about the PPWR. Since 2019, this has generally involved the Packaging Ordinance, which has cost us a five-digit annual turnover since then. For the reasons set out below, we were forced to stop shipping to almost all EU countries years ago. Since then, we have supplied only Germany and Austria.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop with two employees, I would ask you to take into account the particular burdens arising from the planned implementation of the PPWR producer registers for micro and small enterprises.

Filed in German · English published by the European Commission

Dear Members of the Commission, the PPWR meets start-ups in the start-up phase in a way that is not economically proportionate. We are close to entering or entering the market and have already made significant investments in construction, development and initial structures. The additional costs and organisational requirements now facing us exacerbate the burden at a time when profitability is not yet stable.

Filed in German · English published by the European Commission

Ladies and gentlemen, we have a small online shop based in Germany and we also sell our goods to customers in other EU Member States. The European single market should enable small businesses in particular to reach customers across the EU. However, the design of extended producer responsibility for packaging risks significantly limiting this idea.

Filed in German · English published by the European Commission

Dear Sir/Madam, I would like to inform you that the new packaging rules are not in order. As a solo self-employed person with a small ebay shop and low turnover, I do not feel able to continue offering international shipping. I make up 95 % of shipments within Germany using packaging material that I have already used and have been licensed to use for packaging for several years.

Filed in German · English published by the European Commission

Request to adapt the PPWR. As a small company, we cannot designate an authorised representative in every EU Member State, as this would entail very high costs and is therefore not feasible. It would also be helpful to allow derogations for certain small enterprises. Until such a change is made, we have to stop shipping to all EU countries where we do not sell enough. Detrimental to our EU customers.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

We, solo self-employed retailers, call for de minimis thresholds for registration in EU-wide shipping within the EU-wide internal market. There are around 3.5 million self-employed people in Germany. The majority of them are solo self-employed. About a third of the self-employed are women. Many of them are single mothers who generate their family income in this way.

Filed in German · English published by the European Commission

We sell home-made hand-woven rugs and wool products worth up to 10.000 a year to other EU countries. As private customers find us online, this turnover can vary every year, just as the origin can vary. As with many other craftsmen, this is therefore impossible to calculate. Turnover also does not mean profit, and the new costs we have to either generate by adjusting prices or pay from our profit.

Filed in German · English published by the European Commission

This is a shocking new set of regulations that seems to be focussed on destroying small companies in the EU. While originally setup to make big companies pay for this recycling, the EU has shoot themselves in the foot with this regulation. I don't even know where to begin. We have to register in every country we ship too?

Ladies and gentlemen, as the operator of a small online shop, I am deeply concerned about the planned obligation to act as an authorised representative under the PPWR. Individual sales to another EU Member State may require an authorised representative to be appointed there, a contract to be concluded and the corresponding fixed costs to be borne.

Filed in German · English published by the European Commission

Comments from Zaiser Art GbR (East Filders, Germany) Practical report by a micro-enterprise on EPR registration under the PPWR We are a two-person company (online sale of collector figures, mybearbrick.de) and served customers in 20 EU Member States until August 2026.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a traditional family business in Hamburg, we would like to tell you how the Packaging and Packaging Waste Regulation (PPWR), in its current form, affects small and medium-sized enterprises. For the time being: We explicitly share the environmental objectives of the Regulation.

Filed in German · English published by the European Commission

I am the owner of penumbra, a very small business based in Austria. We manufacture handmade leather accessories in our own workshop and sell them directly to customers, mostly within the EU. I very much welcome the attempt to harmonise the format of producer registration and reporting across Member States.

We are a small winery and send wine (bottles) via DHL/UPS to various end consumers or smaller traders in EU countries (NL, DK, F, etc.). It would be far too costly to contact authorised representatives in the respective Länder and would also make shipping more difficult. As a result of the scheme, we have decided to completely stop shipping to other EU countries – leading to a significant loss of turnover.

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 and the obligation to use licences for cross-border sales.

Filed in German · English published by the European Commission

It is reasonable to appoint an authorised representative for each EU country and to pay a service provider to do so. We are an e-commerce company, which depends in part on turnover from the respective small countries &, if cancelled, would lose around 50.000 a year due to administrative costs!

Filed in German · English published by the European Commission

Ladies and gentlemen, as the owner of serviettenshop.de, a small online shop for decorative paper serviettes and suitable table decorations printed candles, serviettes, wipes, toilet paper, table runners and porcelain, 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…

Filed in German · English published by the European Commission

Ladies and gentlemen, as an operator of a small online shop, I would like to draw your attention to what I consider to be a significant problem in the practical application of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). I strongly support the aim of the PPWR to prevent packaging waste, strengthen recycling and improve producer responsibility across Europe.

Filed in German · English published by the European Commission

I run a small online retail business in Germany and sell directly to consumers and other end users across the EU. Cross-border sales have become very important for my business, but the number of shipments varies enormously from one Member State to another. I have no problem with paying for the collection and recycling of the packaging I put on the market. That is not the issue.

The PPWR in its current form is completely impractical for small businesses that only occasionally send parcels to other EU countries. We are not talking about companies that send hundreds or thousands of parcels every day across Europe. It is also about small traders who may send a few orders per quarter or year to a neighbouring country.

Filed in German · English published by the European Commission

As an online retailer, 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

Feedback as a small e-commerce company concerned from Germany (trade in furniture and residential accessories). We very much welcome the aim of this act: uniform, EU-wide standardised rules for national registers of producers, avoiding diverging national requirements.

Filed in German · English published by the European Commission

As of September 1st, I am laying off both of my employees due to these new regulations and the inability to run my business in its current size and format. A colleague who is on the job market is expecting a child. His comment was laconic - I hope they don't come up with a new regulation for recycling human waste, that I can't afford the recycling fee for my child.

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Dear, We are trading online with up to 12.8, 4 people, since 123 no more than 2 people, it is feasible to register everywhere, and to have a close look at the rules for each country, so companies can hire the extra staff for this and do nothing else. # This law destroys online trade. We will try to survive, otherwise we declare ourselves without fear, two are already unemployed.

Filed in German · English published by the European Commission

Good morning, I dont want to use any prepared text and just copy and paste it here. We are a wine merchant selling small quantities of very and highly specialized wines growing throughout Europe and we sell them to customers throughout Europe. In many European countries we are the only one providing these wines. Every 1000 shipments we have 1 to 2 complaints. We can be reached by phone 24 hours a day.

As a self-employed person with a small online shop, I simply cannot afford to have an authorised representative in each country. Moreover, in my view, this rule runs counter to the basic idea of the EU: trade within Member States should be simplified. This is precisely what is being done to stop it for small traders. This is very bad because, for example, I loved to buy products from small manufacturers via Etsy.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, I sell (very small) used lego parts online via the www.bricklink.com platform. To date, around 50 % of my customers have been from other EU countries. As a maximum annual turnover in individual EU countries, I have earned around EUR 600 each.

Filed in German · English published by the European Commission

Dear Sir, Madam, Although the intention and aim of this Regulation is positive, its implementation in its current form must be viewed critically. I would like to highlight two points which, from the point of view of an SME, constitute a particular barrier to the free movement of goods.

Filed in German · English published by the European Commission

Ladies and gentlemen, I have a owner-managed specialist shop for tools, machines and building accessories with a connected online shop. We see the following serious problem with the planned PPWR implementation. If we have to appoint a separate authorised representative for producer responsibility for sale in each EU country, this increases either our human or financial resources to such an extent that we have to…

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

We are a small online owner with a turnover of around 1 million. We send it to every EU country. In some of them, less than 10 packages per year. With the exception of Austria, most of them do not have 100 parcels per year. Overall, however, this is still a volume that secures a job with us.

Filed in German · English published by the European Commission

We strongly support the PPWR’s objective of reducing packaging waste, conserving resources and strengthening environmental protection. However, from the point of view of the companies concerned, it is often felt that new requirements are mainly accompanied by prohibitions, sanctions and additional obligations, rather than providing sufficient support to companies in their practical implementation.

Filed in German · English published by the European Commission

The EU repeatedly claims that Europe has a Single Market. The packaging regulation is a perfect example of why many businesses increasingly consider this claim almost cynical. For an SME selling across Europe, the current system means national registrations, national reporting requirements, national authorities, different portals, different procedures and additional compliance costs in multiple Member States.

Hello, we are a small online trader with 8 employees. It is commercially and administratively impossible for us to appoint national representatives in the individual EU countries. The alternative, which remains with us, must be abandoned to all EU countries on a wide scale. The implementation of national processes is also a real cause for concern.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, I operate a small handmade business in Germany and sell through an online marketplace. I send 100 parcels per year to 7 other EU countries. My turnover from these countries is EUR 2000. I expect to pay EUR 2100 per year for registration and authorised representatives in these countries. Because the fixed costs exceed my turnover abroad, I have stopped shipping to other EU countries.

Filed in German · English published by the European Commission

Hello, it is a huge burden and far too expensive for small traders. It is no longer worth selling abroad at all. The rule makes absolutely nothing better, but only much more effort, costs and pre-notification of bureaucracy. The EU was of the opinion that intra-EU trade should be easy. Instead, it is made more difficult.

Filed in German · English published by the European Commission

The current approach to cross-border EPR fees is unfair to small creative businesses in the EU. These fees may be insignificant for large companies such as Temu and Amazon, but they can be a serious burden for small independent creators. For many of us, the additional costs of selling to customers in different EU countries can make cross-border sales simply not worthwhile.

These regulations and rules about packaging are mostly waste of money and time. Just making bigger footprint in every possible way, because of increasing bureaucracy. That propably increases need of man power to solve and clarify the needs to continue of making business. Maybe only 1 sheet of paper would have done the same. Don´t use plasrtic too much. Use more cardboard. Use proper size of packaging.

Dear Sir/Madam, I am a small e-commerce trader in Austria and I sell my product mainly in Austria. Nevertheless, customers from all other EU countries are constantly becoming aware of my product and are enthusiastic in order to order it.

Filed in German · English published by the European Commission

The new PPWR legislation, which took effect on August 12th 2026, will have a massive and disproportionate impact on sole traders and SMEs, who simply cannot afford to buy all the necessary EPR licences (in advance of possible sales, with no refund if no sales are made), appointing an AR (Authorised Representative) in each EU country they wish to sell to, and the time and effort the different reporting schedules will…

Hello, this new tax will simply put an end to my activity and I will have to become a jobseeker again and receive the RSA, as I have no other solution at the moment. Indeed, my volume of online sales is not very significant for the time being. I still send parcels to many EU countries, but I don't have enough volume to pay this tax in each of these Member States.

Filed in French · English published by the European Commission

We are a small Norwegian startup and we welcome the attempt of the European Union to reduce waste and to make packaging for products and delivery more sustainable. The suggested solutions involving, among other things, - a great deal of additional administrative effort for the companies selling within the EU, - demand for representatives in target EU countries, - different rules for packaging products bought in the…

As a sole trader making ornaments and gifts from recycled plastic and natural fibres who donates a significant part of profit to the rainforest charities, I'm very dedicated to sustainability. My makes ship mostly in reused cardboard boxes. Yet, while it's still business as usual from Amazon and other big polluters, I have to pause my sales to the EU. How is that an improvement?

In principle, I support the PPWR’s objective of reducing packaging waste, promoting recycling and ensuring a fair share of the costs incurred by companies placing large quantities of packaging on the market. However, the envisaged administrative obligations in cross-border shipping, in particular the obligation to appoint an authorised representative for extended producer responsibility in individual Member States…

Filed in German · English published by the European Commission

Ladies and gentlemen, for me as a small entrepreneur, selling abroad in the EU has so far been an obvious step forward without a legal department of my own, but with the aim of complying with the law in force. The PPWR significantly changes this invoice: Once I sell goods to another Member State, a single sale may trigger the obligation to appoint and pay for an authorised representative there.

Filed in German · English published by the European Commission

I run a small micro business out of the UK just me and my wife and turnover under £100k, the new EPR representative requirements and high volume (1ton minimum) PPWR costs for businesses of this size is going to have a huge impact on my ability to serve our EU customers. As a 2 person team the administrative burden has gone from zero to 100% in just dealing with 1 EU state let alone all 27.

The new PPWR and EPR rules have made having a micro business impossible. While I agree that packaging should be disposed of in a responsible way. I do not think this is the way to do it. The simple solution is to make a lower limit that if you stay under you don't have to register to the individual countries.

I run two small online shops, which for years have also allowed me to supply individual customers across the EU. With the introduction of the Packaging Ordinance in Germany, I have to pay around EUR 150 per year for the recycling of the shipping packaging for Germany alone. Similar costs would be incurred for each country where there are no allowances. This cannot afford a small online shop.

Filed in German · English published by the European Commission

This is well-intended but completely unfeasible in its implementation requiring complicated paperwork and expensive physical representation in a country to ship there. It will block trade and make it harder for Europeans to order goods from small businesses in countries like Canada, the UK and Australia. This needs to go back to the drawing board!

Red tape from the finest. Simply ridiculous. Customers laugh one when they tell it. EU supplies are like or not, but we buy a lot abroad in the EU and the burden is huge. Cash and carry in the Netherlands then also become almost illegal. Where should the trader know the data? Sometimes 180 traders in a hall and you pay at a cashier. The providers come from many EU countries. Who should hold the dung?

Filed in German · English published by the European Commission

I run a one-person game shop in the Netherlands with a webshop attached. I am responding as a micro-enterprise directly affected by this draft act. Harmonising the format of national producer registers is genuinely useful and I welcome it. But the burden for the smallest sellers is not the format of the registers. It is their number, and the mandatory authorised representative attached to each one.

Hello, I'm a small business owner from Slovakia, i understand all of the safety concerns of the European Union about shipping across different states, but such a law would cause a significant impact on small businesses' sales that are already paying big taxes.

The regulations being put forward are simply unworkable for small businesses (micro-enterprises). The country registrations, paperwork and verifications alone are too much for a small business to handle and then include what will amount to huge financial costs is going to cause the closure of many businesses.The EU is founded on the idea of free trade and movement of goods between countries, these regulations are in…

I have sent online sales of skservice products and have so far sent them to 12 EU countries. Turnover between EUR 200 and EUR 5000 per country. At a cost of more than EUR 300 per country, with a profit of 5 %, shipping does not cover my costs. Not to talk about additional bureaucracy at all. That is why I will stop delivering to these countries from now on.

Filed in German · English published by the European Commission

I represent a small band in the UK selling small numbers of parcels to the EU each month and I think this is a terrible regulation. Not only is our packaging immaculate and recyclable (most CD/shirt printing companies take good care of their packaging nowadays) but the regulation makes it also impossible for small bands like us to continue trading, as the associated cost and time spent on declaring packaging details…

As a small UK creative business owner (I sell only a few thousand pounds worth of products a year), the new EPR regulations essentially make it impossible for me and many small craft / indipendant micro businesses to sell into the EU. I completely agree on the principles behind the packaging law changes, and I think they're brilliant for large businesses who are selling millions of products.

As an operator of small online sales, I would like to comment on a point of PPWR implementation which, in its current form, does not act as regulation, but as a de facto trade ban: 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 operate a small workshop alone and sell 60% to customers in other EU countries. Most countries only 1 or 2 packages a year. The biggest 20 cardboard boxes. Licensing my packaging in my home country is affordable and relatively straightforward. Paying 26x VAT via OSS is clumsy but manageable.

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to what I consider to be a critical point in the planned 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

As an artist, I am also affected by the new regulation and will no longer be able to sell my work to EU countries. The basic idea of the EU is to create a single market without barriers, which is wiped out. I am in favour of environmental laws, but here it is essential to make an exception for small businesses, for which this regulation means economic death. This cannot be in everyone’s interest.

Filed in German · English published by the European Commission

The main problem with these rules is the disproportionate burden on small traders due to bureaucratic hurdles. The resulting royalties are also disproportionate. Allowance levels should be introduced or consideration should be given to the extent to which such regulations are the least restrictive means.

Filed in German · English published by the European Commission

As a small business owner, who works hard, and contributes greatly to my country's economy, like millions of others... it's killing us!! It makes impossible for us to sell to EU customers now, first of all because of the costs, and having to register in each EU country - which is impossible still in certain countries, as they don't have an international registration system in place.

I am a small independent skincare business owner based in the EU, manufacturing my own products and hoping to sell them across the European market. While I fully support the environmental objectives of the PPWR and Extended Producer Responsibility, the current system creates a disproportionate burden for microbusinesses.

We are a small, independent business based in Austria and primarily sell rare, historical and pre owned collectible items to other EU Member States. Our shipping volume is very low compared with large online retailers. Many of our shipments consist of individual high value items. We strongly support the EUs objectives of waste prevention, reuse and resource conservation.

I am a founding member of an art collective that has both EU citizen members and also ships merchandise to EU customers. This merchandise is usually physical media of music released on our record label, typically in vinyl or cassette format. These regulations will make it financially prohibitive for us to continue shipping to customers within the EU.

Ladies and gentlemen, as the operator of a small online shop focusing on ECHTE Sustainability and Resource Conservation, 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…

Filed in German · English published by the European Commission

In principle, I support the objectives pursued by the European Commission in its packaging regulation: Reducing and improving the recyclability of packaging waste is an important objective that I fully support as an EU citizen!

Filed in German · English published by the European Commission

Ladies and gentlemen, it is really a sacrifice with which the European Commission is pushing through such a draft law without any consideration for losses. The idea is laudable and worthwhile, but its implementation bypasses any business practice and is unrealistic. Especially for smaller companies.

Filed in German · English published by the European Commission

Comments on the implementation of the PPWR producer register Dear Sir/Madam, my name is Samir Zamel. I operate a small online shop under the name Kanana Design, selling, among other things, small garden items and fishing accessories.

Filed in German · English published by the European Commission

Good afternoon, as a foreigner based outside Germany who, as a small entrepreneur with a turnover of EUR 5-10 per year, wishes to sell her own ceramics for 7 days at a sales exhibition in Germany, I am obliged under the new Packaging Act to look for an authorised representative to confirm the conformity of my really small quantity of packaging placed on the market in Germany and to regulate other things.

Filed in German · English published by the European Commission

It is so sad to read so many news and messages that small shops are no longer able to supply their customers because the hurdles and costs of shipping are now too high and too high. Of course, environmental protection is important, but perhaps it could be designed in such a way that it does not lead to so many company tasks. Large companies will be able to absorb this.

Filed in German · English published by the European Commission

The PPWR puts small businesses at a disadvantage by not distinguishing between small and large businesses. Even if we only send one package to another country, we have to pay hundreds of euros to register in that country. This is unfeasible for small businesses. The PPWR favours big businesses by driving small businesses off the market.

As a micro business owner I ask you to look carefully at how this is currently written and clearly state where micro businesses fall within this scheme. Please take our situation in consideration. We cannot afford this. We cant afford an EPR in every country.

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

Filed in German · English published by the European Commission

As the founder of a small artisanal manufacture, I would like to comment on this initiative in practice. Starting point I am a sole trader and run my business on my own. I manufacture products from natural materials in traditional craft technology and sell them via my own online shop and via Etsy mainly to customers in Germany.

Filed in German · English published by the European Commission

Disproportionate impact of cross-border EPR requirements on micro-enterprises. I am writing as the owner of a small Irish business selling natural dyes, textile and craft materials and providing education in natural dyeing. We have traded across the EU for many years. We fully support the environmental objectives of the PPWR and the principle of Extended Producer Responsibility.

I am an artist and an EU citizen based in Germany. I have been practicing my craft for 33 years, conducting business worldwide, and supporting my country through the taxes I pay. Like many of my colleagues, I don't want to be a burden on the government. But if small business owners can no longer operate because of this new legislation, that is exactly what will happen.

I can hardly believe how micro entrepreneurs are being sidelined and subjected to the same rules as large enterprises. The two are completely incomparable, and the situation is unsustainablee specially for sole proprietorships. Don't let the small entrepreneur go under, help!

I am a micro-enterprise artisan based in an EU Member State, producing handmade felt products sold at 1015, with modest annual turnover. Due to the small size and low weight of the items, the packaging used is minimal in both weight and dimensions.

I fully support the goal of reducing packaging waste as a green girl from day 1 but I strongly disagree with the disproportionate burden the PPWR may place on micro and small businesses like mine. Additional packaging requirements can create significant financial, administrative and practical difficulties. We already use limited packaging and actively seek more sustainable solutions.

We are a small Latvian company preparing to sell Irish craft beverages and food products within the Baltic market. Our experience shows that the current system creates a serious barrier for micro and small businesses wishing to trade across the EU Single Market.

I am writing to express my deep concern regarding the Packaging and Packaging Waste Regulation (PPWR) and its severe consequences for small businesses, micro-enterprises, and self-employed individuals across Europe. While the goal of reducing packaging waste is absolutely necessary, the current framework of the PPWR acts as a direct threat to the survival of small-scale entrepreneurs.

Thank you for acknowledging the impact on micro-businesses and for working towards a solution. I do have one question that I hope the Commission will also examine: how did this impact pass the EUs existing Better Regulation safeguards in the first place? The Better Regulation framework already includes SME, proportionality, administrative burden and Single Market assessments.

The financial and administrative burden for small and very small enterprises brought about by this text is simply not bearable for them. I am directly concerned. I am a craft artist, I cannot take on the financial and administrative burden of selling my creations in other European countries and I am afraid that my main supplier, located in another European country, will no longer be able to send me his goods.

Filed in French · English published by the European Commission

Giiiirrrrrrrrlllll, this shall not pass. Artists like me send like 10-50 packages per year to 27 different countries. This pushes people like us into grey economics, because we will NOT be pushed into oblivion. Your choice, though. Here is a list of suggestions, if you care about the nature: ban cars, short continental flights, and billionaires. Recycling was not enough in the 90s! Time to do some real work.

Ladies and gentlemen, as a small, family-run model-building specialist shop with associated mail-order sales, we would like to express our concerns about the implementation of the new EU Packaging Regulation (PPWR). Our cross-border shipping within the EU is only a small part of our business.

Filed in German · English published by the European Commission

**Dear ladies and gentlemen,** as the operator of the German animal feed brand **petinjo®**, we sell our products directly to end customers via our own online shop. As a small company, we would also like to offer our products in future to customers in other EU Member States, thereby taking advantage of the opportunities offered by the European single market.

Filed in German · English published by the European Commission

I run a small e-commerce business AKI selling across several EU countries. All my suppliers are local, within 70 km, all certified for sustainability: tissue paper, corrugated cardboard, labels, outer boxes. My packaging is already minimal, recyclable, and protective I sell glass, couriers won't insure it, every box is sized to the centimetre to cut both damage and waste.

I'm writing as the owner of a microbusiness in the Arts Industry. I implore you to reconsider how these new regulations are implemented. I fully support heavier rules around curbing waste and making sure packaging is done in an environmentally conscious way, but the current legislation completely kills trade for micro companies with the current setup.

# Comments on the obligation of authorised representatives in EU online trade **Dear Sir/Madam,** as the operator of a small owner-run online trade in motorsports and car parts, we would like to draw attention to an issue of particular concern in our view regarding the 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

many small businesses need the size of the European market to generate for their mostly niche product across Europe the sales they need to make a profit without excessive advertising. A single market, in this case the German market, is too small for many products, including my construction toys. Small businesses are often flexible in their services and offerings and are extremely customer-oriented.

Filed in German · English published by the European Commission

Honourable Members of the European Parliament, I am writing to you as a small Austrian online trader. I support the objectives of the EU Packaging Regulation: less packaging waste, more recycling and a fair share of disposal costs. What I do not understand is implementation in the European single market.

Filed in German · English published by the European Commission

We are a small shipping company for used motorcycle parts. Since 12 August 2026, we have NOT sent more to other European countries. Neither the burden nor the costs would be tolerable for us. That’s not the idea of Europe? Right? Harms the fact that the European Union does not seem to have an interest in the fate of small businesses.

Filed in German · English published by the European Commission

I, like most others commenting here, am a small business in my case a micro enterprise of just one person in France. I have an online shop in which I sell goods imported both from other EU countries and also 3 non-EU European countries.

Ladies and gentlemen, as the operator of a small online antiquarantine, 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. I sell abroad only occasionally.

Filed in German · English published by the European Commission

I am the owner of a small independent handmade jewellery business based in Athens, Greece. I am writing because the new packaging obligations are creating a disproportionate burden for micro and small European businesses selling directly to consumers across the EU.

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to an aspect of the planned implementation of the PPWR Producer Register, which has significant practical and economic implications, especially for small businesses: 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, for many years I have been selling online on a small scale in Germany. I develop and manufacture accessories for motorcycles myself and have so far supplied customers in many EU Member States. For me, this is one of the great advantages of the European single market: A very small company can also produce specialised products and offer these customers across Europe.

Filed in German · English published by the European Commission

Hello, my annual turnover with the products concerned is around EUR 25.000 net. I send only around 40 parcels per year to private customers in other EU Member States. My company is a sole proprietorship with no employees.

Filed in German · English published by the European Commission

Ladies and gentlemen, but I fully understand your concern, I would like to point out that without the introduction of meaningful thresholds, this draft is simply damaging to business and will significantly restrict EU trade to the detriment of consumers.

Filed in German · English published by the European Commission

Ladies and gentlemen, as owner of the small online shop Naturzwerge Kindermode, I would like to draw your attention to a particularly problematic point in my view regarding the planned implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

I am writing to you as a small French entrepreneur in art crafts. I am deeply concerned about the new European Packaging Regulation, and in particular the resulting national obligations to register, declare and appoint an authorised representative. As things stand, a small company like mine is required to register in each EU Member State and, in some cases, appoint an authorised representative.

Filed in French · English published by the European Commission

Ladies and gentlemen, I am writing to you today as the owner of a small online shop to highlight a critical weakness from a practical point of view of the planned PPWR producer register: the country-specific obligation to have an authorised representative in the case of cross-border sales. The Digital Single Market offers excellent growth opportunities for small businesses.

Filed in German · English published by the European Commission

As managing director of ReFairIT GmbH, a small enterprise specialising in B2B IT refurbishment and hardware remarketing in the DACH region, I am writing to you to comment on the planned implementation of the PPWR rules on national producer registers. ReFairIT sells pre-processed IT and telecommunications hardware across borders, including via Amazon.de and Amazon.it.

Filed in German · English published by the European Commission

With the obligation to appoint an authorised representative in each country, the very existence of small and micro-enterprises is threatened and these costs are disproportionate. Here, the legislator fails to take account of the fact that online trade is largely made up of small traders and not just large firms such as Zalande & Co.

Filed in German · English published by the European Commission

Dear Sir or Madam, I run a small online business and would like to raise a point in the PPWR that directly affects me as a small business owner: the requirement to appoint an authorised representative (Art. 45 PPWR) for cross border sales.

I run a micro-enterprise in Erkelenz, Germany, selling second-hand vinyl records by mail order to consumers in all other EU Member States, with roughly 2000 shipments per year. Since the PPWR became applicable on 12 August 2026, Article 45(3) requires me to appoint an authorised representative for extended producer responsibility in every country I ship to, and to register there.

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to an aspect of the planned PPWR producer register which is, in my view, particularly problematic: 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

Whilst we need to increase recycling and lower waste dramatically, these new rules and procedures and untenable for small and micro businesses, both in terms of regulatory overhead and direct costs. Single person businesses should not be treated the same as the likes of Amazon, and will not remain in business if they are forced to do so.

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

Filed in German · English published by the European Commission

Ladies and gentlemen, we are a small company with 5 employees and, in addition to a brick-and-mortar shop, we also have an online shop in which we occasionally deliver parcels abroad. The minimum cost of an agent solution per European country is around 300 net/country/year.

Filed in German · English published by the European Commission

Ladies and gentlemen, as small e-commerce traders, I would like to express my concerns about the new EU Packaging Regulation (PPWR). The basic objectives of the Regulation of reducing packaging waste, conserving resources and promoting recycling are understandable and should be supported.

Filed in German · English published by the European Commission

National EPR registers jeopardise the internal market for SMEs We are ALBERT KREUZ GmbH, a German manufacturer and online trader with four employees. We produce clothing in Germany and Portugal and sell it directly to EU consumers. We strongly support the objective of reducing packaging waste and ensuring that producers contribute to the actual costs of recycling.

Filed in German · English published by the European Commission

Ladies and gentlemen, I have a small online shop with a few employees. I would urge you to reconsider and revise the obligation of authorised representatives under the PPWR and the Packaging Ordinance in general.

Filed in German · English published by the European Commission

Ladies and Gentlemen, I lead CrackersCompany as a German micro-enterprise. We employ fewer than 10 people and have an annual turnover of less than EUR 2 million. We want to deliver goods to customers within the European single market with legal certainty.

Filed in German · English published by the European Commission

Ladies and gentlemen, I am a small online retailer for retro video games sold largely via the Ebay platform. https://www.ebay.de/str/retrogamehunterde In total, I send around 2000 parcels per year, of which around 25 % are abroad. Of this 25 %, the largest share, more than 90 %, is abroad in the EU.

Filed in German · English published by the European Commission

Ladies and gentlemen, as owners of small online sales, I would like to draw your attention to a particularly problematic aspect of the planned implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border sales in other EU Member States.

Filed in German · English published by the European Commission

As an online trader with a turnover of around 2 million, we have switched off cross-border mailing to most EU countries. It simply is not worth the effort. We cannot appoint plenipotentiaries everywhere. All costs money. This is no longer worthwhile. What about less bureaucracy? Every law that comes from the EU increases red tape. The Chinese are supposed to take over my market shares. I'm out!

Filed in German · English published by the European Commission

I strongly object to the new PPWR requirements and their impact on smaller businesses. The EU is supposed to be a connected Single Market, yet these rules increasingly mean that businesses face different requirements in each country. For a small business, having to understand multiple national systems and pay for local representatives or compliance services can make cross-border sales simply uneconomical.

Ladies and gentlemen, as Orsini Manufaktur, a small e-commerce company, would like to draw attention to a particularly critical point in the implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales. Selling to other EU Member States is an important and obvious growth step 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 draw your attention to a particularly problematic aspect of the planned implementation of the PPWR producer register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, thank you for the opportunity to submit personal comments on the introduced PPWR Regulation. As in the current media, this is not economically and legally feasible for small businesses in the EU internal market and amounts to a dexit for the German market. On 12.08.26, we had to limit our two online shops in the dispatch area to our home market in Germany.

Filed in German · English published by the European Commission

Small companies are not smaller wholesalers with proportionally smaller obligations. They bear the same fixed costs as large market players, spread over a much smaller volume of business. A design of the authorised representative obligation that takes this into account would allow me and many other small traders to make effective use of the European internal market, rather than limiting us to the German market for…

Filed in German · English published by the European Commission

Dear European Commission, I am writing as the owner of de:Nihil Records, an independent record label based in the Sweden. First of all, I want to express my support for the goals behind the new packaging regulations. Reducing waste, encouraging recycling, and limiting unnecessary plastic use are important objectives that I fully support. In fact, our label has already taken voluntary steps in this direction.

Good morning. Here Julie, who has been independent for 24 years and has been selling online for 11 years. With less than 5 kg of cartons, paper and bubble paper used per year for all my items, I am forced to pay disproportionate sums (already the case for France and Germany). And what will happen to my US, English and European suppliers of raw materials... Will they follow laws or boycott shipments to Europe?

Filed in French · English published by the European Commission

One of the EU’s principles is that trade can operate in the single market without barriers and barriers. It is not economically viable for a micro-enterprise such as myself to be represented by an authorised representative in each Member State. The costs would be many times higher than the average yield.

Filed in German · English published by the European Commission

**Subject: Proportionate duty of attorney under the PPWR** Dear Sir/Madam, as the owner of a family-run production unit with connected online sales, I would like to draw your attention to a significant burden arising from the PPWR for small and medium-sized enterprises when selling cross-border: the obligation to appoint an authorised representative for the extended producer responsibility in each Member State…

Filed in German · English published by the European Commission

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

VTH Verband Technischer Handel e.V. represents medium-sized wholesalers in Germany and Austria who supply industry, crafts and maintenance with technical products. Many member companies supply packaged goods across borders to commercial resellers and industrial end-users. We welcome the objective of harmonising registration and reporting under Article 44 PPWR. However, a common data format alone is not enough.

Filed in German · English published by the European Commission

Ladies and gentlemen, we would like to highlight a significant practical problem in the implementation of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). We are a small and medium-sized enterprise in Germany. The two owners are fully involved in the day-to-day business; there is no separate legal or compliance department.

Filed in German · English published by the European Commission

We do not call for the abolition of the PPWR We want to make it explicitly clear: We do not call for the abolition of environmental protection. We also do not call for a return to unnecessary single-use packaging or irresponsible use of resources. Rather, we call for a realistic and SME-friendly implementation of the PPWR. Therefore: 1. A genuine SME exemption or simplified rules (e.g.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a company according to the European SME definition, we would like to draw attention to a critical point in the implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales. For G. Retail GmbH, intra-EU trade is an important component of the internal market.

Filed in German · English published by the European Commission

As the founder of a micro-enterprise based in the EU (The Netherlands) that sells and ships physical goods directly to consumers across the Single Market, I support the goals of the Packaging and Packaging Waste Regulation (PPWR) reducing packaging waste and building a genuine circular economy are objectives I share.

I am the owner of Nox K-Pop Shop, a small retail online shop based in Italy specialized in K-Pop and Japanese goods. The new EPR regulations enforced starting from Aug 12th are making it extremely difficult for small businesses to continue shipping outside of their own country.

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a particularly problematic issue in my view regarding the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for EPR in cross-border sales within the EU.

Filed in German · English published by the European Commission

Ladies and gentlemen, EU rules have already been adopted in recent years, which impose an immense bureaucratic burden on sole traders, on self-manufactured products and on a few or no employees such as me. At the beginning of the year, I told customers abroad about the promised facilitation of the Packaging Act and the requirements for shipping abroad. That’s how I listened to drafts.

Filed in German · English published by the European Commission

Ladies and gentlemen, I would like to draw your attention to the significant economic impact of the PPWR and in particular the obligation to appoint authorised representatives in individual EU Member States. We are a company with ** more than 10 employees and more than EUR 2 million annual turnover**.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

For me, as a small entrepreneur, selling abroad in the EU has so far been an obvious step forward without a legal department of my own, but with the aim of complying with the law in force. The PPWR significantly changes this invoice: Once I sell goods to another Member State, a single sale may trigger the obligation to appoint and pay for an authorised representative there.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, let’s finally work easily. There is an ever-increasing economic run-off here, and what comes from politics only feels more laws, more regulations and even more bureaucracy. And please: Before launching the next law, simply TAKE briefly beforehand how this will work in practice.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

As much as I understand the idea behind it, its hard to fathom how the implementation could be so disastrous. How out of touch with reality must one be to believe that this law will move things in the right direction? The outcome is already predictable. The many small European businesses will disappear from the market, and what will remain is a flood of goods from Asia.

Good afternoon, as a sole trader with small online sales, I would like to draw your attention to a problem with the PPWR producer register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales. This means for me, as an absolute small business, that from 12 August I will pay EUR 300 per year per EU-COUNTRY, including notarial costs.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and Gentlemen, We operate a non-profit association in Austria and sell handmade products, inter alia, through an online marketplace. We send 35-40 parcels to another EU country, Germany, in the course of the year. Our turnover from this country is just under EUR 900 a year. Registration and authorised representatives in Germany are expected to pay EUR 250-300 per year.

Filed in German · English published by the European Commission

Ladies and gentlemen, but I can understand your fears about the large quantities of cardboard and other shipping materials. They are destroying smaller traders, as I am one. We simply do not have the financial resources for each country to license. I have now had to pay 1500 for Denmark, for example. Only that I am licensed there until the end of the year with an authorised representative.

Filed in German · English published by the European Commission

Complaint to the European Commission Subject: Regulation (EU) 2025/40 (PPWR) imposes a disproportionate burden on micro-enterprises as a result of the cross-border obligation to appoint EPR representatives and the loss of turnover that has already occurred.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small business, I would like to draw your attention to what I consider to be a particularly critical point in the implementation of the Packaging Ordinance (PPWR): the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border sales within the EU.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a medium-sized company with pan-European distribution, we would like to take this opportunity to draw attention to what we consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

As the owner of a small business in the EU, I generally welcome the idea of environmental protection and consider sustainable action to be a matter of course also as an active part of German entrepreneurship, where you are already prepared to face numerous bureaucratic and economic challenges. However, in its current form, the PPWR breaks almost completely the economic genocide of small businesses.

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 an issue of the planned implementation of the PPWR producer registers which I consider to be particularly problematic: 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 businessman, I am very worried about what the new rules on packaging registration mean for small businesses. I understand that packaging and its disposal must be regulated and I am ready to contribute to it.

Filed in German · English published by the European Commission

I am the owner of a small UK online business selling to EU customers. I fully support the aims of the PPWR and believe businesses should contribute appropriately towards the packaging they place on the market. My concern is the practical impact on microbusinesses undertaking low-volume cross-border trade.

The obligation to appoint an authorised representative is a completely overpriced measure that poses major financial challenges, especially for small distributors and manufacturers! It always means cutting red tape?! Further bureaucracy is being built up here, at the expense of small businesses! Why not appoint an authorised representative for the EU as a whole?

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online trade in products from my own manufacturer, 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, as a small e-commerce operator, I would like to take this opportunity to highlight two points that I consider particularly critical in the planned implementation of the PPWR Producer Registers: the obligation to appoint an authorised representative for extended producer responsibility in cross-border sales and the obligation to register in each EU country, which creates disproportionate…

Filed in German · English published by the European Commission

As the founder of Sashe, a Slovak online marketplace for local and handmade products, I would like to share, we understand the need to reduce packaging waste, increase recycling and establish clear responsibility for packaging across the European Union. However, we are deeply concerned that the current approach may place a disproportionate administrative and financial burden on micro and small businesses.

EC and EU governance has proven once again it's bureaucratic, anti-business DNA. There is proverb , very adequate saying that such actions are like burning the whole bedroom because one bug in the bedsheets. Small, independent operators and entrepreneureal independent demographic layer has been punished by utterly inappropriate and unpropprtional measures.

Feedback on the implementation of the PPWR Extended Producer Responsibility and Authorised Representatives We fully support the objectives of the PPWR. Extended producer responsibility for packaging is sound in principle, and we see little disagreement about this among actors along the value chain. Our concern is not the substance of the obligations, but the way they are to be implemented. 1.

I operate with Aquakallax a very small German company that manufactures and distributes self-developed products for aquaristics through an online shop. To date, I have also supplied customers in other Member States of the European Union.

Filed in German · English published by the European Commission

We are a GbR with 2 people in the photography field and feel disadvantaged and excluded from the EU market. We do not even have the opportunity to increase our reach and make ourselves visible, as high fees already apply before the first possible order. In particular, it is not financially feasible to appoint an authorised representative in each EU country. Quite apart from the enormous amount of work involved.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as a small e-commerce company, we would like to draw attention to a significant practical problem in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in each EU Member State for cross-border sales. Selling to other EU countries is an important way for small businesses in particular to reach new customers and develop.

Filed in German · English published by the European Commission

I am the owner of a small Czech online antiquarian bookshop. I only send a small number of orders abroad, with Slovakia being by far my most important foreign market. I am currently trying to find out how to comply with the new requirements in Slovakia. I send only a few dozen orders to Slovakia each year, and the amount of packaging I place on the Slovak market is well below 100 kg per year.

Hello. We have a very small company selling our bands t-shirts, CDs, vinyls etc and we have just started out last year. We send 0-10 shipments a month, depending if there are new products. We are looking to grow we have fans from several EU countries, where we have also played concerts and who are looking to buy from us and support us.

As the owner of a small e-commerce business in Germany, I want to raise a concern about the PPWR. The extended producer responsibility requirements now imposed are neither financially nor administratively feasible for a small business like ours. As a result, we have had to stop shipping to most EU countries entirely. This costs us not only current revenue, but also future growth markets we can no longer even test.

European packaging policy has now reached a level for small traders that has little to do with proportionate environmental policy. It is becoming a bureaucratic and cost machine which is damaging to the European single market. I operate a small online retail business in Germany.

Filed in German · English published by the European Commission

I am a micro-enterprise in the Netherlands, one tabletop game shop with a webshop, under ten staff. This draft harmonises the registration and reporting duties that, at my scale, will stop me selling across borders. SOLVIT case 6880/26/NL is open on the same facts. MY NUMBERS Complete trading history, 28 Nov 2025 to 12 Aug 2026. 271 parcels, 149 domestic, 122 across a border to 20 countries.

I have a small 3D printing business in Germany and I occasionally sell abroad in the EU. In the case of relatively small transactions, it is not worthwhile for me to appoint an authorised representative in each country. The cost of doing so exceeds the turnover/profit. With the new PPWR, I now have to stop selling to the EU. Once again, that made you super! Now I have to slowly vote for the AfD...

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to 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. Selling abroad in the EU has been an obvious growth step for me as a small entrepreneur.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of an online trade in weighing scales and weighing technology, I would like to draw your attention to a particularly critical point in our view regarding the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as a micro-entrepreneur without an employee engaged in small online commerce, I would like to take this opportunity to draw attention to an aspect of the PPWR which I consider particularly problematic: the obligation to appoint an authorised representative for the extended producer responsibility for cross-border shipments within the European Union.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a small manufacturer from Germany with an online shop and shipping mainly within the EU, we would like to draw attention to a number of critical points in the implementation of the producer registers under the EU Packaging Regulation (PPWR): the obligation to appoint an authorised representative for the extended producer responsibility in each destination country in the case of cross-border…

Filed in German · English published by the European Commission

Opinion on the draft Implementing Regulation concerning national registers of packaging producers (Initiative 15352 Packaging and packaging waste rules on national registers of producers) Sir/Madam, I am Paweł Jakub Górecki and I am self-employed under the name Rotten Factory.

Filed in Polish · English published by the European Commission

As a small building brick reseller which goes under a micro enterprise and can just make enough money to keep life going. I fear this will kill my business and my livelihood. I ship to EU country's because of the free trade but cant afford any agents or added costs. I don't want to grow bigger, can't even, and I'm at a loss what to do here.

I am writing as a artist based in Cyprus who sells small quantities of original artworks and prints directly to individual customers across the EU. I strongly support the objective of reducing packaging waste and ensuring that producers contribute fairly to recycling costs.

I understand that things needs to be changed about how we deal with packaing and waste, BUT the new regulations that were added on August 12 might have just killed my business indefinitely. I'm a one person business on Etsy, I sell art prints, stickers, handmade items. If I'm lucky I get 100 orders a year, and my income from this business is very small.

It is prohibitively expensive for the small firms and commercial individuals that sometimes send goods abroad to Europe as shippers. Europe should grow together and not destroy the entire trade in goods between small firms through immensely expensive regulations. Cutting red tape therefore only sounds like a farce!

Filed in German · English published by the European Commission

When we separate our garbage for recycling, most EU waste management mixes it in the same bloody garbage truck. You're just doing this for the money, yes? No way you care about recycling. If you did, you'd implement recycling plants and systems instead of sending our garbage and millions of euros to third world countries.

Opinion on PPWR implementation (register of producers/authorised representatives) The current design of the registration and authorised representative obligations under PPWR creates a regulatory burden that threatens the existence of micro, small and medium-sized enterprises (SMEs). The fixed costs per Member State are disproportionate to the amount of packaging and lead to a barrier to entry. 1.

Filed in German · English published by the European Commission

The original idea behind the new Packaging Act represents the right approach and is sound in principle. In my view, serious consideration should be given to exempting micro-enterprisesat least in partfrom the requirements for implementing and complying with the law.

As a micro business online I can't afford to pay a representative. I can't separately register for 27 countries. I can't afford to pay the licensing fees. I had to stop selling to the EU altogether. While much larger businesses can afford the fees and find ways to overcome the regulations, my business is shut out. I can buy from Europe but Europe can not buy from me.

Ladies and gentlemen, I operate an antiquaria. 70 % of my turnover comes from mail order. Shipping to other EU countries is an existential thing for me. But I cannot register and license in any country. On the one hand, the burden is too high and, on the other hand, the costs are disproportionate to the profit made.

Filed in German · English published by the European Commission

Ladies and gentlemen, I have a small online business and would like to use the consultation to draw attention to an aspect of the planned PPWR producer register that directly concerns me: the obligation to appoint an authorised representative for the extended producer responsibility for sales in other Member States.

Filed in German · English published by the European Commission

Your letter has a strong personal perspective and a clear central argument. I would mainly tighten the language, make the economic argument more precise, and soften a few phrases so that the Commission is more likely to focus on your substantive request rather than the tone. Dear European Commission, Thank you for giving me the opportunity to comment on the Packaging and Packaging Waste Regulation (PPWR).

We support the fundamental objectives of the PPWR: We believe it is right and necessary to save resources, reduce packaging waste and strengthen the circular economy in Europe. However, we firmly reject the PPWR in its current form and in particular in its practical implementation. As a medium-sized distributor of cosmetic packaging, we are directly affected by the new requirements.

Filed in German · English published by the European Commission

I am the owner of a very small, one-person handmade business in the EU. I fully support environmental protection and the reduction of packaging waste. However, I am concerned that the increasing number of regulations, administrative requirements and fees related to packaging are becoming disproportionately burdensome for micro-businesses.

I am writing to express my serious concern about the impact of the new Packaging and Packaging Waste Regulation (PPWR) on small businesses. As a small business owner in Germany, I understand and support the need to reduce packaging waste and protect the environment. However, the current requirements are creating a level of registration, reporting, and fees that many small businesses simply cannot manage.

Ladies and gentlemen, as European e-commerce companies, we support the PPWR’s objective of reducing packaging waste, improving recycling and ensuring that producers pay a fair share of the actual disposal costs. However, the planned implementation risks creating significant red tape and costs without creating corresponding environmental added value.

Filed in German · English published by the European Commission

You are killing small businesses that only manage to make a living because they can sell through Europe. You are completely disproportionately impacting small creatives while big conglomerates will barely feel the effect. Get your act together. If you really care about the environment do something about CO2 and data centers. This is absolutely ridiculous.

Bureaucracy instead of relief in times of economic hardship The Chamber of Commerce and Industry (Cottbus Chamber of Commerce and Industry) criticises the complex requirements and the increase in bureaucracy brought about by the new European Packaging Regulation 2025/40.

Filed in German · English published by the European Commission

I reject the planned form of the additional registration and administrative obligations under the PPWR in this form. I am selling online in Germany and I want to expand my business further in the coming years and to sell more of my products to customers in other EU Member States. It is precisely for this purpose that the European single market should create ideal conditions.

Filed in German · English published by the European Commission

It's pretty simple. If we have to pay a subscription fee on a yearly basis, find representatives, do tons of paper work, check each country separately and their regulations, and pay in total 17 000 euros a year to cover all 27 EU countries then it makes EU zone horrible for a business. If I make 3000 euros a month, then it makes my business useless.

Dear European Commission, I am writing as the owner of White Russian Records, an independent record label based in the Netherlands. First of all, I want to express my support for the goals behind the new packaging regulations. Reducing waste, encouraging recycling, and limiting unnecessary plastic use are important objectives that I fully support.

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

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

Ladies and gentlemen, my name is Aleksandra and I have a small jewellery label in Austria for 6 years. Since November 2024, however, I have been living on it only because I also send my jewellery outside Austria. Every year, around the 100 parcels, I send all the environmentally friendly packages to Germany in order to protect the environment. I have also re-used small cartoons.

Filed in German · English published by the European Commission

Dear Sir or Madam, I am the owner of a small handmade business based in Greece, which sells its products directly online to customers throughout the European Union. I am writing because the implementation of the PPWR makes it unfair for a micro-business like mine to continue selling throughout the EU. I already pay separate EPR registration and compliance costs in the Member States where required.

This is the death of EU small businesses, like mine. Ive been working for a few years, have my business growing, paying all taxes, and now EPR, PPWR, WEEE representation EPR fees are becoming unbearable for me and other small business. Why couldn't this system work like OSS VAT? I just declare sales to EU countries and pay taxes to the one account.Without any complicated and expensive EPR in each EU member state.

Dear Feedback Reader, As someone who is planning to open a small handmade shop in Malta, I am honestly worried about how these new packaging rules could affect my business before it even has the chance to get started. I completely understand the environmental reasons behind these regulations, and I support reducing waste and encouraging better packaging.

For small businesses like us, this regulation is a KO. We imported from the US, which we sell all over Europe. With this regulation, we are no longer able to do so. According to authorisedme.eu, the cost per EU country is 199 service fee plus 75 per year in the smallest package. We are currently sending in 14 countries in the EU. In some, only 1-5 consignments per year.

Filed in German · English published by the European Commission

Porth Realms is a micropublisher producing shortrun tabletop games and accessories. We support the aims of Regulation (EU) 2025/40, but the proposed Implementing Regulation places a disproportionate burden on businesses of our size. The reporting and registration format assumes resources, technical knowledge, and administrative capacity that microenterprises simply do not have.

I am the owner of a micro-business in Sweden, manufacturing my products myself and selling directly to consumers. One of the great advantages of the EU Single Market has been that even a one-person business can reach customers across Europe. The implementation of the PPWR risks changing this.

As a small entrepreneur and mother who simply tries to secure a small income, this is another rule that makes everything even more difficult, and one really wonders whether all this still makes sense. We all understand the intention and background of the action, but there should definitely be a rule here that excludes companies below a certain turnover.

Filed in German · English published by the European Commission

Although the intention is good, implementation is very bureaucratic – and very expensive for companies that supply Europe-wide, but only sporadically! It would be preferable to have one representative for the EU as a whole. After all, in the long term, we want to remove all barriers and obstacles to trade in goods. However, this only creates new problems. Small-scale state-building will only be re-energised. Bitter!

Filed in German · English published by the European Commission

I am a small business sole trader in UK shipping vinyl records, and making small runs of vinyl records in UK and EU. Our associates in EU that distribute, sell etc with small shops and micro production are now at risk as they can no longer ship small vinyl runs and orders across EU bordersand this initiative has stopped me from being able to ship to EU as we only ship 3-30 packets a year to each country - the cost…

Dear Eu. Year and half ago I started making dolls. Took some time before I could sell them. I had to learn a lot. Right now I sell 0-2/ month. I have a day job but I always dreamed of being able to earn money by art I make. Although it costs a lot of money, I pay taxes, fees, have tax id.. I try to do everything the right way. But all that already costs me 25% of the money I make.

I am a small online shop operator and we have stopped shipping to the EU. The current rules effectively exclude small and medium-sized enterprises from the EU market. This is exactly the opposite of what the EU should be. Although we already have regular orders from abroad in the EU, there are only a few hundred to a few thousand euros of turnover per country/year broken down by country.

Filed in German · English published by the European Commission

I am writing from the perspective of a small EU-based online retailer. We fully support the environmental objectives of the PPWR and the principle that businesses should contribute to the collection and recycling of the packaging they place on the market. However, the current approach to producer registration and EPR risks creating a serious barrier to cross-border e-commerce for small and micro businesses.

I am a micro-business owner and through this regulation, my business within the EU has been destroyed. I earn about the average wage in my country and if I had to comply with these new rules, I would not be able to afford to run my business let alone to live. All of my proceeds would go into complying with these regulations and paying for the bureaucracy of them.

We are a small company from Germany and have a very small volume of parcels within the EU. The costs of an agent and the administrative burden under the PPWR Regulation are disproportionate to our revenues from the EU, so we can no longer offer shipping in the EU. Truly sad that the small ones have not been taken into account in the scheme and that only large suppliers are allowed to participate in the EU market.

Filed in German · English published by the European Commission

Dear European Commission, As an artist and crafts woman running a EU based for business for 20 year the new regulation is bureaucratic and financial disaster for mico-buisnesses across the field. I run an artist/craft studio with no online shop and mainly work with galeries (b2b), however customers and prospective clients sometimes ask me for personal commissions of my designs.

Hello feedback-reader, As a small business who just started selling her jewelry, this law makes growing my business very complicated. I do understand why these laws should exist and I am super pro-environment conscious choices but this will affect so many independent/small business who really, are not the problem in my opinion.

PPWR and EPR requirements are disproportionately burdensome for micro-businesses and independent artists. I am a self-employed artist and the owner of a one-person micro-business in the EU. I have spent the past year preparing to launch my business, selling my own original artworks and art prints directly to individual customers in Poland and across the EU.

While I see the general objective of the initiative, I would nevertheless like to express my concerns from the point of view of a small handmade company. I use approximately 95 % of already used cartons for shipping my products and thus deliberately redirect packaging material to further use.

Filed in German · English published by the European Commission

Dear Sir or Madam, I am a Finnish artist and small business owner. I have worked in this field for over 20 years, producing art and small-batch work from my own studio in Helsinki. My business is a typical EU microenterprise: one person, modest turnover, no legal department and no budget for outsourced regulatory expertise.

I'm absolutely in favor of reducing packaging and waste. I'm a microbusiness that works with cardboard, and I often reuse packaging to ship my products, to avoid creating new packaging. This new European Union law profoundly harms small businesses around the world, which don't have the same resources as large companies to meet the new requirements, materials, certifications, compliance, and bureaucracy that has…

We are all in favour of reducing waste and promoting more environmentally friendly recycling programmes. The major problem, however, is that although this is EU-wide legislation, each member state implements its own scheme, registration requirements and charges separately.

We support the objective of a single harmonised data format. However, the draft harmonises the paperwork without touching the structure that makes it unmanageable for small businesses. Registration and reporting remain national: a separate registration, a separate producer identifier, a separate portal, a separate fee schedule and, in many cases, a separate authorised representative in every Member State we ship to.

| No EU sales > No EU sales tax > No EU tax revenue!| Dear European Parliament, reducing packaging waste is, in itself, a very good idea, but the PPWR in its current form is a disaster. We small businesses are already cutting back on packaging because packaging materials cost a lot of money! For example, I have small boxes custom-made that are just big enough to fit a DHL/UPS label!

Hallo liebe Entscheider:innen, Ich betreibe ein kleines Gewerbe, nur lokal mit Geschäftsräumen, kein Webshop, trotzdem kommt es vor, das mich Kunden und Interessenten bitten, ein oder mehrere Produkte zu versenden, dies sind teilweise für mich erhebliche Umsätze, die nun unmöglich werden. Bitte überdenken sie das neue Gesetz und bessern sie nach!

This legislation NEEDS an exemption for small/micro businesses. Im a small businesss selling maybe 5 packages per year across the entire EU, i am the ONLY employee, and yet im subject to the exact same expensive fees & headache of a registration process for *every EU country- all 27 of them SEPERATELY* while some of these countries have vastly different compliance needs and often dont have websites in english im…

| No EU sales > No EU sales price > No EU tax revenue! | love EU Parliament, reducing packaging waste as such is a very good idea, but the PPWR in its current form is a catastrophe. We are saving small businesses on packaging anyway, because packaging costs the right amount of money! For example, I have such small boxes made for me that a DHL/UPS label still fits in! The filling material is jewellery paper!

Filed in German · English published by the European Commission

I run a one-person business in Dublin, Ireland, selling pre-owned and vintage collectibles. Almost everything I sell is second-hand. It already exists, and my job is keeping it out of landfill and in circulation. I say that first because I am not against recycling or producer responsibility. My business is the circular economy working at street level, with no subsidy.

I am a small game developer from Germany with an online shop where I sell (or more realistically "sold") merchandise for my games across the EU. In no way, shape or form is this new regulation feasible for any kind of micro-business. The cost and maintenance to comply to all these regulations outperforms any potential income I would generate through selling to EU nations.

I have been running my small label ShaliSari successfully for 20 years. In my studio in Germany, MIR ALLEIN produces beautiful hand-made dance costumes for BellyFusionDance. I sell enquiries via online shop in Germany and via Instagram in the EU, Japan, Australia... The USA has already broken me off in terms of turnover...

Filed in German · English published by the European Commission