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

Ares(2026)8029651 - 20/08/2026 PPWR: Die EU darf Kleinstunternehmen nicht aus dem BinnenmarktRef. regulieren Sehr geehrte Europäische Kommission, wir wenden uns mit großer Sorge an Sie! Wir sind ein Kleinstunternehmen Barre Products und Hersteller von Nahrungsergänzungsmitteln.

Filed in German · English published by the European Commission

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

I work as an accountant and consultant for small business owners, and also rum an association that helps small entrepreneurs , especiall those in fragile situation. While I love our planet and support the recycling effort, the PPWR regulations at the moment are unsustainable for small creators. The burden both finalcially and administratively is way too high, and the impact on info will be catastrophic.

I soon have a micro company registered as I am developing a new solar driven water heater and plan to sell all over Europe. I have no funds to cover the 3000 fees for packaging waste registering. Please implement a micro company exemption and put a moratorium on current rules. I might have to close my project otherwize.

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

Filed in German · English published by the European Commission

As a small trader who also sends small quantities of his goods to other Member States of the European Union, I would like to express my deep concern about the increasing bureaucratic and financial burdens resulting from the new packaging requirements. In principle, I support the objective of making packaging greener, promoting recycling and making producers more accountable.

Filed in German · English published by the European Commission

I run a small one-person jewellery business based in the UK, creating pieces inspired by Kazakh and Central Asian culture. I may receive only a few orders per year from some EU countries, yet I can still be expected to deal with separate registrations, fees, reporting requirements and, in some cases, local representatives.

PPWR Stellungnahme Stellungnahme zur öffentlichen Konsultation Initiative: Verpackungen und Verpackungsabfälle — Vorschriften über nationale Durchführungsrechtsakts zu Art. 44 Abs. 14 der Verordnung (EU) 2025/40 (PPWR) Ref.

Filed in German · English published by the European Commission

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

Our business mainly sells on the Big markets DE and IT. However we do make a profit of 400-1000 Eur per year inside the next 5 markets such as NL BE FR ES SE. And we for the last around 20 countries we make small profit of around 100-200 eur Per Year. With this destructive law it means we have to pay on top of the Packaging Waste fees - AR fees 150-300 eur per coountry. And this is only for the packaging category.

As an independent artist running a small stationery shop with a very limited number of sales per year and only a handful of orders in individual EU countries, I believe the new packaging regulations place a disproportionate and unrealistic burdenboth financial and bureaucraticon micro businesses.

What do you do? First, Trump’s removal of the de minimis rule deprives my handmade glass beads business of all US customers, leaving almost only the EU as a market, and now I also have to pay extra costs and make a lot of effort for all that administration on an EU country basis. 1 shipping a sale of EUR 32 already gives shipping costs of EUR 11 with minimal margin.

Filed in Dutch · English published by the European Commission

If you want the European single market to cease to exist. Congratulations: And in this they succeeded. This makes the EU obsolete as an economic community! These rules destroy livelihoods and create economic weakness. What then follows has often been observed in history.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

As manufacturers of packaging, we fundamentally support the objective of the PPWR to harmonise packaging requirements within the European Union and promote a functioning circular economy. However, from the point of view of an industrial packaging manufacturer, we see significant challenges in the practical implementation.

Filed in German · English published by the European Commission

I am a sole self-employed craft business based in Spain, selling handmade jewellery online. I support the environmental objectives of the Packaging and Packaging Waste Regulation and I fully agree that businesses should contribute fairly to the management of the packaging waste they generate.

Congratulations! You managed to do it again! Destroying the entire European single market! How to think of scrap?! We have now stopped all exports. Thank you for that! This definitely costs a few jobs! Sooner or later, the EU will completely ruin us with your senseless, impractical and absurd bureaucracy! Do you really have any qualifications to see what impact your decisions have on the economy?

Filed in German · English published by the European Commission

Very simple. From now on all trade with other EU-countries are stopped. My small business cant motivate the very time- and money consuming work to register i each country I would like to send a single book to. Not mentioning if I have to pay for a legal entity to handle it for me. This is very non-EU. See to that, at least for very small companies, there is a common registration for all of EU.

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

Dear, We are a small owner-run company that sells water sports accessories. Last year’s annual turnover was approximately EUR 600.000. In various EU countries, the proportion of turnover is between EUR 300.000 and EUR 50. Registration (not the actual taxes) costs around EUR 500 per EU Member State. In our return calculation, therefore, registration will only be worthwhile if registration costs are more than earned.

Filed in German · English published by the European Commission

In addition to our activity as a craftsman, we also sell goods via a sales platform. As these are mostly rare individual pieces, it is already a tremendous effort to insert the parts with all the necessary information. So far, we had offered these parts for the whole of the EU – the parts are constantly going to a wide range of countries.

Filed in German · English published by the European Commission

As a small trader – a ceramicsman who develops single-piece handicrafts – it is simply unthinkable how it is possible after the entry into force of these rules to survive and sell their products to other countries. How can we pay for packaging taxes in all European countries, even when earning an average salary? NOT AT ALL. It is unfortunate that fewer businesses and artists in particular are being disrupted.

Filed in Lithuanian · English published by the European Commission

The new rules on packaging and packaging waste are a complete disaster for small businesses. Yes, there are businesses much smaller than 10 employees and 2 million Euros annual turnover. I am running my business all by myself and it just about gives me enough of a result to make a living.

I am a very small specialist music publisher. With this perhaps well-intentioned regulation, you are preventing the distribution of cultural goods. I had imagined the European Union differently: Open borders, free movement of goods, uniform and comprehensible procedures for all Member States. Please refer to the attached pdf for details.

Filed in German · English published by the European Commission

The planned national registers of producers will lead to additional bureaucracy, multiple registrations and higher costs for businesses. A particular problem is that establishments need to comply with different national requirements when trading cross-border in several EU countries. This runs counter to the objective of a single European internal market.

Filed in German · English published by the European Commission

We are a small company in motorcycle accessories. The shipment is international. With the rules, I would have to bear an annual cost of more than 4000.- not to cover all quantities per country. If there is no simple solution, we will stop shipping within the countries concerned. Everyone is willing to contribute, but this should depend on the size of the business and turnover.

Filed in German · English published by the European Commission

Dear Sir/Madam, As a small e-commerce business owner, I am writing to express urgent concern regarding the implementation of the Packaging and Packaging Waste Regulation (PPWR) specifically the obligation to appoint an Authorized Representative (AR) for Extended Producer Responsibility (EPR) when selling cross-border. Under the current setup, AR requirements generate fixed, non-scaling costs per country.

I am a micro-entrepreneur (artisanal craft) with a very small turnover and tiny shipping boxes. Nevertheless, I have been registered with the Green Point in Germany for years. And yes, I think it is very important that packaging waste is reduced as online trade grows. But what has now been decided is not financially viable for me, not to mention the bureaucratic burden.

Filed in German · English published by the European Commission

We are a small family company from Latvia. Our business is oriented entirely towards the common European market, through stores like eBay and the like. Our business is closed. 3 families were left without a livelihood. The new regulation increases the price of each of our products by 21.03 euros. And we make a net profit of 15.20 euros per product. Europe is no longer a good place for us to live.

This is the complete destruction of small business. I only send a few shipments to certain European countries, and I can't even predict how much I'll sell in each one. If I have to purchase this representation, I will simply have to close down because it means complete financial bankruptcy.

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

For many years, we have been delivering our musical notes to customers across Europe. For us, the EU single market has been a great success: a common economic space without borders and unnecessary barriers, where small specialised companies could also reach customers in all Member States. This is now over for us. We have stopped shipping to customers in other EU Member States.

Filed in German · English published by the European Commission

The proposed packaging waste system is not sufficiently adapted to the reality of small businesses and micro-enterprises operating across the EU. As a small business selling handmade products online to customers in different EU countries, I find the new requirements disproportionately complex, costly and administratively burdensome.

Hello, I and many other solo business entrepreneurs in France do not understand what is being proposed. The mechanism for sharing this information is not robust, many people in a Facebook group I belong to for female business owners in France did not know anything about it. I use entirely recycled packaging to pack the 30 second hand goods I sell on a global online marketplace each year.

an unbearable burden for a small business. sometimes I don't sell a single item or I sell only 1-2 items to a European country per year and a fixed fee of 200-800 euros just for the opportunity to send to that country is inadequate. I only sell 0-3 items of super small items to each EU country per year and the fees requested are enormous. small businesses deserve exceptions

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

Filed in German · English published by the European Commission

Dear Sir or Madam. The current packaging rules place a disproportionate burden on micro-businesses. We are a two-person family business receiving only a few orders per year from each EU country. Requiring separate registrations, fees, reporting and potentially representatives in every Member State makes no financial or practical sense.

This does not work at all, costs far too much and some countries still have non-usable portals for registration. The obligation of an authorised representative ultimately makes it impossible. The only alternative would be a portal for reporting for all countries and payment to an account from where it is then distributed, basically in the same way as OSS VAT returns.

Filed in German · English published by the European Commission

The rules are once again as blooming as then the GDPR (not misunderstood, I am not against data protection, privacy or now also sustainability). Some laws are adopted without specifying what this means and how they are to be implemented in the real world. Regulations enter into force and, with a few exceptions, no country is prepared for them. No one knows what it is, it is almost impossible to obtain information.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a small 1-man online trader with only sporadic orders from other EU countries, it is completely uneconomical and organisationally impossible to conclude a separate waste disposal contract for each EU country. As much as I can understand your efforts, I must nevertheless inform you that EU trade will become impossible for me.

Filed in German · English published by the European Commission

I import and sell high-quality, low-volume Japanese artisanal goods to customers across the EU, and I am writing to say plainly that the PPWR, as implemented, is destroying small businesses like mine. The Regulation was justified as a single-market measure, yet it has left me facing separate registration, separate declarations, separate deadlines and separate evidence files in every member state I sell to.

Im a sole trader running a small handmade jewellery business from Cornwall, UK every piece made by hand, sold through Etsy, Folksy, my own shop and Faire, using minimal, recycled cardboard packaging. The extended producer responsibility (EPR) rules for packaging under PPWR make cross-border EU sales unworkable for a business my size.

I am a sole trader (small e-commerce) As a result of the obligation to appoint an authorised representative for Extended Producer Responsibility (EPR) in cross-border sales, I have on 12 August. All EU countries (except D) blocked as supplier country. This is completely at odds with the EU’s free internal market! This authorisation for each EU country is not financially viable for small traders.

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 serious point in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales. For small online traders, selling to other EU Member States is an important part of the single market.

Filed in German · English published by the European Commission

Ladies and gentlemen, "I am not really able to do this anymore. I am already struggling with CE, WEEE, the old Packaging Regulation, the Duales System, etc. I fully support the objectives. Unfortunately, in this sense, I am also a first-time distributor in the EU, but I also sell my products directly. Nevertheless, I am a mini-company. I am a one-person company.

Filed in German · English published by the European Commission

I am shocked to see the new legistlation. I am a Hungarian-Swiss new small business owner. My companyi s based in Switzerland but I intended to create an affiliation for the european market for my european consumers. I am launching this October/ November and now remaking my strategy to avoid all EU countries sales as I cannot unfortunately afford nor a legal representative nor paying high fees in 27 countries.

Our company was founded in 1990, employs between one and five permanent employees, and since its creation has successfully trained 17 young people in various commercial professions. The requirements of the PPWR pose significant economic and administrative problems for our direct cross-border sales to end-customers within the EU.

Filed in German · English published by the European Commission

I believe that the system currently being developed is not well suited to small businesses, particularly those that sell in small quantities and ship their products to different EU countries. For a small business, taking responsibility for packaging is not the difficult part.

EPR rules are disproportionate for micro-businesses I run a one-person micro-business in Lithuania selling handmade linen home textiles across the EU. I fully support EPR and paying for the environmental impact of the products and packaging I place on the market. However, the current system is becoming disproportionate for businesses of my size.

We have just established the business less than a year ago. Everything has been planned based on the EU wide market research and presence. It is extremely difficult to start a business from zero with these requirements. I understand the rules when business and turnover reach a level where it is possible to pay the fees.

The current packaging regulations impose an entirely disproportionate financial and administrative burden on the smallest enterprises. Many of us operate as one-person businesses receiving only a handful of orders per year from various EU Member States.

We are a family business in Lithuania. We make steel shelf brackets in a small workshop and sell them online to customers in about 17 countries. This has been our income for years. This act should not be adopted in this form. To keep selling into another EU country we would need to register there and pay an authorised representative in that country.

Clearly no consideration has been given to micro or small businesses within this new regulation. As a small business, this regulation completely stops me being able to sell to other EU countries, because of the costs involved.

Ladies and gentlemen, as the owner of a small trading company in Germany, I would like to draw your attention to a significant problem in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border sales within the EU.

Filed in German · English published by the European Commission

Dear, We are a medium-sized weather forecaster and sell a unique product in Europe via e-commerce: a WetterDisplay that provides a live picture of weather trends on a large map at all times. We have been selling it since 2019, now in the 4th Generation.

Filed in German · English published by the European Commission

I'm an independent music artist releasing my first album on vinyl soon. Without an exception for micro-businesses like mine, I will make a substantial loss (both monetary and opportunity cost) on every single record I sell outside my own country. The risks, time investment and associated costs of complying with the new regulation are destroying my business before it can even start.

Ladies and gentlemen, I operate a small handmade business in Germany and sell through an online marketplace and my own website. I send 250 packages to 25 other EU countries each year. My turnover from these countries is EUR 7500. I am expected to pay EUR 6500 per year for registration and authorised representatives in these countries.

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 and my own website. I send 150 packages to 20 other EU countries each year. My turnover from these countries is EUR 8000. I am expected to pay EUR 6500 per year for registration and authorised representatives in these countries.

Filed in German · English published by the European Commission

Ladies and gentlemen, I am a sole trader without employees and send my physical goods exclusively with environmentally friendly shipping bags made of 100 % recycled cardboard and paper. I deliberately renounce plastic in order to protect the environment and facilitate recycling.

Filed in German · English published by the European Commission

I am a self-employed sculptor in Spain, working from home, and my only way of selling my work is online. Some of my customers are in other EU countries. The bureaucracy and costs involved in these new EPR requirements are simply unmanageable for a small artisan like me. There are many of us in this situation, and these rules could make it impossible for us to continue selling our work.

Ladies and gentlemen, we are a small online trader in the field of model railways. We delivered 191 parcels (less than 1 kg) to 21 EU countries in 2025. According to the calculation of a packaging licence provider, we would have to expect a cost of around EUR 8000 per year for these 191 packages.

Filed in German · English published by the European Commission

Dear Commissioner, I am writing to you not as a lawyer, lobbyist or representative of a large organisation, but simply as a European artisan and owner of a small handmade business in Germany. For many years, I have created handcrafted lampwork glass beads and one-of-a-kind glass jewellery in my own workshop. Every bead is made by hand in the flame.

Ladies and gentlemen, I run a small online business – and I had to stop sending me abroad in Europe for the time being, as it is not acceptable for me, as a sole trader, to appoint an authorised representative in each EU country. The financial burden is simply unbearable! That is absolutely impossible for me to do. I hope that this will be reconsidered and changed.

Filed in German · English published by the European Commission

It is quite clear these rules were created without thinking of the sole traders, small businesses that operate within the EU. These regulations as they stand place the same burdens of registration cost and compliance on the mega corporations as a single person operating a small business. The environmental impact of these 2 types of operations are clearly wildly different.

Ladies and gentlemen, as the owner of a small retail business, I expressly support the objective of a sustainable circular economy and the reduction of packaging waste. However, the designs of the national producer registers provided for under the PPWR have the very opposite effect of European free trade in practice: You are pushing small traders out of the EU cross-border market.

Filed in German · English published by the European Commission

Ladies and gentlemen, as founder of Chill n Feel, a small German family business, I would like to draw your attention to the significant consequences of the EU Packaging Regulation (PPWR) for small specialised providers and affected families. We develop and sell special companion clothing for babies and children with neurodermitis, highly sensitive skin and special medical needs.

Filed in German · English published by the European Commission

Hello, as the owner of specialised online sales of niche products, I fully support the basic objectives of the new EU Packaging Regulation (PPWR), in particular the prevention of packaging waste and the promotion of the circular economy. Micro and small businesses also want to play their part in sustainable action.

Filed in German · English published by the European Commission

As the owner of a stationary small business, I consider these rules to be completely unrealistic. The sending of parcels plays little role in my business; however, what is at issue here is the principle and fundamental freedom of action of small undertakings.

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 resulting burdens for small online traders. I have been a small online retailer in the field of handicrafts for 14 years, I produce all the products in my own name and also manage the online shop as a one-woman entrepreneur.

Filed in German · English published by the European Commission

Ladies and gentlemen, for many years I have been engaged in small online sales (currently no employees other than me) and I have specialised in the sale/trade of automotive spare parts for BMW Young and Oldtimer. For almost two years, I have also been increasingly using the European market, as it offers great potential for customers.

Filed in German · English published by the European Commission

I ship less than 10 orders to the EU in a month. Having to register in each country that orders would cost more than the value of the goods. Additionally I have always reused packaging, cardboard boxes, mailers etc. Rarely purchasing new materials for shipping, Compliance would be an impossibility adding more cost and waste to the process.

I support better recycling and reducing packaging waste, but the current system is far too complicated for small businesses. There should be one EU-wide system where a business registers once and that registration covers all EU countries. Reporting could also be done in one place, with packaging amounts assigned to each country.

As the owner of a small business with additional online sales, I must draw your attention to an impossible 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

Subject: PPWR-Manufacturers’ Register Mandatory representative for cross-border sales Dear Sir/Madam, as a family-run shoehouse with a small online shop, we would like to draw attention to a particularly critical point in our view in the planned implementation of the PPWR-Manufacturers’ Register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of…

Filed in German · English published by the European Commission

Ladies and gentlemen, we have been selling online on a small scale in Germany for many years and have regularly supplied customers in other EU Member States. We expressly support the PPWR’s fundamental objectives of reducing packaging waste, promoting recycling and ensuring that companies contribute adequately to the costs of disposing of their packaging.

Filed in German · English published by the European Commission

As a sole trader/micro company with an online shop with both purchased, imported and home-made products, the administrative rules and the additional costs related to the PPWR are not workable. 1. It is an EU rule, why separate registration with different fees in each country. 2. Why is everything placed in the user industry?

Filed in Dutch · 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 an issue of the planned implementation of the PPWR which, in my view, is particularly problematic for small traders: the obligation to appoint an authorised representative for extended producer responsibility in case of sales to other EU Member States.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of online sales which have hitherto been active internationally, 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

Sehr geehrte Damen und Herren, ich betreibe ein Handelshaus in Braunschweig (4 festangestellte Mitarbeiter) und Handeln mit Briefmarken und Münzen. Etwa 20 % des Umsatzes you Lieferungen in die EU, Tendenz steigend.

Filed in Estonian · English published by the European Commission

Yes. I would formulate this in a factual and clear manner, without exaggerating it. Importantly, you make it clear that the scheme is economically disproportionate for small businesses and, in the worst case scenario, forces you to stop supplying EU countries.

Filed in German · English published by the European Commission

Title/Subject: Alibi bureaucracy rather than real solutions: Why PPWR and national registers fail and how targeted research and foundations create real sustainability Dears and gentlemen, I use this consultation to point out a fundamental systemic error in the current EU packaging regulation. The structure of PPWR and national individual registers (such as LUCID, etc.) is nothing more than a futile alibi function.

Filed in German · English published by the European Commission

for years, if you set up your business as an individual fighter, you find a niche market and therefore customers around the world. Today, with one strike each EU costs around EUR 300 per year, plus enormous administrative burdens and red tape. Through one strike, this EU is destroying millions of people with the EU Packaging Regulation (PPWR), which an individual fighter cannot afford.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Hello, I would like to see a threshold for small businesses for each country in the future. For example, from the 50 or 100 pack onwards, you will first have to sign a contract in the country concerned. This will also allow small businesses to participate in EU trade. Or that there will be a one-stop-shop solution by being able to conclude a contract for several countries. Please also bear in mind the costs.

Filed in German · English published by the European Commission

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

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 an online small and medium-sized business, I would like to draw your attention to a critical 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

As a very small, one-person business selling handmade products online across the EU, I am concerned that the proposed requirements could create a disproportionate administrative and financial burden for micro-businesses. I may receive only a few orders per year from some EU countries, yet I could potentially be required to deal with separate registrations and obligations in each country.

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a particularly critical aspect of the planned implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales. For small businesses, sales to other EU Member States have been an obvious step forward so far.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Feedback on the PPWR: It is not feasible for (micro)enterprises Dear ladies and gentlemen, as operators of small online sales, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of…

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a particularly problematic point of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in cross-border sales in each Member State concerned. Selling to other EU countries is an important way for small businesses to enter new markets.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

As a self-employed micro-business owner in Lithuania, I fully support the objectives of reducing packaging waste and ensuring producer responsibility. However, the regulatory and administrative framework must be proportionate to the actual scale of a business and must take into account the specific situation of very small businesses and consumers in smaller EU Member States.

I send about 160 to 200 shipments per year to almost all European countries. If I had to go further, an intermediary company wants exactly 11,500 euros for the service of representing me, plus each individual recycling fee. There is one catch - in each country there is a minimum threshold and it doesn't matter if you sent 1, 5 or 10 shipments.

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

Hello, as an operator of a small online shop, I give up shipping abroad, as for me the bureaucratic burden and costs are disproportionate to the revenue. Badly, the idea of an EU and perhaps the future “United States of Europe” is different.

Filed in German · English published by the European Commission

For micro-enterprises, in particular solo self-employed, artists, creators and one-person companies, the PPWR obligations in cross-border trade are not just an additional bureaucratic burden. You can decide whether a company can still operate economically throughout the EU. I myself run a one-person company and operate a niche market with a community spread across Europe and beyond.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a medium-sized trading company, we would like to draw your attention to a particularly problematic issue in our view regarding the implementation of the PPWR producer registers: the envisaged obligation to appoint a separate authorised representative for the extended producer responsibility in each Member State for cross-border sales.

Filed in German · English published by the European Commission

The PPWR represents a significant bureaucratic and financial burden, especially for small businesses. I think that each producer or producer is willing to take responsibility for the packaging they place on the market. However, this responsibility must not lead to disproportionate administrative burdens and high additional costs, especially in difficult economic times.

Filed in German · English published by the European Commission

Ladies and gentlemen, the Directive is in many ways unworkable for small (online) traders. Small quantities of individual shipping boxes are already becoming the manufacturer with all the obligations. The thresholds for small traders are too low, and they are quickly exceeded in the case of distance selling.

Filed in German · English published by the European Commission

I own a small business and sell second-hand collectors’ merchandise to historical enthusiasts. I am not bringing any new litter to the world, but products that have been seeing life for almost a century. Postita’s products to customers around the globe and I would not like to waste my business to use margins to pay extra fees for mailing packages in each country separately.

Filed in Finnish · English published by the European Commission

Ladies and gentlemen, as a medium-sized German company, we would like to draw your attention to an aspect that we consider problematic in the implementation of the European Packaging Regulation (PPWR): the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border deliveries within the EU.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop for vintage perfumes, collectors’ items and other special or second-hand goods, I would like to draw your attention to the disproportionate burdens that, in my view, can be imposed on micro-enterprises as a result of the implementation of the PPWR.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

With regard to the new PPWR (bureaucratic monster) Regulation, I do not want to go into detail at all about the obligation and costs of an agent in each country, that there will be enough others, and you know yourself what barrier you have created here for shipping within the Union.

Filed in German · English published by the European Commission

Ladies and gentlemen, we are a small family business that has existed for more than 70 years, and we produce and sell organic and special foods through the wholesale, retail and directly to consumers. We have also built up a small customer base in other EU countries. As of 12 August 2026, we are forced to completely stop cross-border trade to most other EU Member States.

Filed in German · English published by the European Commission

Spending money on up to 26 proxies is financially harmful for small and medium-sized enterprises. Sending only 2-3 parcels to the country makes no sense to send them to that country. As a customer, I live in Germany. De is the largest market, so it is most likely that a foreign distributor will appoint the authorised representative, as this will cover costs.

Filed in German · English published by the European Commission

As a small, internationally established trading company with 8 employees, we serve both B2B and B2C customers across Europe and beyond. The VAT scheme (OSS) has already placed a significant administrative and financial burden on our company, requiring registrations, external service providers and considerable additional effort for cross-border transactions.

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

Filed in German · English published by the European Commission

I think this is something that needs to be done in a simple way and with as little administrative effort as possible. Lucid receives the notification for Germany from me. There can be no problem that reports can also be filed there for all countries, so that information can then be exchanged between countries. I pay a waste disposal operator in Germany.

Filed in German · English published by the European Commission

The current implementation of the Packaging and Packaging Waste Regulation is unsuitable for micro-enterprises engaged in cross-border e-commerce within the European Union. While reducing packaging waste and improving recycling are important objectives, the present system creates a disproportionate administrative and financial burden for small businesses.

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

Filed in German · English published by the European Commission

I am a small business owner based in Lithuania, selling handmade products online to customers across the European Union. I fully support the environmental goals behind packaging waste regulation. However, the current implementation creates a disproportionate administrative and financial burden for micro and small businesses engaged in cross-border e-commerce.

Dear Sir/Madam, I am the managing director of Burkhart Engineering GmbH. We sell vehicle parts and accessories from Germany via our own online shop worldwide, supplying almost all the Member States of the European Union. In the course of the PPWR, we have worked intensively on the new obligations and have already engaged a specialised service provider.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Dear EU, the U stands for Union. But with the new PPWR, the EU is going back several steps away from what it actually means. Each country is now back on its own, at least when it comes to the online trade of SMEs. I sell used spare parts for E-Pianos/Keyboards/Synthesisers, so far shipping to the EU has accounted for 40 % of my turnover. This is no longer the case.

Filed in German · English published by the European Commission

As a medium-sized trading company (11 employees), we are internationally established and address B2B and B2C customers. The VAT scheme (OSS) has already required us a lot and led to high costs (contracting of service providers for EU countries, registration, etc.). The tightening of product safety standards and registrations has continued to hit us hard.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as an operator of (very) small online sales, I would like to draw your attention to a particularly problematic consequence of the planned PPWR implementation: the obligation to appoint an authorised representative for the extended producer responsibility in each relevant Member State for cross-border sales.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

The system in its current form is absurd and will produce the opposite of the intended result. I sell reclaimed used laptop parts and pack everything in used boxes whenever possible, thereby helping to reduce the carbon footprint that the European Union is fighting so hard to lower. Thanks to my work, customers can repair their damaged equipment instead of buying new hardware.

As a small e-commerce owner, I generally welcome the objective of harmonising registration and reporting formats across the EU. However, from the point of view of a small enterprise, I would like to raise the following concerns: 1.

Filed in German · English published by the European Commission

In principle, we welcome the objectives of the PPWR, but we are critical of the planned obligation to appoint a separate authorised representative for extended producer responsibility in each EU Member State in the case of cross-border sales.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, the objectives of the PPWR, in particular the reduction of packaging waste and more effective producer responsibility across Europe, are in principle to be welcomed. However, when it comes to practical implementation, care should be taken to ensure that the resulting administrative requirements remain economically viable, especially for small businesses.

Filed in German · English published by the European Commission

My company has existed for 23 years, but we have never faced such a bureaucratic monster. For small and medium-sized enterprises, under the labelling requirements of the Product Protection Act and now also the EUDR, it is simply no longer manageable and we are serious about ceasing to exist. We have already rejected orders because we have not yet been able to respond so quickly and comprehensively to PPWR.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Dear European Commission, Unfortunately, the new rule is far from well thought out and leads not only to immense disadvantages for businesses, but also for EU citizens from small Member States and for the environment as a whole. A few examples: 1. Completely different practices in different Member States: Spain needs Hague Apostille (bureaucratic) and Italy needs a local address, which again costs extra each year.

Filed in German · English published by the European Commission

As the sole owner and operator of a micro-enterprise manufacturing guitar effects pedals in Belgium, I sell directly to customers across the EU through my own e-commerce website. I want to flag how the current approach to national producer registers under Article 44 PPWR is creating a disproportionate burden for very small, cross-border sellers like myself.

Thought we had open trading routes and almost same rules with all eu countrys. This new PPWR has forged to stop selling trough the whole eu. What idiot forges a registration rule without a central system like the OSS. And idiot part you have to pay for almost 20 countrys 500 euro to get the license? Come one stoopit EU! Hope allot of companys are giving a big finger too this rule and wont pay any penaltys.

These rules may create a disproportionate financial and administrative burden for micro and small businesses. Many of us receive only a few orders from other EU countries, yet would have to deal with registration requirements in each country. Please consider a simple, harmonised EU system or an exemption/simplified regime for very small businesses and low-volume sales.

I am already registered for packaging compliance in Germany and have been complying with the system for the past two years. At present, I pay approximately 20 per year because the amount of packaging I actually place on the German market is extremely small. Under the new system, the minimum cost would already increase to around 75 per year, even though I do not sell enough in Germany to justify such a fee.

The PPWR risks creating a disproportionate administrative and financial burden for small businesses while adding another layer of bureaucracy to waste management and recycling systems that already exist. Waste collection, sorting and recycling systems are already in place and businesses and consumers already pay for these services.

I am a one-person small business owner based in Lithuania, selling handmade products mainly through Etsy. I already comply with packaging requirements in Germany through LUCID, because Germany is my largest EU market. But almost half of my EU sales come from customers scattered across other Member States. In many countries I receive only 1-20 orders per year, and in some years none.

I am surprised how I can have easy access to the markets in the USA, China, Canada, Brazil, Great Britain, Switzerland and 150 other countries and at the same time have an unbearable financial bureaucratic burden to my neighbors France, Germany and 24 other EU member states. There is something rotten and smelly at the base of everything. And it is not recyclable. It is not repairable.

Ladies and gentlemen, the new EU regulation may be a good idea, but it is not feasible for me as a small businessman. The PPWR declaration of conformity is not a problem for me, as I know where to buy my packaging and filling materials.

Filed in German · English published by the European Commission

Dear Sir/Madam, My company Iko Audio is still in the process of being set up. We sell high-quality loudspeakers that can be produced independently at home using a 3D printer. This requires materials such as seals, frequency softeners, etc. We intended to sell this product to the EU far and even globally. The new Packaging Directive makes it impossible to sell in the EU, at least in the initial phase.

Filed in German · English published by the European Commission

We support the objectives of the PPWR: reducing packaging waste, improving recyclability and harmonising packaging rules across the EU. However, its current form risks creating an administrative burden disproportionate to its environmental benefit, particularly for SMEs.

I am a self-employed artist and designer based in Austria and I run a one-person microbusiness. Until now, I have been able to sell small quantities of my products directly to customers across the European Union. These are not mass-market goods: they are limited-edition art products, prints, postcards and other small creative products, often sent only occasionally to an individual customer in another Member State.

The problem is not fair for all, artists and creators are faced with a fait accompli to go through a paying agent, of course, but not all have so much financial means to do so, it is like e-invoicing, the EU is becoming a mafia. To be able to work, you have to pay and go to the cash office. This is against the free trade market, people want to siphon money for their own interests.

Filed in French · English published by the European Commission

The PPWR, if it remains valid in the current version, will severely restrict the barrier-free movement of goods in the EU. This is for a number of reasons: 1. Distributors will supply selective markets, if at all. 2.

Filed in German · English published by the European Commission

PPWR of 12.082026 Dear Sir/Madam, the EU Packaging Regulation has been applicable since 12 August 2026. As the operator of a newly established, small online retail business, I am particularly critical of the introduction of the planned implementation of the PPWR producer registers.

Filed in German · English published by the European Commission

As the owner of a small business that has been manufacturing natural wooden toys in Germany for over 30 years, I am significantly affected by the new European packaging regulations. I fully support environmental protection, recycling, and the responsible use of resources in general! In my specific case, over 90% of the cardboard boxes I use for shipping are second-hand, collected for me by various local retailers.

Hi, I'm Cristina and I want to join all the small entrepreneurs who are crying out for help and support from a community that should have protected our small businesses and stimulated the entrepreneurial environment. I'm from Romania and I have a small handmade jewelry and mandala painting business. I only have a few orders a year in the EU but little by little it adds up and for a small business it means a lot.

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

Filed in German · English published by the European Commission

Years ago, Italy had a huge problem with the mafia and garbage. Which was solved with exceptional political will. Back then, countries like Germany, France, Belgium, the Netherlands, Sweden pointed the finger at us, the Italians, that we were a mafia state. Today, however, the perception is different. These same countries have been taken over by the same garbage mafia.

Ladies and gentlemen, as a small commercial operator, I would like to express my concerns about the new EU Packaging Regulation (Regulation (EU) 2025/40). I engage in a small commercial trade in second-hand goods, in particular LEGO, Playmobile, toys, records, cassettes, tools and various vintage items. My turnover, and in particular my turnover with customers abroad in Europe, is very low.

Filed in German · English published by the European Commission

I believe that small business ownerssuch as eBay sellers, Kleinanzeigen sellers, Catawiki sellers, small online shops, and artistsshould not have to make payments to the European Union. This is because their shipping volumes are lower compared to giants like Amazon, Bol, and AliExpress, which ship far larger quantitiesand do so less efficiently.

These new rules are completely unfair and unsustainable for small businesses. Recycling and packing rules are great but it's the big companies that need to be stepping up, not the little grass roots businesses that are trying to be innovative, and create work in a world that's increasingly difficult to live in.

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

Filed in German · English published by the European Commission

Comments on the PPWR National Register of Producers I expressly support the objectives of Regulation (EU) 2025/40. Reducing packaging waste, improving recycling and making producers more accountable. However, the specific design of Extended Producer Responsibility (EPR) and national producer registers risks becoming disproportionately burdensome and costly for micro-enterprises selling small quantities across…

Filed in German · English published by the European Commission

I am writing on behalf of Skånes Hemslöjdsförbund, a non-profit organisation in southern Sweden working to preserve, develop and disseminate traditional handicrafts and cultural heritage. Our organisation operates a small shop selling Swedish and regional handicrafts, as well as material kits for traditional embroidery techniques that are part of Sweden's cultural heritage.

I urge the European Commission to take the impact of the PPWR on micro-enterprises seriously. As a micro-entrepreneur, I was genuinely shocked when I realised that selling goods across borders within the EU Single Market can require separate registrations, reporting, contracts, fees and, in some cases, authorised representatives in different Member States.

This regulation is a straightforward disaster for small businesses (with little or no staff). Individual registration in up to 26 countries, each with its own system, its own costs, its own rules, its own thresholds: it is impossible for an individual entrepreneur to understand without legal help.

Filed in Dutch · English published by the European Commission

Ladies and gentlemen, as the operator of a small specialised online shop for Bonsai, Bonsaischalen and accessories, we would like to draw your attention to a particularly critical point in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border sales within the EU.

Filed in German · English published by the European Commission

Hello, we are a family business from Germany with 12 employees and sell our articles across Europe. Our customers from Germany account for around 80 %. The remaining 20 % will be distributed among Austria, France, Belgium, the Netherlands, Italy and Spain.

Filed in German · English published by the European Commission

Hello, we are a German SME called Leenskleidung (www.lebenskleidung.com) selling sustainable fabrics B2B and B2C across the EU. We minimise packaging and are willing to pay the actual EPR costs generated by our packaging. However, the fragmentation into national registrations, reporting systems, minimum fees and authorised representatives makes cross-border trade economically disproportionate.

Submission to PPWR consultation (Initiative 15352) I am writing as a disabled DIY musician based in Wales, UK. My project, tAngerinecAt, operates entirely independently no label backing, no booking agent, no PR budget and has run for years on direct online sales of CDs, vinyl, and merchandise to a small, dedicated audience across the EU and UK.

My business ships maybe 50 parcels a year into the EU from the US. Each one is individually packaged as custom order. The products we sell are used in research and development, science, and engineering labs, government entities, etc. We sell enough in the EU that it will be painful to both our business and our EU customers if we have to cease shipments.

Ladies and gentlemen, as a sole trader, I operate a goldsmith without an employee. My customers come mainly from Germany, but I have occasional international customers. I was very sorry last year that I had to exclude Austria from my online shop, as the costs for the authorised representative there are disproportionate to the volume of orders, and now I also had to exclude the other EU countries.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, I run a goldsmiths’ artisanal business in Germany with an employee. In the past, we have also supplied individual customers from other EU Member States, in particular Austria and France. This does not involve large-scale mail-order sales, but rather a small number of high-quality jewellery items and correspondingly small quantities of packaging.

Filed in German · English published by the European Commission

I run a small book publisher in the UK. This legislation will kill my entire EU business which I have run for almost 20 years. I ship books to customers across the EU in cardboard packaging. To comply with the new rules will cost me thousands of Euros, making it impossible for me to send books to my small number of specialist customers. You are killing trade and killing businesses.

I have a micro business in Ireland making handmade ceramics and the new PPWR rules will completely shut down my sales outside Ireland to other countries in the EU. I only have a handful of sales to different EU countries and I use recycled boxes and recycled newspapers for packaging. Also because my handmade ceramics are fragile I need to use a larger amount of recycled paper than the PPWR allows.

Normal development of environmental torture in Europe - small businesses have easier access to world markets and a restriction to the single European market. The unthinkable is a fact - the basis for the existence of the European Union no longer exists and no one believes in the tales of free movement of goods and people, the principle of "small business has priority and equality" or the rosy single market in which…

Ladies and gentlemen, as the owner of a small Austrian online trading company supplying customers in many EU Member States, I am directly concerned by the provisions of the PPWR. I warmly welcome the objective of reducing packaging waste, conserving resources and promoting reuse.

Filed in German · English published by the European Commission

How should onlineshops with sales of 1000-5000 euro to different kind of countries survive. As a matter of fact you cant sell to these countries anymore and the loss of missed taxes will be x-times what EU are thinking to make. Our products are sold just by us for while Europe but now must seize down to maybe 3-4 main countries. Total the opposite what the EU stands for .

As a small company this regulations seems way too heavy. We ship sometimes 0-2 parcels of sustainable fashion to other eu countries. With paper hangtag and reused paper envelope made of recycled paper. All is easily recyclable and very minimal. Still we should registrate 27 seven times and update information to manage sometimes 2 paper envelopes sent to one country.

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

Filed in German · English published by the European Commission

For more than two decades, I have been marketing a dongle for my software products worldwide. Within the EU (with the exception of my home country), I sell around 10-20 units per year to customers in different EU countries. Compliance with the PPWR would exceed the yield of the individual sales. I therefore currently feel compelled to restrict sales within the EU to Germany (my home country).

Filed in German · English published by the European Commission

I have been in the e-commerce business for 28 years, specializing in handmade goods. Last year alone, I shipped around 60 kg of postal envelopes within the EU, with my annual average ranging between 50 and 65 kg. Today, simply to retain access to the European single market, I am required to pay a private firm around 9,800, plus additional recycling fees for each individual country.

Ladies and gentlemen, drum-tec (www.drum-tec.com) is a highly specialised retailer of electronic percusses, unique in the world. We provide advice, products, solutions and services that large market players cannot afford in this depth and specialisation. It is precisely such specialised companies that ensure diversity, innovation and a much better product world for private end-users.

Filed in German · English published by the European Commission

I run a small independent antiquarian bookshop in Sweden, selling new and second-hand books. Occasionally, we send a single book to a customer in another EU country, usually in a cardboard envelope or small box purchased from a Swedish supplier. In some countries, we may have only one or two customers per year. I support the environmental aims of the PPWR.

I am from Romania and I have to hire a company in Germany to count how many packages I have sent. Then I have to pay another company (affiliated organizations, as far as I understand) to do the work and profit from the work done. What is this strange job? What is this scandalous policy of subsidizing working and profitable business models? Is this the EU? Is this the free single market?

The cost for small and micro businesses to register individually in every EU state is a disproportionate burden. The cost is also prohibitive- costing a huge amount before a sale has been made. It will also hinder the cost and availability of buying materials from other small EU based businesses.

Ladies and gentlemen, since 2001 we have been operating a small, specialised online shop for merchandise made from pure silk (www.silknature.de). Naturally registered with LUCID in Germany, all packaging is licensed in Germany. For some time now, due to the costly obligation to appoint authorised representatives, we have had to stop sending our silk materials to end-users in Austria and some other EU countries.

Filed in German · English published by the European Commission

Ladies and gentlemen, Zeitauktion GmbH is an online retailer specialising in high-quality second-hand watches. We also sell our products cross-border within the European Union. We would like to draw your attention to a particularly problematic aspect of the implementation of the EU Packaging Regulation (PPWR): the obligation to appoint an authorised representative for the extended producer responsibility in each…

Filed in German · English published by the European Commission

These rules – if I interpret them correctly – make it impossible for me to continue my current secondary profession. I sell LEGO parts across the EU, which would now mean that I would have to make a special arrangement for each EU country that would cost me a relatively large amount of money and would make it impossible in practice to continue my trade.

Filed in Dutch · English published by the European Commission

I am submitting this feedback on behalf of an SME established in Germany that sells goods cross-border to customers in several EU Member States. We fully support the environmental objectives of Regulation (EU) 2025/40 and agree that producers should contribute fairly to the collection and recycling of packaging.

Ladies and gentlemen, as a digital print shop (micro-entrepreneurs for very high-quality micro-conditions), I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Ladies and gentlemen, not only does the implementation of the PPWR promote a significant increase in bureaucracy, but it is the small things that are almost incomprehensible to traders. The recycling rate is to be increased, but it is no longer possible to use used cartons, as these declarations of conformity are also needed, for example.

Filed in German · English published by the European Commission

How bitter should micro-enterprises like us bear this additional (after REACH and many more) administrative burden? Unfortunately, the EU officials in Brussels – who are completely alienated from the practice of a small company – are only able to destroy the EU and are now so far away from the original idea of a free internal market that it is hoped that the whole shop will soon break completely together or finally…

Filed in German · English published by the European Commission

From the point of view of a small online trader based in Germany, I would like to draw your attention to the considerable practical burdens arising from the current design of extended producer responsibility for packaging. I sell predominantly already fully packaged branded products, which I regularly buy within the EU and resell unaltered.

Filed in German · English published by the European Commission

Dear Sirs, this is biggest bullshit regulation thought out by political amateurs who never worked in private industry let alone were responsible for a small business. we had to stop any deliveries to any EU country as it is not justifiable to spend hundreds to thousands of Euros for bueraucratic nonsense to legally ship small parts to countries which only occassionally buy small parts.

I am writing as the owner of a small B2B company in Germany. We sell industrial transport equipment through our own online shop and ship to commercial customers in Germany and, where it is still economically possible, in other EU Member States. We support the environmental objectives of the PPWR.

The PPWR Must Not Turn the EU Single Market into 27 Separate Markets Pharmabinoid B.V. Response to the implementation of Regulation (EU) 2025/40 Pharmabinoid B.V. supports the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR) and the principle that companies should contribute fairly to the recycling and waste-management costs of the packaging they place on the European market.

I welcome the European Commission’s objective of standardising the requirements for national producer registers under Article 44 of Regulation (EU) 2025/40. However, from the point of view of a small B2B trading company, the specific situation of en-route transactions should be explicitly taken into account. My company is almost exclusively active in the line business.

Filed in German · English published by the European Commission

This proposed implementing regulation is like painting the window sill on a burning house instead of calling the fire brigade. (EU)2025/40 is completely dysfunctional, a serious violation of the common market, and must be scrapped. There is no chance of salvaging this ill guided regulation. The rules for registration and marking of the packaging materials miss any contact with reality.

as an operator of small online sales, I am very critical of the planned obligation to appoint an authorised representative under the PPWR in the case of cross-border sales. Individual sales to another EU country may require an authorised representative to be appointed and paid for there.

Filed in German · English published by the European Commission

Subject: Feedback from a small business operator on the PPWR/harmonisation of packaging registers Dear Sir/Madam, as a small business operator from Germany, I would like to speak out strongly against the unacceptable bureaucratic and financial hurdles of the new EU Packaging Regulation (PPWR).

Filed in German · English published by the European Commission

The PPWR jeopardises the free movement of goods through disproportionate bureaucracy and costs. As an entrepreneur and a lawyer, I am deeply concerned about the current design of the EU Packaging Regulation (PPWR). The free movement of goods is one of the fundamental principles of the European Union.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a small German online trader, we would like to share our views on the planned rules on national producer registers under the PPWR. In principle, we expressly welcome the objectives of the PPWR. Reducing packaging waste, promoting the circular economy, and improving the re-use and recyclability of packaging are important and useful objectives that we support.

Filed in German · English published by the European Commission

I am self-employed individual hand making and selling guitars and accessories. I recently took the difficult decision to pay for an authorised EU representative to ensure compliance with GPSR and enable me to sell to the EU once again, considering I already operate at a loss. This new directive fully prevents me from selling to the EU due to the cost of registering with an appropriate representative.

Hello, I am an internet retailer, a small business. My customers are record collectors from all over the world. The US is already a catastrophe because of Trump's customs. I was always glad that we have the EU. I appreciate that you want to reduce waste. But with the PPWR you will miss the target. You make the European market weaker. A handful of people work here.

Ladies and gentlemen, as a small owner-run company with its own development, production and online sales, we are directly affected by the planned PPWR rules on extended producer responsibility. Our company is a micro-enterprise according to the European SME definition: less than 10 employees and no more than EUR 2 million in annual turnover or balance sheet total.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Dear European Commission, I am writing to share my concerns regarding the Packaging Waste Regulation (PPWR) and EPR, particularly its impact on micro-enterprises selling across the EU. I run a very small business with just 1.5 people, including myself, and relatively small revenues.

We are a small German company and plan to expand our sales to other EU Member States. We take it for granted that we will contribute to the costs of collecting and recovering the packaging we place on the market. However, the administrative and financial burden involved is problematic.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

As a sole trader in the field of model building, I am affected by the PPWR, as are many traders in my area. I cannot afford the costs in terms of time of reading 26 different sets of rules in 26 different languages and implementing them in 26 different countries. I need this time for my actual business.

Filed in German · English published by the European Commission

Ladies and Gentlemen of the EU. Directly in advance. As a child of the 1970s, who was still acquainted with East/West Time, borders, individual currencies and even reunification, I am fundamentally a supporter of the European idea. The euro, invisible borders, free movement... wonderful. The ‘we’ instead of the national ‘I’, which the EU also wants to portray, is standard for me.

Filed in German · English published by the European Commission

I am preparing to launch Shaka Digz, a registered Swedish micro-enterprise and online clothing brand. I support reducing packaging waste, but the proposed national registration system is disproportionate for micro-enterprises. One sale to another EU country could require separate registration, reporting and an authorised representative.

The Federation of Finnish Woodworking Industries supports a genuinely harmonised and automated format for national producer registers. Four amendments are needed to prevent double reporting and disproportionate burdens for wood and transport packaging. Cross-border movements and reimbursement.

From the point of view of a small and medium-sized enterprise, the PPWR is becoming a considerable administrative burden, which is difficult to implement, especially for SMEs. A harmonised directive is a long way from being achieved. Instead of uniform rules, national one-size-fits-all solutions continue to emerge, with different registration, reporting and proof obligations.

Filed in German · English published by the European Commission

Concrete impact on our operations: We are massively losing turnover, as we can only send it to consumers in Germany and all other EU citizens must be excluded from our product. As a small shop with only a few kg of packaging (all of which we have already registered in Germany), we cannot afford the costs and effort involved! This law contradicts the idea of the EU as a single market.

Filed in German · English published by the European Commission

We are a small online shop from Austria and supply customers in Germany. Further expansion into EU markets is not possible: on the one hand, the costs for an authorised representative (per country!) are too high; on the other hand, the bureaucratic burden is indisputable. We want to develop our business further by using our resources rather than satisfying the wishes of bureaucrats.

Filed in German · English published by the European Commission

Ladies and gentlemen, as an operator of a small online shop, I unfortunately had to give up selling abroad in Europe as a result of the introduction of the PPWR. Above all, the obligation to appoint an authorised representative for extended producer responsibility in the case of cross-border sales is unaffordable for my company with few sales abroad.

Filed in German · English published by the European Commission

Good afternoon, this new regulation is a blow to the face of all micro-entrepreneurs who, for example, run a business as a side business and also supply neighbouring countries to the EU. The EU has allowed free travel to all EU countries and is now preventing free trade. I am a one-man show that manufactures and distributes electronic systems for model building.

Filed in German · English published by the European Commission

Dear Sir or Madam, Did anyone consider small businesses when the authorised representative obligation was designed? I run a one-person online shop selling vintage and second-hand clothing in Germany. I ask because from where I sit, the answer looks like no. Under the PPWR producer registers, a single sale into another Member State can trigger the duty to appoint and pay an authorised representative in that country.

As an operator of small online sales, I would like to draw your attention to a particularly problematic consequence of the PPWR: the financial and administrative burden of cross-border shipments within the EU, in particular through the obligation to appoint an authorised representative for the extended producer responsibility. In principle, I support the objectives of the PPWR.

Filed in German · English published by the European Commission

I am a very small one women business, seling my crafts on Etsy for 14 years. I agree, that I should pay for the waste I create and have absolutely no problem with that. But paying for the environmental impact of my packaging and maintaining a separate national compliance structure simply to be allowed to pay for that packaging are two very different things.

In addition to my actual profession, I practise a small-scale farming of discus fish in Germany. I sell my offspring to private customers and specialist retailers in Germany and many other European countries via my own online shop. I strongly support the idea that companies placing packaging on the market contribute adequately to the costs of collection, disposal and recycling.

Filed in German · English published by the European Commission

Dear Members of the European Parliament, I'm writing as the owner of a small online shop for board games. I founded the shop in 2024, with the hope of eventually being able to live from its earnings. In the meantime, I have spent countless hours, besides my day job, bringing my shop to its current state and being able to ship within Europe and the UK.

As a sole proprietor with an annual revenue ceiling of EUR 10,000, I find it practically impossible to comply with the PPWR requirements when shipping products to customers in other EU Member States. The requirement to appoint local legal representatives can result in costs of several thousand euros per country, which is completely disproportionate for a micro-business with such a limited turnover.

We are a family-run medium-sized enterprise. The obligations to which we are subject as soon as the PPWR enters into force represent a huge additional burden for us. All the tasks (authorisations, declarations of conformity, etc.) carried out by an entire department in the case of larger firms will be carried out by two members of our staff. This takes a long time.

Filed in German · English published by the European Commission

I am concerned about the impact of the new packaging rules on small, traditional and artisanal businesses like ours. Craftsmanship, authenticity and the way products are carefully made and presented are an important part, and these new requirements can have a disproportionate effect on us.

Ladies and gentlemen, as **fejn GmbH**, a small e-commerce company, would like to draw attention to the considerable burden of the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

I contacted the Swedish Environmental Protection Agency (Naturvårdsverket) just over a year ago to proactively find out which rules applied, or were going to come into effect. I was told to check the information on their website, but the problem was precisely that their website contained no information at all.

The economics of recycling in the EU: regulations, fees and corporate profits Under European Union directives mainly the Waste Framework Directive and the upcoming Packaging and Packaging Waste Regulation (PPWR) the burden of waste management has shifted to the private sector through Extended Producer Responsibility (EPR).

Since 2001 I have run an online shop for remote-controlled model cars, from which I enjoy young and old. With the new PPWR Directive, it is no longer possible for me to send it to the EU countries, which account for just over 20 % of my turnover, as it is not worth defining an authorised representative even in the top five countries.

Filed in German · English published by the European Commission

The regulation tramples on many of the EU's uniform laws. This is an indisputable fact. But we should not blame the green policy. It is not the policy that exports the production of European business outside Europe. It is not the policy that destroyed agriculture and made it dependent on subsidies. It is not the policy that stops the existence of small producers and replaces them with non-European production.

The EU should be one of the world's most prosperous and competitive regions, yet growth and competitiveness are increasingly falling behind. Instead of removing barriers and unleashing European businesses, Brussels keeps adding layers of regulation and bureaucracy that make it harder to invest, innovate and grow.

As a small business owner, I support the goal of reducing packaging waste and making producers responsible for the packaging they place on the market. However, the administrative burden should be proportionate to the size of the business.

The EPR regulations will effectively kill cross-community business for micro-enterprises and sole traders, particularly artists and makers. The need to have separate arrangements for every member state to which art is shipped with set-up fees that can be up to 50% of the cost of an artwork is unsustainable. Most artists will ship one or two artworks to a given country a year, to maybe have 3 or 4 EU countries.

As a UK based small business owner, I am shocked that the EU has devised such a disproportionate, destructive and ill thought regulation. Not only will these new rules change the way many low volume operators do business, it will stop the majority of small business EU trade that this nonsensical ruling is looking to benefit from.

Subject: Violation of the EU Single Market and the "Think Small First" Principle by Regulation (EU) 2025/40 (PPWR)As an EU citizen and micro-entrepreneur, I submit this formal contribution to denounce the brutal violation of the foundational pillars of the European Union by the new Packaging Regulation (PPWR).

Are not the small traders, in the sum of those who pay the most VAT? If almost all traders have half or more of their turnover missing because most cannot afford to implement the PPWR, the turnover tax revenue of the individual EU countries is also likely to fall significantly. To remain silent on the additional bureaucratic burden.

Filed in German · English published by the European Commission

Small businesses face a disproportionate administrative and financial burden from these new rules. For a small business with only a few dozen shipments per year, registration, reporting requirements and potentially the need for a local authorised representative leeds to punitive costs far above the actual packaging and recycling fees.

All European consumers, businesses and farmers should know the most important thing. Germany, France and several other countries have introduced this regulation in its most cruel version. In these countries, consumers are burdened three, four or more times with eco-taxes for the same item or its production. In these countries, green policy has reached levels of super-profit from recycling.

Ladies and gentlemen, as a small owner-managed handmade company, we would like to draw your attention to a particularly critical point of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border sales within the EU. With Noraya, we handmade and sold dog collars, lines, crockery and dog brands through our own online shop.

Filed in German · English published by the European Commission

Ladies and gentlemen, I am a jewellery designer and have been operating as a small/women’s enterprise since 2014, selling only handmade jewellery and brute hair jewellery online. Since the EU set financial requirements for each Member State, I have sold only in Germany. In particular, transactions with customers from Austria and Switzerland have broken down.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Feedback from the public consultation Draft legal act Implementing Regulation on the harmonisation of producer registers (Extended Producer Responsibility for Packaging, PPWR) Committee: C37000 | Category: REFIT feedback deadline: 6 August 2026 10 September 2026 Dear Sir/Madam, as the operator of a small online shop, I am writing to you with a specific concern about the planned implementation of the PPWR producer…

Filed in German · English published by the European Commission

The new PPWR Regulation (EU 2025/40) and the blind application of the Producer’s Wider Liability (EPR) constitute a direct violation of the fundamental principle of free movement of goods. Under the guise of a green policy, this text destroys the fabric of cross-border micro-producers, craftsmen and sellers (on eBay, Etsy, Amazon), while enriching private waste management structures.

Filed in French · English published by the European Commission

Good afternoon. In principle, I support the objective of reducing packaging waste and making companies responsible for the packaging they place on the market. However, the new requirements in their current form pose a hardly solveable problem for small online traders and should be urgently revisited. We send most of our orders within Germany. Other EU countries sometimes receive only one or two packages per month.

Filed in German · English published by the European Commission

In principle, we welcome the objectives of the new EU Packaging Regulation (PPWR), in particular reducing packaging waste, improving recyclability and promoting a functioning circular economy. As a small Austrian company, we already support these goals today and deliberately invest additional time and financial resources in more sustainable solutions.

Filed in German · English published by the European Commission

The corrupt politicians in Brussels have destroyed small businesses in Europe and given full advantage to the big traders of goods from China. They deserve to become honorary residents of China, to catch planes there and never set foot in Europe again. And we in Europe will use goods made in China from here to the end of the world.

Exclude small and micro businesses from the A.R. Rule as it is disproportionate towards micro businesses! We Cant afford it, our shops would have to close. Is this what is being in the EU means? Try no free movement inside EU anymore, which is what EU is all about right?!

Filed in Portuguese · English published by the European Commission

I am the founder and sole operator of a new micro leathercraft business established in Greece. I design, manufacture, package and sell my products myself. My business currently receives approximately one or two orders per month and is still trying to become financially sustainable. Access to customers across the EU is essential for its growth and survival.

These new PPWR rules are beyond absurd for micro 1 person creative businesses like mine. I sell to on average 6-8 other EU countries and have little time for admin as I am making my craft. The majority of businesses like mine already use recycled packaging and are very conscious of waste and recycling but to have to register and pay in each country will kill my intra EU sales. This is the opposite of a common market.

The new rules will lead to significant cost increases for SMEs and individual entrepreneurs, with significantly increased costs. There is an urgent need for exemptions for companies below a certain turnover threshold. Unfortunately, we will only be able to sell within Germany and outside the EU.

Filed in German · English published by the European Commission

I am 100% pro waste reduction and management. But not in such an uncoordinated way. This law is effectively endangering my business that i built for 10+ years. The whole law is not thought through properly. Create a law that can be implemented ONCE in the EU and combine it with the fee systems already in place (i.e. German Lucid) to create A SINGLE central instance for packaging registrations and fee payments.

This law is grossly unfair to small businesses. The fees and admin is disproportionately onerous and small owner-maker businesses are not the ones causing threat to economies or ecosystems. Small businesses famously source low impact packaging and pride themselves on caring for the planet. This law is stifling creativity, culture and diversity.

As a small family business with fewer than 10 employees, we have fought over the last decades to build a name with our niche product on the European market. Avoiding packaging and reusing packaging material is not just a heart issue, but simply a business imperative.

Filed in German · English published by the European Commission

This is absolutely horrible and will directly destroy my small family business. There must be comprehensive exemptions for micro and small businesses! This regulation needs to be re-created from the bottom up, to be proportional and to not create administrative weight or financial burden for Micro-businesses and SMEs - how is the EU business supposed to grow if we adopt regulations that crush small businesses and…

I am a very small. sole proprietor business in France, as such the new rulings will make it impossible for me to continue. It is simply not economically feasible, the costs far outweigh any profit I currently make. I find it ironic that this legislation effectively will make it easier for me to sell items & send them to Countries outside the EU than within it, which seems to be against everything the EU stands for.

In recent years, new obligations, rules, laws have been constantly added. Every month it becomes more complicated, difficult, time-consuming and expensive for traders. The PPWR puts the crown on the whole. I really wonder if anybody is concerned about what this means for small businesses or retailers like me. I wonder even more whether MPs really think about it or simply agree because they expect the party to do so.

Filed in German · English published by the European Commission