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

Ladies and gentlemen, in connection with the planned implementation of the PPWR, we would like to draw attention to one particularly problematic point in our view: the obligation to appoint authorised representatives for extended producer responsibility in cross-border sales. So far, we are shipping our goods to more than 20 countries and we wanted to further develop our international business.

Filed in German · English published by the European Commission

Dear Sir/Madam, In principle, I support the objectives of the PPWR. However, for small and medium-sized online traders, the administrative burden is very high. The requirement to register in each EU Member State and, if necessary, to appoint an authorised representative is particularly difficult.

Filed in German · English published by the European Commission

In principle, I support the objectives of the PPWR: less packaging waste, more recycling and more reuse are right and important. However, what I consider disproportionate is concrete implementation to the detriment of micro and small enterprises. I am a sole trader and, for example, send only around 2050 parcels per year to Austria.

Filed in German · English published by the European Commission

As an EU-based company and resident, it was an odd feeling indeed to disable all EU sales from our web shop. What happened to free trade between the EU states? We've survived a lot of things in our 30 years as a company: new rules, new regulations, the covid lockdowns, Brexit, USA tariffs, our distributors dying out, bricks-and-mortar shops going under etc., but we have managed to set up a thriving mailorder…

Where are we talking about cutting red tape for years? The PPWR is another example of how European regulation is burdening small and medium-sized enterprises with ever-increasing red tape and documentation requirements, without creating corresponding practical or environmental added value.

Filed in German · English published by the European Commission

Dear Sir/Madam, I run a small webshop in second-hand books. I would like to give an example: in 2025 i shipped just over 3 kg of packaging material to Belgium. With the currect rates that should cost 2,60 euro EPR tariff (fair enough) + 330,00 euro (excl. VAT) for handling and representation in Belgium: 332,60 euro for just over 3 kg of packaging material.

Ladies and gentlemen, I have been self-employed for 27 years and run a small brick-and-mortar shop, including a small online shop. I do not have a legal department, a compliance department or a staff. I am an ordinary micro-entrepreneur who tries to run his business through increasingly difficult times.

Filed in German · English published by the European Commission

As a small e-commerce business for 20 years, I would like to raise the following concerns: Delegates in each EU country: Organisationally hardly feasible for micro-enterprises Additional costs for external service providers Not proportionate to low turnover abroad Risk that small traders no longer supply certain EU countries More rather than less red tape: The PPWR, however, creates additional registration, evidence…

Filed in German · English published by the European Commission

Dear Sir/Madam, Thank you very much for the opportunity to comment. The implementation of this Regulation in its current form is a major constraint on intra-European trade. Small businesses are actively prevented from sending goods to other EU countries because, on the one hand, registration and the appointment of authorised representatives in other EU countries often suffer from language barriers and, on the other…

Filed in German · English published by the European Commission

In principle, we welcome the objective of increasing transparency by recording packaging volumes and providing a reliable data basis for European packaging policy. However, the draft requirements impose a disproportionate administrative and financial burden, especially on small and micro-enterprises. We are particularly critical of the obligation to appoint an external representative in each Member State concerned.

Filed in German · English published by the European Commission

After reading about this stupidity I tried to find or comprehend the information on the available websites. This is impossible, it is as clear as mud. According to info from other sources I have to register and pay fees for every country I ship to. The countries I ship to change per year and can be as little as 40,-- per country per year. These are replacement parts that only I make.

I am registered in LUCID and I submit my volume declaration there. Why can I not simply say x kg of packaging, of which x kg to other EU countries or x kg by country and country? Simply a central point as in the case of OSS. I report to LUCID and the countries then make it themselves. Would this be too simple and implementable for SMEs?

Filed in German · English published by the European Commission

Subject: Disproportionate impact on individual artists and micro-producers I am an independent artist who occasionally sells an original artwork to a customer in another EU Member State. I fully support the objectives of reducing packaging waste and producer responsibility, but I am concerned about the disproportionate impact of national registration requirements on very small-scale sellers.

This has devastated my EU Sales. we are a small business with only 3 staff, all EU sales have had to stop. This legislation is favouring big businesses that can pay and deal with these complicated expensive registrations, small business cannot. You are supporting the likes of Amazon and big business not small business. Please make this exempt for smaller sized or smaller turnover businesses.

Ladies and gentlemen, we are a small company (GbR, 2 business partners, 1 x mini-jobber, without our own legal department, etc.) from Germany and we sell our goods almost exclusively via online sales. We would like to take this opportunity to draw attention – from the point of view of a small enterprise – to a particularly critical point in the planned implementation of the PPWR producer register: The obligation to…

Filed in German · English published by the European Commission

Hi, We are a small business in Ireland manufacturing and distributing products for small independent artists to fans across the EU. This regulation essentially places us behind all the major manufacturers and distributors both inside AND outside the EU.

I just want to remind you that a micro-business often has an annual income only about 40 000 euro. A micro-business is often made up of ONE person who does all the work. The proposed new regulation will, in practice, destroy businesses like this. I sell my work online. At most, 250 shipments go to the European Union around 50 to Germany and France, and the rest only a few items per country.

the new laws regarding PPWR are far too expensive for most small and micro businesses. reduction of plastic and waste is massively important, however having to register for each separate company and pay extortionate fees to the random and unregulated companies that individuals is unworkable. Most companies offering this service charge between £300 to £2000 per year per country.

I am the owner of Nifty Needles, a micro craft business based in Northern Ireland. I design and sell my own embroidery, quilting and textile craft patterns, kits and notions. I am a sole trader and my business operates on a scale vastly smaller than the large companies these regulations also affect. Until now I have been able to sell occasional orders to customers in EU Member States.

Ladies and gentlemen, I am appalled by the implementation of the PPWR. We are a small business and the red tape and costs are huge. After consulting five different providers (Landbell, Interzero, etc.) for packaging waste, we can expect almost 1000/per country/year. Although these agents are required at 12.8, this service is not yet offered at all.

Filed in German · English published by the European Commission

Ladies and gentlemen, I am writing as a sole trader regarding the requirements for the national producer registers. I produce biocertified natural cosmetics in Austria from domestic medicinal plants, by hand and in small batches, certified in accordance with AT-BIO-501. My annual turnover is around EUR 13.000, and my products cost between EUR 7.9 and EUR 34. I have no employees.

Filed in German · English published by the European Commission

Ladies and gentlemen, I am pleased that the Packaging Ordinance is intended to prevent waste and to do something for the environment. But the Packaging Ordinance in its current form goes beyond the objective, as you completely miss the reality.

Filed in German · English published by the European Commission

We support the objective of improving transparency and producer responsibility across the EU. However, the proposed system of national producer registers risks creating a disproportionate administrative and financial burden for businesses. Companies operating in several Member States may have to deal with different registration systems, reporting requirements and procedures in each country.

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

Filed in German · English published by the European Commission

As an individual small business, I see my future under threat. It is impossible for me to pay one agent per country, so I am forced to abandon sending my creations by parcel because of a lack of means. As a result of this new law, I therefore separate part of my income, including income in my own country, because I send too few parcels to make it profitable to pay an agent.

Filed in French · English published by the European Commission

In our company we produce handmade wigs, beards and silicone prosthetics. Our annual turnover is around 15.000 and, as a rule, the prices of our products range from EUR 15 to EUR 300. We sell our products both at trade fairs and through online shops.

Filed in German · English published by the European Commission

I run an Irish e-commerce business, retailing almost exclusively on eBay. The business has one employee - me! Whilst the new regulations are difficult to understand, the biggest difficulty is the question of scale and minimum scale of registration. My product is niche (2nd hand collectables) and approximately half of the EU countries I ship to have less than 10 orders per year.

I was born in the EU. I grew up in the EU. I still live in the EU. I own a one woman micro business based in the EU and do everything that comes with it all by myself. I create one of a kind, handmade, wearable art that I package in 100% recyclable, 0% plastic, partially recycled packages, and sent them to people all over the world throughout the past 7,5 years.

Good afternoon, as an operator of a small online shop, I see my existence at risk, as I rely on orders from abroad for my one-woman business. Nor can I simply pass on the costs incurred here for the five main countries to my customers, as this is no longer worthwhile for my customers. As a result, unless a micro-enterprise scheme is used, I can see that my business has not lasted for a long time.

Filed in German · English published by the European Commission

For many smaller companies, the current set-up is unstoppable. This affects not only the companies themselves, but also companies that rely on smaller suppliers and may even have concluded framework contracts. It is unacceptable that this law completely breaks down the basic idea of the EU. The free trade area has been ad absurd.

Filed in German · English published by the European Commission

Having ran my small business since 2012 with very few issues shipping into the EU the new PPWR regulations are going to finish off any chance of shipping to customers in Europe. I am one single person running a small business from home, a business that has paid my bills for the last 14 years, turnover is diminishing due to more and more fees being thrown at small business owners that cannot be absorbed other than…

This new law is a crucial point for my little business. I sell vintage clothing during 15 years. The last year my business went down the hill by many reasons, including the whole economical situation, inflation, new shipping regulations to ship to the United states as well, I found myself with many debts to URRSAF, that I can not pay, I hardly pay my living.

Ladies and gentlemen, the idea for the EU is that everything should be made uniform and, above all, simpler. At present, it is exactly the opposite: As a small business with an online shop for very specific custom-made products, I need 26 individual authorised representatives and 27 different packaging licences.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to an aspect of the planned implementation of the PPWR producer register which, in my view, can have significant practical and economic implications, in particular for small and medium-sized enterprises: the obligation to appoint an authorised representative for the extended producer responsibility in the case of…

Filed in German · English published by the European Commission

Ladies and gentlemen, as micro-entrepreneurs and online traders, I have been monitoring for several years with increasing concern how the regulatory and administrative requirements for small businesses trading cross-border within the EU are constantly increasing. However, I consider the new requirements of the EU Packaging Regulation to be the culmination of this failure so far.

Filed in German · English published by the European Commission

Ladies and gentlemen, I sell online as a sole trader. The sale takes place both within Germany and in almost all EU countries. However, the volume differs significantly, with a large focus within Germany. Sales to other EU countries amount to a small number of letters and/or parcels per year.

Filed in German · English published by the European Commission

Ladies and gentlemen, I operate a small handmade business in Germany and sell mainly through my online shop. I send an average of 40 packages per year to mainly six other EU countries. My turnover from these countries ranges from EUR 1900 to 2100. I would probably have to pay EUR 895 per year to register and appoint representatives in these countries.

Filed in German · English published by the European Commission

Small traders, online shops and importers are disadvantaged by the PPWR. This Regulation effectively abolishes the internal market and promotes only large companies. I strongly support the intention to make packaging materials more environmentally friendly and to save resources.

Filed in German · English published by the European Commission

As small e-commerce, we would like to comment on the obligation to appoint an authorised representative for EPR in cross-border sales. We sell in a small sector as a small family business without a legal department but with the ambition to abide by the law. The PPWR poses significant problems here: However, we often sell only a few parcels per year to many different EU countries.

Filed in German · English published by the European Commission

Ladies and gentlemen, we run a small business [industry, country] and would like to raise three issues that put a particular burden on us in the implementation of PPWR: No minimum threshold for the obligation to act as an authorised representative: Even a single consignment to another EU Member State requires a paid agent to be appointed in the destination country, regardless of how small the turnover there is.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

This proposal is ridiculous for ALL small businesses across the EU - I have no employees and post very little (due to the Trump admin killing my USA trade and La Poste refusing to send small packages to the USA indefinitely. I cannot guess where my next client may live, I cannot afford to register in every single country - the cost is prohibitive and the administration is as well.

Ladies and gentlemen, as small enterprises [industry, country], we would like to draw your attention to the following problems in the implementation of the PPWR: 1. No de minimis limit for the obligation to appoint a representative: Even a single package to another EU Member State triggers the obligation to appoint a paid agent there, irrespective of the actual turnover.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a result of the EU Packaging Regulation, which entered into force on 12 August 2026, we, a stationary and online specialist watch shop, lose approximately 40-60 % of our turnover in the short term. We are not able to register and provide assistance in individual EU countries in terms of staff and costs.

Filed in German · English published by the European Commission

I sell IT hardware to EU countries worth approximately 5001,000 per month (Id need to calculate the exact figure)all via eBay. Over the last few years, Ive shipped to virtually every EU country, though the frequency varies by destination. I generally reuse the plastic packaging from my suppliers, but I could switch to using exclusively paper or cardboard packaging for EU shipments in the future.

The act feels like it was made with money in mind above all else considering how much it costs to apply for each individual country. There should be something like an annual payment of very low cost for micro businesses who don't send out much packaging. Not hundreds - going into thousands - no matter the size of your business.The stress of this new act is far too much.

For micro-enterprises, whose turnover is made up partly of individual consignments to different EU countries, it is equivalent to a sales ban that a separate appointment of an authorised representative and sometimes very high payments are now required in each EU country in order to send even a single parcel to that country via a sales platform.

Filed in German · English published by the European Commission

The company shares the environmental objectives of Regulation (EU) 2025/40 (PPWR). However, the way the implementation is currently unfolding in particular the fragmentation of producer registration and documentation duties across 27 Member States generates a level of administrative burden that is disproportionate to its environmental benefit.

Ladies and gentlemen, I operate a small online shop and would like to tell you about a point from the planned implementation of the PPWR which is of great concern to me in practical application: the obligation to appoint an authorised representative for the extended producer responsibility in the respective target country for cross-border sales.

Filed in German · English published by the European Commission

While I'm very supportive of using recycled or recyclable packaging, I'm an extremely small business (non profit) that sends less than 50 orders abroad per year, so extra costs and admin are just completely impossible for me both financially and work load wise. There's no one employed by the non profit, just one freelancer who works a few days a month.

For a newly started small business like mine, these new packaging requirements could have a serious impact on my ability to grow and sell to customers across the EU. Every additional registration, fee and administrative requirement creates a significant financial and bureaucratic burden when you are operating with very small quantities and limited revenue.

We are a German company that develops and manufactures electronic components for the B2B market; we are classified as an SME. We sell our products worldwide, but with a particular focus on the EU. The new Packaging and Packaging Waste Regulation (PPWR) imposes a massive administrative burden on us.

While the intention behind these regulations reducing packaging waste and encouraging more sustainable practices is admirable, the current one-size-fits-all approach is completely disproportionate and risks seriously harming small and micro businesses. Many small, artisan businesses are not the source of the packaging waste problem.

Ladies and gentlemen, as an operator of growing online trade, I would like to draw your attention to what we consider to be a critical point in the implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the Extended Producer Responsibility (EHR) in the case of cross-border sales. For us, selling abroad in the EU was an essential building block of our business.

Filed in German · English published by the European Commission

Ladies and gentlemen, the planned implementation of the PPWR register of producers, in particular the obligation to appoint an authorised representative for extended producer responsibility in cross-border sales, contradicts everything that a united Europe should stand for. If it is easier and cheaper for a small business in an EU country to export to a non-EU country, the EU becomes absurd.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

We fully support the objective of reducing packaging waste and strengthening producer responsibility, especially given the enormous volume of packaging generated by large e-commerce companies. However, the proposed registration and reporting requirements risk becoming disproportionately burdensome for microbusinesses.

Dear Sir/Madam, Thank you for giving small businesses the opportunity to comment on the PPWR rule. I have a turnover of around 10.000 a year from my products. On average, I send 25 parcels per year to neighbouring countries. Searching for and paying for a representative in each case far exceeds the budget and I consider it to be absolutely disproportionate.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a small business, we must draw your attention to what I consider to be particularly critical points in the implementation of the PPWR: — Obligation to appoint an authorised representative for extended producer responsibility in the case of cross-border sales – Declaration of conformity must be drawn up in the languages of the Member State(s) to which the packaged products are delivered – In…

Filed in German · English published by the European Commission

Unfortunately, we have now had to stop sending event tickets and suitable merchandising articles to the EU countries, to the detriment of EU citizens, as we do not have authorised representatives in other EU countries and it is not currently economically and bureaucratically possible to present this. Very bad for the idea of a big market in the EU!

Filed in German · English published by the European Commission

I am 9 years into running my small business, I have navigated many hurdles along the way. The PPWR is the only one that is so unreasonable, I have chosen NOT to navigate it in all countries, I will simply withdraw the sale of goods there. What happened to encouraging businesses to grow?

I operate a letter shop in Erfurt under mailing pressure24.de In addition to advertising mail, I occasionally send goods such as individual printed matter. From now on, even in the case of small quantities (e.g. an order with a value of 85.00 from Austria), we will have to make a cautious effort to supply a customer. Registration for Austria costs from 295,00 onwards – this is disproportionate to the revenue.

Filed in German · English published by the European Commission

these new regulations are obscene to micro-businesses and new startups like myself. I believe this system would benefit by being tiered, including a minimum threshold. many small business owners care deeply about their packaging and choosing eco-friendly materials.

Ladies and gentlemen, I am writing to the European Commission because, as a solo self-employed person or micro-enterprise, I am directly affected by the new rules on packaging and packaging waste. I send only a comparatively small number of parcels to other EU Member States. Nevertheless, I face registrations, notifications, fees and other requirements.

Filed in German · English published by the European Commission

As a small German e-commerce company, we sell our products to customers across the EU. Requiring us to register, report packaging volumes and potentially appoint representatives separately in every Member State creates disproportionate bureaucracy and costs. Our bigger (international) competitors (e.g. from the US) get a clear advantage as they can cope easily with the new impediments and rules.

We are a small business and supply the whole world. Now we had to stop shipping to the EU. However, we must not be allowed to supply the entire world to our neighbouring countries, as an authorised representative does not expect to be economically viable for 10-20 parcels a year. How to make such a decision? Why is there no small flat rate for micro-quantities?

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

The planned obligation of authorised representatives for extended producer responsibility disproportionately affects small traders in cross-border sales through separate contracts, fees and reporting channels per destination country. Our Consequences: we no longer supply end-users in EU markets. Fixed costs per country act as a market entry threshold and hinder/prevent the European single market for small traders.

Filed in German · English published by the European Commission

How can this be adopted? They destroy hundreds to thousands of small businesses, including myself, with a single rule. The single market has once been the EU’s flagship and now it is no longer possible to participate as a small business. One could call it the enshittification of the EU.

Filed in German · English published by the European Commission

Hello, this new packaging regulations is causing unprecedented disruption to free trade in EU . As an owner of micro business, as many other small companies, I will not be able to continue shipping my handcrafted items outside of my country.

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

Filed in German · English published by the European Commission

I am writing as the owner of a UK micro-business that has previously sold products to customers throughout the European Union. I fully support the environmental aims of the Packaging and Packaging Waste Regulation.

Dear Members of the European Parliament, I am writing about the new Extended Producer Responsibility (EPR) rules coming into effect on 12 August. I fully understand the goal: reducing unnecessary packaging and improving recycling. My concern is the disproportionate burden these rules place on very small businesses. I run Liquid Disco, a one-person creative business that is both my dream and my only source of income.

As a small online trader, I also sell my products in several EU Member States. The obligation to appoint an authorised representative for each country generates significant running costs and additional administrative burden. Especially in lower-turnover countries, these costs are disproportionate to the revenues generated there.

Filed in German · English published by the European Commission

As a medium-sized industrial supplier, we are already working intensively on the practical implementation of the PPWR and the development of corresponding packaging data. In particular, the division of responsibilities between the manufacturer and the EPR producer, the multiplicity of different packaging variants and nationally differing registration and reporting requirements require considerable clarification.

Filed in German · English published by the European Commission

I understand that Europe has not enough money to support refugees, the war in Ukraine and other fertilisers, but this is already too bad. I am a taxable person for VAT and I pay all taxes fairly, but this is already too much! As a small businessman, I turn up to 20000 a year and cannot afford to pay this squeeze-out fee.

Filed in Latvian · English published by the European Commission

I am the owner of a U.S.-based micro-business producing handmade jewelry, and I am writing as a directly affected small business owner. I support the European Unions objective of reducing packaging waste and promoting greater environmental responsibility.

While the idea behind this is good on paper, in practice this will kill every micro business shipping internationally in the EU. It is next to impossible to manage registrations for 27 separate countries as a one-man business, and it is also completely economically unfeasible if you are only shipping a small amount of parcels annually. Please consider adding exemptions for small/micro businesses.

While I wholeheartedly agree with the overarching purpose of the initiative - plastic waste is a curse and should be eliminated - the process around this is completely unworkable for micro and small businesses. I do think micro and small businesses should look to use sustainable and minimal packaging but the true culprits in the waste creation problem are large companies such as coca cola not one person micro…

The objectives of the EU Packaging Regulation to reduce packaging waste, conserve resources and promote the reuse of packaging are strongly welcomed. However, I consider the implementation currently envisaged to be disproportionate for micro-enterprises and one-person enterprises, impractical and unlikely to be acceptable in this form.

Filed in German · English published by the European Commission

I am a tiny one-woman micro business. I have been running my jewellery online store for five years in Germany. I try to minimise my impact on the environment in every possible way. I only use recyclable cardboard packaging, and very minimally too.

I strongly support the EUs goal of reducing packaging waste and protecting the environment. However, I am deeply concerned about the impact that the implementation of PPWR and national EPR requirements will have on micro-businesses and start-ups selling small quantities across EU borders.

I represent a Portuguese micro-business that designs and manufactures dog accessories in-house and sells directly to consumers across the EU. We support the environmental objectives of the PPWR and the principle that producers should contribute to the management of the packaging waste they generate. We already aim to minimise packaging and use responsible materials.

Hello, unfortunately, the basic idea of the EU is that the Regulation has completely failed. SMEs can only give up. The first thinkers of an open market, Robert Schuman, Konrad Adenauer, Jean Monnet, etc., were keen to strengthen the idea. Modern politicians such as François Mitterrand, Helmut Kohl and Jacques Delors then perfected it.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small engraving workshop with an online shop in Germany in the countryside, I would like to take this opportunity to draw attention to what I consider to be two particularly critical points in the planned implementation of the PPWR producer registers: (1) the obligation to appoint an authorised representative for extended producer responsibility in the case of cross-border…

Filed in German · English published by the European Commission

Soy responsable de una pequeña empresa familiar en España que vende principalmente a clientes particulares. Apoyo plenamente el objetivo de reducir los residuos de envases y fomentar un sistema más sostenible. Sin embargo, la obligación de registrarse y cumplir diferentes sistemas de responsabilidad ampliada del productor (EPR) en cada Estado miembro supone una carga administrativa y económica desproporcionada para…

To whom it may concern, I run Tama Spa & Repair, a micro-enterprise based in Germany. I design and manufacture small electronic accessories for Tamagotchi and similar virtual pets and offer specialist repairs. I aim to make my own products repairable, publish schematics where possible, reuse packaging and avoid unnecessary plastic.

If a small enterprise sends a few parcels per month to Belgium, this is not possible. The costs are then much higher than what the profit on sun packet can be. The big boys, bull, joke amp, etc., will have no trouble with this. This is detrimental to small businesses.

Filed in Dutch · English published by the European Commission

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

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

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

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

Filed in French · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Ladies and gentlemen, as the operator of a small 1 man online shop, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

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

Filed in German · English published by the European Commission

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

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

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

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Ladies and gentlemen, as the operator of a small shop for children’s furniture for disabled children and young people, I would like to take this opportunity to draw your attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border…

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, in connection with the planned implementation of the PPWR, we would like to draw attention to one particularly problematic point in our view: the obligation to appoint authorised representatives for extended producer responsibility in cross-border sales. So far, we are shipping our goods to more than 20 countries and we wanted to further develop our international business.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

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

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

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

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

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

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

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

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

Filed in Dutch · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in French · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in Dutch · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in Spanish · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in Swedish · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to key criticisms of the planned PPWR implementation, in particular the obligation to have an authorised representative in the case of cross-border sales. As a small businessman, selling abroad in the EU has been an obvious step forward so far.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

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

Filed in German · English published by the European Commission

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

Ladies and gentlemen, as the operator of a small online shop, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for Extended Producer Responsibility (EPR) in cross-border sales – another pointless bureaucratic monster that deprives us…

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop in a very limited niche, I would like to point out an existential point for us in the implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Comments on the PPWR I, as a one-person company, engage in small-scale e-commerce mail order sales of small-label phonograms for special music products, some of which appear only in very small print runs and are not available in regular trade. My international customer base has grown for decades. Around 500 of my packages go to other EU countries every year; this gives me almost a third of my turnover.

Filed in German · English published by the European Commission

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

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