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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in Dutch · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in French · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, As Klein Bean to Bar Schokoladenmanufaktur with two brick-and-mortar shops and a small online shop, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border…

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in Swedish · English published by the European Commission

Ladies and gentlemen, In this situation with the new law, it is economically impossible to send it to the European Union. My proposal; and that’s how all the traders I’m in contact with see it: Introduction of a total quantity of cartonboard for the whole EU in relation to merchant size/turnover/staff. E.g. 1 000 kg in total.

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a point in the planned implementation of the PPWR producer register, which can quickly become a real hurdle for small traders: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in French · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in Finnish · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in Spanish · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

With regard to PPWR, I call on the European Commission to adopt the power of attorney rule and to register for companies with fewer than 10 employees and less than 2 million employees. Annual turnover. From me, a central EU registration of the company with a total lump sum for all EU countries of max. 500 per year.

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a particularly problematic aspect of the planned PPWR producer register: the mandatory appointment of an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Ladies and gentlemen, we run a small online shop, previously sent to many EU countries. Unfortunately, due to the obligation to appoint an authorised representative in each supplier country and the resulting costs, we will no longer be able to offer this in the future. An exemption for small businesses or a de minimis threshold should be created as a matter of urgency.

Filed in German · English published by the European Commission

In the context of the consultation on the planned requirements for national producer registers under the PPWR, I would like to draw your attention to the serious burdens this entails, in particular for solo self-employed persons and micro-enterprises. I sell small online and would like to continue selling my handmade products as an individual to customers in other EU Member States.

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the owner of serviettenshop.de, a small online shop for decorative paper serviettes and suitable table decorations printed candles, serviettes, wipes, toilet paper, table runners and porcelain, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint…

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in French · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

As an operator of small online sales, I would like to comment on a point of PPWR implementation which, in its current form, does not act as regulation, but as a de facto trade ban: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

I operate a small workshop alone and sell 60% to customers in other EU countries. Most countries only 1 or 2 packages a year. The biggest 20 cardboard boxes. Licensing my packaging in my home country is affordable and relatively straightforward. Paying 26x VAT via OSS is clumsy but manageable.

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

Ladies and gentlemen, as the operator of a small online shop focusing on ECHTE Sustainability and Resource Conservation, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR Producer Register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border…

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

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

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

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

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

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

Filed in French · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

# Comments on the obligation of authorised representatives in EU online trade **Dear Sir/Madam,** as the operator of a small owner-run online trade in motorsports and car parts, we would like to draw attention to an issue of particular concern in our view regarding the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border…

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to an aspect of the planned implementation of the PPWR Producer Register, which has significant practical and economic implications, especially for small businesses: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Ladies and gentlemen, for many years I have been selling online on a small scale in Germany. I develop and manufacture accessories for motorcycles myself and have so far supplied customers in many EU Member States. For me, this is one of the great advantages of the European single market: A very small company can also produce specialised products and offer these customers across Europe.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in French · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to an aspect of the planned PPWR producer register which is, in my view, particularly problematic: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in French · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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