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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

As a small businessman, I am very worried about what the new rules on packaging registration mean for small businesses. I understand that packaging and its disposal must be regulated and I am ready to contribute to it.

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a particularly critical point in the planned implementation of the PPWR producer register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales. Selling abroad in the EU has been an obvious growth step for me as a small entrepreneur.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in Polish · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

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

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

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

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

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

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

Filed in German · English published by the European Commission

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

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

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

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

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

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

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

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

Filed in German · English published by the European Commission

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

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

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

Filed in German · English published by the European Commission

The objectives of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), in particular strengthening the circular economy and better capturing packaging flows, are basically understandable. However, administrative implementation risks placing a disproportionate burden on small and medium-sized enterprises in particular.

Filed in German · English published by the European Commission

The new EU directives (EPR & PPWR) represent a gross injustice. Until August 11, 2026, my company allowed me to support my family by selling a small number of shipments to the EU (only about 1 to 6 per country annually!). As of August 12, 2026, I was forced to halt sales. Chinese sellers, of course, continue trading with impunity.

I would like to draw your attention to the significant practical difficulties for micro-enterprises and solo self-employed persons arising from the new EU Packaging Regulation (PPWR). In principle, I support the objective of reducing packaging waste and making packaging as resource-efficient and recyclable as possible.

Filed in German · English published by the European Commission

Ladies and gentlemen of the EU, enywear GbR, a German small enterprise with an annual turnover of less than 500 k, has approximately 50 consignments per year to other EU Member States, i.e. 5 %. Current markets primarily AT, the plan is F, IT to be reached more intensively. Our product is robust, sustainable workwear made of 100 % plant fibres.

Filed in German · English published by the European Commission

Hello EU, I am an EPU from one of your member countries. Like so many others, the new regulation affects me and leaves me in some cases desperate, futile and angry. While I understand the rationale of this Regulation, its implementation has not been successful.

Filed in German · English published by the European Commission

Dear European Commission, I would like to tell you about the impact of the new rules from the point of view of an Austrian micro-enterprise. I operate a small handmade label in Austria and make my products by hand. In my work, I am conscious of the importance of durability, high-quality materials, bio-materials and the most responsible use of resources.

Filed in German · English published by the European Commission

This has such a huge effect on small businesses. While we all agree with the environmental issues, this will cull small businesses and stop them from expanding. We are not all global mega corporations and should not be punished for this. The little guy is always the one hurt the most when decisions like this are made.

The current design of the EU Packaging Regulation (PPWR) for small and medium-sized enterprises (SMEs) poses a serious threat to the free EU internal market. Instead of cutting red tape, regulation closes national markets.

Filed in German · English published by the European Commission

Hello! I am a self-employed micro-business owner in Lithuania, manufacturing handmade products and selling directly to customers across the EU. I fully support EPR and I am willing to pay the recycling costs for every kilogram of packaging I place on the market. The problem is not the recycling fee, but disproportionate administrative costs and mandatory intermediaries.

Ladies and gentlemen, I understand the objectives of the Regulation, but for me as a solo company it is an unmanageable mammoth project. The additional financial costs are in no way related to my small firm’s current and probably future income. Quite apart from the huge amount of red tape that needs to be dealt with in order to explore and understand this legislative jungle for the first time.

Filed in German · English published by the European Commission

The new EU regulation affects me very much as a small online retailer (small entrepreneur). I sell collectors’ items (stamps, postcards, etc.) through various auction platforms. Many collectors in Europe have already purchased from me over the past 25 years. I use used packaging for shipping, which comes from other companies and would otherwise be disposed of there.

Filed in German · English published by the European Commission

The new EU regulation on packaging and packaging waste will make it impossible for us to continue doing business within the EU. The procedure is too complicated for a small company and the costs are far too high. This makes small businesses exemplified and erased. A small allowance or a portal, which would certainly be authorised for all EU countries, would be useful.

Filed in German · English published by the European Commission

We have been active and operational as a micro-business since 2017. The new regulations make it impossible for us to compete in the EU market. Adapting towards a more environmental friendly way of packing and shipping is mandatory.

As an artist based in the Netherlands, I am concerned that the current approach to national producer registration and EPR requirements creates a disproportionate burden for micro and small businesses selling across EU borders. I sell photographic prints directly to private end-buyers in other EU Member States. To generate a modest but viable income, I need access to customers across the EU.

I strongly support the EU's goal of reducing packaging waste and protecting the environment. However, I am very concerned about the disproportionate administrative burden that the PPWR may place on micro-businesses and very small craft businesses. I run a very small craft business and ship approximately **10 parcels per year**. The amount of packaging I place on the market is therefore extremely small.

I understand the goals of PPWR, but the outcome is too extreme for businesses like mine where I am selling 500-1000 bottles of organic wine per year. I can easily declare that my glass bottles, labels, corks, wax and boxes are sustainable and recyclable, but the suppliers who produce these materials need to have the DoC available for me to download. The challenges I see are two fold: 1.

Regarding articles 44 and 45 of the regulation: Requering a legal representative in every single EU country is basically a paywall for small businesses and artisans. First thing - going through EPR and representative registration 27 times just to be able to sell to EU countries is expensive, time consuming and most os online shops run by a single person won't be able to comply. We just don't earn that much.

Dear Sir or Madam, For our small company, the European Single Market has effectively ceased to exist. Until recently, we sold small quantities of our products directly to customers in several EU Member States. However, due to the combination of fragmented national packaging and EPR rules and the new requirements under the Packaging and Packaging Waste Regulation, we have now been forced to discontinue all…

Ladies and gentlemen, as a sole trader with a small craft business in Germany, I can earn my living in this way financially. I do not have the time to deal with the bureaucratic burden of this law and I do not even understand my new obligations as a farmer after having spent a full working day informing me about the new law. On that day, I was unable to produce anything to sell it and generate money.

Filed in German · English published by the European Commission

Good morning, I run a secondary business and send second-hand records (cultural goods) from Germany to other EU countries. The volume will be around 100 per year, spread over around 12 EU countries. As a result, I got a lot of beautiful and nice contacts. The new rules are far too costly and time-consuming for me. That is why I stopped sending it from today. My acquaintances act accordingly.

Filed in German · English published by the European Commission

This law makes the European market into 27 small markets, where only the big players, that often don't pay any taxes here or only very little, are allowed to operate. What you are saying with this law is, that you like to help conglomerates like Amazon, but the small business owner has no right to sell into all European countries. This is supposed to be a union with free circulation of goods and services.

You are completely ruined by the need to check – and this is breaking the small traders. Did you put your bribes in Amazon’s own pocket? This is because this is the main profit of the already emerging trader’s death. And once again, what happened to cutting red tape in the EU? You are still packed with more!

Filed in German · English published by the European Commission

As Small business owner this law need a regulation based on the type of the shop, the quantities of the package and waste, ita not fair to put in all the businesses at the same consequences, we dont have the same impact like Amazon for example.

Ladies and gentlemen, the new requirements for packaging to be registered/licensed in each country and, in some cases, for an authorised representative to be established locally, entail considerable additional costs and red tape, particularly for solo self-employed persons and small businesses. The objective of reducing packaging waste is in principle understandable.

Filed in German · English published by the European Commission

As the owner of a small business in the Netherlands, started when I was 18 years old and I am now 36, I am deeply concerned about the disproportionate impact these registration requirements will have on small businesses. We will soon be paying the same fixed costs for registration and representation in multiple Member States as large multinationals, even though our volumes and margins are entirely different.

My feedback on the implementation of the new packaging rules The objective of reducing packaging waste and improving recycling seems to me to be useful in principle. However, I see a problem with the considerable bureaucratic and financial burden, especially for small and medium-sized enterprises. My proposal would therefore be to link recycling costs as directly as possible to the actual shipment of a consignment.

Filed in German · English published by the European Commission

As a micro-entrepreneur in the artisanal sector, I want to be able to send my products across the EU. The current obligations, in particular the appointment of an authorised representative in each EU country, are disproportionate for micro-enterprises and make EU-wide shipping hardly economically feasible. This effectively limits small businesses to the national market.

Filed in German · English published by the European Commission

In the time of increased energycost, geppolitical instability and tradewars with US and China, you decide that it would be a good idea to bankrupt small business owners and add to "red tape" that we so desperatly are combating in theory at least. When I thought that US was run by complete morons, you rushed in to join the club and prove me wrong

The regulation not only creates more red tape, it puts small businesses out of the single market. A person who sends only one handful of consignments of goods per year to another EU country cannot do so economically, as the costs are many times higher than the turnover. The burden is also immense. Nor can a small trader check where a carton or bag originally came from.

Filed in German · English published by the European Commission

I operate a small handmade business in Germany and sell through an online marketplace. I send only individual parcels to other EU countries each year. My turnover from these countries is < EUR 50. I expect to pay a much higher price per year for registration and authorised representatives in these countries.

Filed in German · English published by the European Commission

The PPWR is a poorly conceived regulation that places a disproportionate burden on small businesses, forcing them to navigate costly and confusing bureaucracy simply to trade across European borders. Instead of creating a genuine single market, it fragments Europe further, discourages competition and protects large corporations that can afford dedicated compliance departments.

I am a sole trader and microbusiness based in Spain, selling handmade products online directly to consumers across the EU. I fully support the environmental objectives of the PPWR and I already comply with Extended Producer Responsibility requirements in my home country. I also register and pay for packaging compliance in Germany.

Good evening, I think the idea of reducing waste due to imposed costs is correct. In our own business, however, the costs of registration and registration and representation in various countries are much higher than the actual waste collection fees. A large number of firms are burdened with additional work. Recording and billing of manufacturers/importers would be much more desirable.

Filed in German · English published by the European Commission

Im a small/micro business owner and while we only offer freelance service (graphic design), we always thought about opening a little web store for offering our own (non commissioned) creations as prints etc. In the last week my entire social media feed was dominated by fellow artists, illustrators & artisans who were trying to figure out how to deal with this new regulations.

Current regulations are absurdly unthinkable, declarating and destroying micro/small companies and individuals earning money on handicrafts. Personally, I cannot afford to pay intermediaries in every EU country, which at my former intermediary amount to around EUR 275 per country. When I get back to my student budget for one year, I now have to close my shop across the EU.

Filed in Polish · English published by the European Commission

We are Dejama Home Interiors, a family business run by my partner and me from Rotterdam. We sell one product motion-activated singing bird boxes through our own webshop, singingbirdbox.shop, to customers across Europe, Germany included. Under 60,000 in annual profit. Here is the whole problem in two numbers. The eco-fees we genuinely owe on our packaging a printed carton and a mailer come to about 50 a year.

This proposed law is absurd. It hinders small business to ship to other EU countries and causes alot more paperwork. The fees to arrange PPWR contacts in all EU countries are enormous and only allow large sellers like amazon etc to successfully sell in the whole EU. This must be stopped, we need less paperwork.

We are a small enterprise with fewer than 10 employees. Tenders for ERP authorised representatives start at 250 for each country per year for ‘small quantities’. We produce less than 250 raw materials in 1/3 of the EU countries. We do not know before which ones. This changes every year as we supply final consumers.

Filed in German · English published by the European Commission

I have always been a glowing supporter of the idea of the EU. I appreciate what weve achieved with it, and I will remain a supporter. But truth be told this is bollocks. Its not thought through, its poorly executed, and it makes the EU administration look like a lemonade stand. What are you thinking? How can you actively put small businesses under such pressure? Im not only talking about the laws behind it.

I support the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR), including reducing unnecessary packaging, increasing recycling and encouraging more sustainable packaging design. However, I am concerned that the proposed framework for national registers of producers could impose disproportionate administrative and financial burdens on European micro-businesses engaged in small-scale…

Ambinor AB is a small Swedish design company producing lighting products in Sweden. We fully support the environmental objectives of the PPWR and the principle that producers should take responsibility for the packaging they place on the market.

I strongly suspect that it is not this red tape that reduces waste, but because tens of thousands of small traders have to give up their internal shipments. Counter-proposal: only 10 employees and more than 100 kg of shipped material per country. It is not manageable for small traders under any circumstances. They are destroying tens of thousands of livelihoods and damaging the EU.

Filed in German · English published by the European Commission

Dear people, I was very afraid to take the news about the new rules under the PPWR. I have a small business, in addition to a permanent job, with which I send around 25 parcels per month. However, these new rules actually make this impossible for me. Having to register and pay for everything is not for a small ZZPer to do, and then the threat of fines actually means that I have to stop my own business.

Filed in Dutch · English published by the European Commission

I run a very small business in Sweden where I make handmade leather goods and sell directly to customers in Sweden, the EU and other countries. I fully understand why PPWR and EPR are needed, and I want to do the right thing. I already use cardboard boxes, tissue paper and as little plastic as possible. I also try to make sure there is very little empty space in my packages.

I am an artist and this regulation, as much as I agree with fighting packaging waste (I mostly use recycled packaging), is threatening my existence. To me and many other micro businesses, it equals a ban to sell to other EU countries and I don't know how to explain to my customers that from now on, it is possible for big companies like Temu to flood our markets, but I won't be able to sell a handmade piece of art to…

I am the owner and operator of a micro business in the Czech Republic. I make and sell pottery. I use only recycled packing materials. I am a micro business, I am the only employee. It is impossible for me to register with and pay all the fees now necessary to ship within the EU. These laws were made to regulate giant companies and are screwing over small artisans like myself.

Ladies and gentlemen, cardboard boxes are not only durable for one-off use. For years, we have been using ‘running’ cartons to send them to our customers. Some of the cartons we receive from our suppliers with goods, but also cartons we receive from neighbours or friends. This is not only a favorable form of packaging, but also a particularly environmentally friendly and resource-efficient form of packaging.

Filed in German · English published by the European Commission

Dear politicians, As a Small Business owner I simply cant comprehend how a law Like this could have ever been drawn up, let alone been passed. Treating small Businesses and Amazon the Same is Beyond absurd. No Small Business can afford the absolute Nightmare in paperwork Thats required now.

As a small handicraft company, the new rules hit me hard. I cannot afford to pay agents in other EU countries and can therefore only offer my handicrafts in Austria. Everything I am writing has already been said by others. And yet I can only ask for: Makes it compulsory for micro-enterprises to appoint representatives. Ensures affordable licensing. The best solution would be a one-size-fits-all EU solution.

Filed in German · English published by the European Commission

I have been reading through all these comments and I keep wondering what will happen a few years from now. First: create yet another problem for businesses. Then, for months or years, explain why it is absolutely necessary for our own good, the environment, safety and sustainability. Businesses will complain. Amendments, exceptions and simplifications will eventually appear.

I am writing as the co-founder of Luyana Skincare, a small EU-based skincare brand formulated in Copenhagen, to share my experience with the Packaging and Packaging Waste Regulation (PPWR), which came into effect on 12 August 2026, and to add my voice to the growing number of small business owners asking for a more equitable application of this policy. I support the intent behind PPWR.

This regulation is welcomed in terms of the intent - the large businesses that are putting literally tonnes of waste into the market. But there MUST be a smooth, affordable process for micro enterprises - my business has ceased overnight because of this. You are putting thousands of small businesses out of the market overnight! This creates a monopoly for large enterprises who can afford the cost of this initiative

Ladies and gentlemen, we strongly support the Regulation’s environmental objective of reducing packaging waste and strengthening the circular economy. However, the design of Extended Producer Responsibility (EPR) has unintended but devastating effects on the European single market and the existence of micro and small enterprises and international small suppliers. The key issues in detail: 1.

Filed in German · English published by the European Commission

The companies that create the pollution that this is meant to address are also the companies that can afford the exorbitant fees this enforces. Small businesses have no chance of competing and end up being entirely curtailed in terms of not only profit, but previous and current clientele that they have desperately depended on.

As the owner of a small handmade business based in Poland, I fully support the EUs environmental objectives and the goal of improving packaging recycling. However, the new cross-border EPR requirements create a disproportionate administrative and financial burden for micro-businesses selling small quantities to consumers in other EU countries. I sell handmade textile products through an online marketplace.

**Complementary to my previous feedback:** Europe is a community. And like in a family, it should be about enabling connections and fostering cohesion, not about bureaucratic hurdles dividing us apart. A common internal market should also feel like a common market for the smallest of us. Madlen Baumann MABA Ceramic Studio, Germany

Filed in German · English published by the European Commission

I operate a very small business in Germany and produce my ceramics myself. I want to make a proposal to simplify the packaging obligations for cross-border sales within the EU. I am expressly not seeking to take less responsibility for packaging. Small companies are also supposed to pay for the packaging they actually send to other Member States.

Filed in German · English published by the European Commission

Treating every business equally, rather than proportionately, does not create a level playing field. In practice, it means that small businesses will once again bear a disproportionate burden, ultimately resulting in reduced competition and less choice for European consumers.

Hello, I have been a craftsman since 2007. In recent years, because of the licensing/registration of packaging, I have been able to offer my unicellants only within Germany and non-EU countries because there are not enough orders from EU countries to cover the fees in each EU country. Nevertheless, I repeatedly receive disappointing requests from interested parties.

Filed in German · English published by the European Commission

We are a family-owned winery in Germany, Weingut Dönnhoff, exporting our wines throughout Europe and around the world. Every year we hear political commitments to reduce bureaucracy, strengthen SMEs and improve European competitiveness. Yet, in practice, we experience the opposite: new registrations, reporting obligations and administrative procedures are constantly being added. The PPWR is another example.

This new law is aiming to kill small businesses. From position of an artist, it makes it impossible to sell my products abroad, because fees for just one country would eat my monthly incomes, let alone more countries. As far as I want out environment to be safer from human impact, its not pro-environmental law. Its pro-corporations law.

This is insanity. I have heard it said it will cost £7000 to register and comply with these rules. My small business doesn't even make £7000 a year. This will cripple and destroy so many small business the world over, mine and my friends included. There needs to be some sort of allowance and exception for small businesses.

Dear EU Commission, I am fully in favor of greater sustainability and the avoidance of unnecessary packaging, especially regarding recyclability. I run a solo textil-upcycling business where I already prioritize sustainable packaging choices. I do consider many aspects of the new PPWR to be a very positive development. However.

While the idea is great for large companies and bad actors, it's terrible for smaller companies. As a micro business looking to expand into other sectors, we were disappointed to see this law come up. It makes it impossible for us to ship physical products to customers across the EU, even if the amount of packaging is extremely low.

I fully support the European Union’s environmental objectives and the need to reduce packaging waste, promote reuse, recycling and a truly circular economy. However, I believe that these objectives will only be fair and effective if the legislation takes into account the huge difference between large industrial producers and microenterprises, artists and independent craftsmen.

Filed in Portuguese · English published by the European Commission

I do not understand that this law does not take into account the volume of consignments. I am a French craft and I send a few parcels to several European countries. This is an activity I would have liked to develop, but if I have to pay one agent per country, it will not be profitable for me...

Filed in French · English published by the European Commission

I run a small, EU-registered independent music business (Spain) selling physical CDs and vinyl directly to fans worldwide, including across the EU. I support the underlying goal of extended producer responsibility, packaging waste is a real problem, and producers should bear the cost of it. My concern is with how this regulation implements that goal for small businesses.

This legislation goes directly against the first reason for starting the EEG by creating obstacles to trade among countries. With every country setting it's own fees, this is completely ridiculous to a so-called Union. It attacks all small businesses that want to trade within the EU, while big business will pay the fee and continue wiping out small businesses, that put their heart and soul in.

For several years we have been operating a specialised online shop for painting supplies (lackierbedarf.info) with 4 employees and a significant proportion of B2B customers who order important and sometimes time-critical products from us for their professional needs. So far, we have delivered across the EU, with a focus on Austria, France, Italy, Belgium and the Netherlands, as well as Switzerland.

Filed in German · English published by the European Commission

As a small business owner who has an own label tea brand and a store in a small community in the Baltic Sea, who sells only European made products. Im faced with two problems from the PPWR requirements. 1. is I can never enter another EU market to see if my teas will sell there because the costs will be too high to register in that market if it doesnt work out. 2.

I have a very small business and operate through a sales platform with vintage tableware and used design objects. I send a small number of parcels a year to different countries abroad in Europe. If the regulation were adopted as it stands, I would be forced to restrict myself to Germany or even abandon my business altogether.

Filed in German · English published by the European Commission

No shipment to countries of the European Union: EU bureaucrats have decided that all traders shipping to countries in the European Union must have a registration number and an authorised representative in each country. This registration is subject to several hundred euros of annual fees in each country. This amounts to more than EUR 10000 per year. None of the smaller traders can afford this anymore.

Filed in German · English published by the European Commission

I am a small business Based in Estonia who is mostly sells digital products, but this year we decided to also sell physical products all around Europe. Now with this new regulation, it is basically impossible... Please take into consideration talking to small businesses as well, not just big corporations. This new rule will wipe out most of us and leave no place for growth...

Ladies and gentlemen, I sell small quantities of textiles online in Germany and send only very small quantities of orders to other EU Member States. I strongly support the objectives of the PPWR to reduce packaging waste and promote recycling and sustainable packaging.

Filed in German · English published by the European Commission

This new Vetpackungsverordnung destroys many small German companies, as they cannot afford the representatives they need. There are already enough authorities that could do this in the EU country & do not generate further costs!

Filed in German · English published by the European Commission

I am the founder of a small skincare brand based in Norway (an EEA member). We are a micro-business that relies on every sale that comes our way, with an established customer base across the EU, both B2B and D2C. In 2026, we were recognised with Eco-Awards for Best Circular Beauty Brand and Best Recyclable Beauty Brand.

In this way, the entire European trade of non-groups can be paralysed and truncated. Why don’t you really talk to us professionals who do their e-commerce business on a daily basis? This is where things are decided that are completely unthinkable at the back and at the front. If you want us to stop SMEs, you just have to say it. Who, apart from the big corporations, should be able to afford this?

Filed in German · English published by the European Commission

We have run a small online shop for 10 years and have customers worldwide. We have always sent our hand-printed T-shirts in Berlin completely plastic-free bags made of recycled paper. With the new EU Packaging Act, we are facing such a significant additional burden, both bureaucratic and financial – that we must seriously ask ourselves whether sending parcels to EU countries every year makes sense.

Filed in German · English published by the European Commission

As a one person, disable small ceramic business owner making a few hundred a month in total it would force me to close the only activity I have. The EU is meant to unite, facilitate and support business across EU countries and be enticing for people in the EU.

As a small trader, I am no longer able to send EU-wide because of the requirements for registration and local representatives in each supplier country. It is simply not worthwhile for a few parcels, while large distance sellers, especially those based outside the EU, have huge advantages here. Small traders and, above all, citizens from other EU countries who can no longer shop cross-border lose out.

Filed in German · English published by the European Commission

Hello, what we should pay for, where there is a Union, it is becoming increasingly complicated, opaque, bureaucratic, there are even more shamewords, I think who represents craftsmen and small businesses, because MEPs have ever questioned us, who know what life costs. There is the proverb: Craftsmanship has Golden Boden. It is more likely that craftsmanship should be called a barrel without ground.

Filed in German · English published by the European Commission

I have a very small online company in Austria. My annual profit is around EUR 4000. In 2025, I sent 150 parcels within Austria and two to Germany. I have used the packaging repeatedly for environmental reasons. I cannot remember that I have ever bought a carton. I have all licences so far. But what now comes at a cost is a bribe. Did anyone think of the little ones in your mind? It’s a brittle thing you do with us.

Filed in German · English published by the European Commission

Ich betreibe in Deutschland einen Kleinstbetrieb im Handmade-Bereich und verkaufe meine Produkte über einen Onlinemarktplatz. Ich liefere derzeit nur in sehr geringem Umfang nach Österreich: etwa 5 Pakete pro Jahr. Mein Umsatz aus Österreich liegt bei ca. 1.000 Euro brutto pro Jahr. Ich liefere meine Produkte unverpackt an ein österreichisches Fachgeschäft.

I am the owner of a small business that sells products to customers across different EU countries. Mandatory EPR registrations, fixed fees, and the requirement to comply with separate administrative procedures in each country create a disproportionate financial and bureaucratic burden for micro-businesses.

This is a horrible, expensive and time consuming piece of legislation for micro businessss already struggling with tariffs.Whilst I appreciate the intent to minimise waste and packaging this legislation is unnecessarily burdensome for small businesses... different rules and prices and paperwork for each EU country?it beggers believe that the EU is implementing this.

As an illustrator, I am self-employed with my art and sell art prints, postcards, stickers and other products through my shop. Of these, I produce most paper products myself, in small print, after ordering them. This minimises waste generation. My packaging is recycled and consists exclusively of paper and cardboard.

Filed in German · English published by the European Commission

It’s incomprehensible! Why not an elegant, pragmatic solution? Just cut a small amount of obolus per package centrally and the EU distributes the money? The money is not used for the very purpose... This is suicide for every small trader without millions of profits! Cumbersome, expensive, and over ambiguous third parties, where none knows where the money ends up. Thank you very much, but only the EU can decide.

Filed in German · English published by the European Commission

From a common European internal market, which was once the original idea of the European Union, this bureaucratic monster turns national, locally isolated markets back into national markets. In fact, the PPWR costs constitute a market entry fee for each individual target country.

Filed in German · English published by the European Commission

Unfortunately, a small company like ours, with perhaps 5-10 packages per EU country per year, cannot be funded or implemented. I asked about the costs via Linzezero and, if I used 2025 as a basis, I would pay around 3000 per year for nine EU countries supplied, without calculating the additional costs.

Filed in German · English published by the European Commission

As the owner of a small one-person company, I expressly support the objective of reducing packaging waste and financing the actual disposal costs in a polluter-pays-friendly manner. However, the current design of Extended Producer Responsibility (EPR) places disproportionate burdens on micro-enterprises, artisans and small online traders.

Filed in German · English published by the European Commission

I operate a small handmade business in Germany and sell through an online marketplace. I send around 20-30 parcels a year to 4-5 other EU countries. My turnover from these countries is less than EUR 1500. For registration and plenipotentiary ONLY for these 5 countries, I would probably have to pay EUR 4800 per year.

Filed in German · English published by the European Commission

Feedback on the EU Packaging Regulation PPWR from the perspective of a small online trader Since 12 August 2026, the new EU Packaging Regulation PPWR applies directly in all Member States. With this letter, as the operator of a small online shop, I would like to give my feedback on this Regulation because, in practice, it hits precisely those businesses that actually contribute the least to packaging waste.

Filed in German · English published by the European Commission

In principle, we support the objective of reducing packaging waste and making producers more accountable. However, the current design of the requirements poses significant practical and financial problems for small and medium-sized distance sellers. As a German company, we have been sending directly to customers in almost all EU Member States for many years.

Filed in German · English published by the European Commission

As a small trader and operator of an online shop, I am increasingly wondering how much bureaucratic burden a small business can actually still cope with. Has this new EU Packaging Regulation ever been viewed from the perspective of craft businesses, traders or online shops? Companies without their own legal department?

Filed in German · English published by the European Commission

Regardless of when the PWPR was first passed, the fact so many businesses are only finding out about it on the week of its enforcement is in itself a testament to how poorly this has been considered and subsequently executed.

I cannot believe that the policy has not taken into account what the innovations mean for small farms and to whom they ultimately help. Amazon & Co and cheap China vendors, which are likely to remain silent, are again the winners, even though they are actually the reason for a standardised regulation.

Filed in German · English published by the European Commission

Subject: Opinion on the EU Packaging Regulation (PPWR) Urgent adaptation needs for micro-enterprises Dear Sir/Madam, as micro-enterprises with fewer than 10 employees, we strongly support the environmental objectives of the new EU Packaging Regulation. However, in its current form, the Regulation presents us with administrative and financial hurdles that threaten the very existence of a company of our size.

Filed in German · English published by the European Commission

The regulation is confusing, unclear, badly documented and seems to involve a huge regulatory burden for a two-people enterprise. I need to focus on daily operations and R&D work, not compliance. We are sending about 50 small packages per year to B2B and B2C customers in the EU. Our packaging is 100% cardboard and paper.

As a micro-business, the authorized representative costs are far too high for me to manage. The upfront and annual costs are so high that it is a complete barrier to continue selling my meaningful art to people across the EU. This kind of barrier will bankrupt businesses like mine. Please make a unified registration with a reasonable registration fee. My packaging is already compliant, I have the DOCs.

I am one of the arguably many small businesses that no longer sees any possibility of shipping outside D in the EU as a result of this scheme, which provides for registration in each country to which delivery/potential delivery takes place and corresponding payments in each country.

Filed in German · English published by the European Commission

In its current form, the PPWR Directive constitutes an unacceptable barrier to intra-European trade. The mandatory and inconsistent appointment of proxies in each of the 27 EU Member States creates disproportionate hurdles for small and medium-sized enterprises, with huge annual costs and excessive administrative burdens.

Filed in German · English published by the European Commission

I started to establish myself in an absolute niche environment 4 years ago, i.e. I create wigs for shows and events. I produce this from scratch with me at home alone. This project is a matter of my heart. I only produce contract work and send it out. I do not have a shop because I cannot afford it. The fees I already have to pay in Germany (IHK, LUCID, Grüner Punkt, Steuer...) are already a very heavy burden.

Filed in German · English published by the European Commission

To the European Commission: The current PPWR and EPR laws are creating fear and uncertainty in small and middle size companies within the EU and push them for more administrative tasks and additional costs. I own and run a small bike store and I rely on exports from Austria to the EU internal market, because I sell specialty bike parts that are extremely hard to find anywhere else.

I'm agree that packaging needs to be controlled, specially with big companies as Amazon but did you forgot small business don't play in the same yard? I'm an artist, I hardly can survive from my work. Little sales (5 maximum per year in different countries of Europe) can make a big impact in my economy. My packaging is fully created with recycled material.

Plain and simple: I can only express my contempt for the EU. They force me, as a small online trader, to abandon shipping to other European countries. Amazon and Co., as well as ALL Chinese zero-law traders, will benefit. Lobbying works. What or how much persuasion was done? The madness cannot be explained otherwise. I hope that Germany will draw the consequences here, as GB has done. Yours faithfully, [name removed]

Filed in German · English published by the European Commission

Dear European Commission, I am happy to support the basic idea of waste reduction and prevention. In my view, all decisions and current packaging regulations are disproportionate and not cost-effective for smaller companies. I have been using my suppliers’ cartons and fillers for re-dispatching for years. I would urge you to revise the decisions for smaller companies.

Filed in German · English published by the European Commission

Ladies and gentlemen, I operate a small handmade business in Germany and sell my products via an online marketplace. Last year, I sent around 200 packages to other EU countries, and even so deliberately only to countries where micro-enterprises were subject to de minimis thresholds or simplified rules, such as Italy or the Netherlands.

Filed in German · English published by the European Commission

EU directive 2025/40 goes against the EU's commissions' ambitions to remove internal trade barriers and to reduce administrative hurdles for small and medium companies. It imposes unneccesarily high administrative and financial burdens, especially so for small companies, in comparison to the rather minimalistic goals as stated in the directive.

I run a small online shop in Germany. I sell vintage goods, mainly porcelain and tableware, all over the world. Until now, the possibility of shipping within the EU has already been severely restricted by the individual EU Member States. The new rules on packaging, which will apply from 12.8.2026, will bring my business to the EU to a complete standstill.

Filed in German · English published by the European Commission

For artisans and small businesses, PPWR effectively means the end of the European single market. Like many who have shared feedback, we are a small independent business (a bookstore). We invested heavily in digital infrastructure to be able to offer EU customers an alternative to Amazon and the like for books.

We have heard of de-bureaucratisation for years, but the opposite is true. PPWR drives it to absurd new heights. The burden is enormous. Even for easy-to-identify materials such as glass or cardboard, comprehensive certificates must be collected and declarations of conformity drawn up from them. In some cases, packaging sizes differ from one supplier to another.

Filed in German · English published by the European Commission

I operate a small handmade business in Germany and sell through an online marketplace. I think it is basically good that less waste is produced. That is why I use cartons of purchased goods again. I am certainly not the only one. I send around 6 – 8 parcels per year to 2 EU countries. My turnover from these countries is around EUR 10.

Filed in German · English published by the European Commission

As a small studio in Ireland, employing four people including myself, we have put a lot of effort over many years into building up customers across Europe. However, these regulations are making it impossible for us to sell to most EU countries as the admin and financial cost is simply too high.

Sorry but did the EU just destroy every small online shop within the EU?, registering this costs a company 1000s of euro's for maintaining this including representatives, I already have weeks of work for the "1 stop shop" VAT registration and now this? good green packaging is fine but this is absurd, and why on such short notice? , i haven't heard anything of this?

Dear European Commission, I fully support the EU's efforts to make Europe cleaner and reduce packaging waste. However, as a very small business owner in Slovenia producing artisan lamps, I am concerned about the impact of the new PPWR requirements on micro businesses like mine. We sell only 1 to 50 lamps per year to customers in each individual EU country.

Dear European Commission, On the one hand, it makes sense to contain and regulate packaging waste. But it makes no sense to use a bureaucratic monster like the PPWR to force small, creative solo companies into their knees and even to abandon them. With the PPWR, they are destroying the diversity of entrepreneurship and at the same time leaving the big corporations free!

Filed in German · English published by the European Commission

Micro-enterprise impact of PPWR Article 45 and fragmented EPR registrations Although I fully support the attempt to be more environmentally friendly and Im happy to pay for my packaging waste, these new laws are sadly killing all small businesses. It would be helpful if: 1.

I am a small business owner on Etsy, and the current implementation of the PPWR risks forcing me to withdraw from cross-border sales because the fixed compliance costs are completely disproportionate to the very small quantities of packaging I place on the market. Is this really your goal? To force small businesses like mine to stop selling to customers in other EU countries?

We are an Austrian manufacturing company producing packaging made of cardboard and corrugated board. In principle, we welcome the objectives of the PPWR: reducing packaging waste, increasing recycling and making the circular economy work are important and necessary objectives. However, the current implementation is of great concern to us.

Filed in German · English published by the European Commission

I welcome the objective of harmonising certain elements of Extended Producer Responsibility schemes for packaging across the European Union. A clearer and more coherent framework can help reduce administrative fragmentation and support environmental objectives.

I am a Dutch micro-enterprise planning to sell handmade sterling-silver jewellery through my own webshop. I expect fewer than 50 B2C cross-border sales per year and use only a few kilograms of paper/cardboard packaging (no plastics).

Feedback on the PPWR to cut red tape for the EU single market through a one-stop shop The Packaging and Packaging Waste Regulation (PPWR) pursues important and correct environmental objectives. However, as a small company that has recently taken the step from the German market to EU-wide distribution, I would like to provide urgent feedback on the practical implementation.

Filed in German · English published by the European Commission

I have a small vintage trader (used design classifiers in the mid-century sector) in a one-person company and have been passionate about this for over 20 years. The idea of sustainability has been the focus of 100 % of the design classic – furniture we sell from the 60s to 70s and will certainly continue to be used by the new owner for the next 50 years. Packaging location hits us very hard as vintage traders. E.g.

Filed in German · English published by the European Commission

Irrespective of the good intentions, the provision in its current form is completely secondary. After every second statement stressed the importance of bringing the EU closer together, cutting red tape and completing the single market, such crazy rules were adopted, which were diametrically opposed and had the opposite effect.

Filed in German · English published by the European Commission

I am a self-employed illustrator and small business owner based in Spain. I sell physical products through Printful and Printumo, where products are manufactured and shipped directly to customers, and I also ship printed and textile products directly from Spain. The new PPWR and EPR requirements create a significant burden for a one-person business.

Agreeing to push for waste reduction, I disagree that this is the way. According to Eurostat data, there are 34.7 million enterprises in Europe: 93 % are micro enterprises (0-9 persons employed) 6 % are small enterprises (10-49 persons employed) 0.8 % are medium enterprises (50-249 persons employed) 0.2 % are large enterprises (> 249 persons employed) How many of the 93 % micro enterprises (and even 6 % of small…

Filed in Spanish · English published by the European Commission

Although I agree with EPR in principle the fact that there is a requirement to register, record and pay fees for EVERY EU country is not only very time consuming but also expensive and difficult for a small business to cope with. I feel the EU should have a threshold that any sales below in the country does not need to do EPR or there is a system where all EU countries can be covered in one EPR registration system.

Subject: PPWR Implementation Is Failing the SMEs the EU Claims to Protect To the European Commission, I am the founder of a small, women-led fashion business operating across the EU, writing to formally object to how the Packaging and Packaging Waste Regulation (PPWR) has been implemented and communicated to the businesses it governs.

Subject: Feedback from an micro-enterprise: Disproportionate financial and administrative burden of current EPR/packaging regulations on cross-border e-commerceTo whom it may concern,I am writing to share feedback from the perspective of a micro-enterprise based in Latvia.

Hello, I'm a german artist and I would like to still be able to sell my paintings and prints within the EU in the future. Small businesses simply cannot afford what the new PPWR regulation wants from them. Please, don't let small businesses, art and culture in Europe die!

In principle, I welcome the EU’s objective of reducing packaging waste and ensuring that producers contribute to the costs incurred in disposing of it. However, for micro-enterprises and especially for very small cross-border shipments, the implementation currently foreseen is disproportionately complicated and costly.

Filed in German · English published by the European Commission

Dear European Commission, I generally welcome the idea behind the EU Packaging Regulation (PPWR) of reducing packaging waste and strengthening the circular economy. I fully support the EU’s environmental objectives. However, individual companies such as mys were completely omitted from the requirements.

Filed in German · English published by the European Commission

In principle, I support the aim of the Packaging Regulation to reduce packaging waste, promote recycling and make packaging more sustainable. At the same time, I consider the current set-up to be disproportionately burdensome for micro-enterprises and in particular for one-person enterprises and small handmade enterprises.

Filed in German · English published by the European Commission

Ladies and gentlemen, we operate a micro-business in the creative sector in Germany and sell mainly through our own online shop. We send around 270 parcels a year to 17 other EU countries. Our turnover from these countries is EUR 23.000. We expect to pay around EUR 10.000 per year for registration and plenipotentiaries in all these countries.

Filed in German · English published by the European Commission

Theben Smart Energy GmbH welcomes the objective of Regulation (EU) 2025/40 and supports, in particular, an effective design of Extended Producer Responsibility (EPR), high transparency of packaging volume data and ensuring a well-functioning European internal market.

Filed in German · English published by the European Commission

Hello – I am a small craftsman and a one-woman show and it’s definitely sat! These and many other rules break the genocide of micro-enterprises, we take time to red tape, in time we could have generated turnover and collected corresponding taxes for the state.

Filed in German · English published by the European Commission

In principle, the overall objective of the Regulation is to be welcomed, but the practical arrangements for its implementation prove to be highly dysfunctional. As an operator of online sales for Italian wines and fine foods at www.vineola.de, we are directly confronted with insurmountable regulatory hurdles.

Filed in German · English published by the European Commission

I run a small Portuguese brand of personalised products, based in the Azores, operating on a made-to-order basis. We hold no stock. Each order is produced and dispatched by production partners located in different Member States and reaches the customer in a simple cardboard or paper mailer. The draft leaves genuine practical questions unanswered for this model.

We receive essential food raw materials and goods every day, which we use for our European and global customers to produce key end products. According to its legislation, we are no longer able to guarantee production as of today, as we do not yet have a solution for our suppliers. (90 % small certified farms) Similarly, it concerns our supplies to the EU.

Filed in German · English published by the European Commission

The law is obviously made by lawyers, but not by practitioners. Why is it not possible for small and micro-enterprises to declare the quantities of packaging used to the contracted shipping service provider (e.g. DHL, Deutsche Post) and pay the disposal costs there directly for each individual case, together with the shipping fees? With a small mark-up for the service, if applicable.

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 burdens this may entail for small online traders. I am a small e-commerce business and would like to sell my products to customers in other EU Member States. However, I am deeply concerned about the registration and reporting obligations associated with the PPWR.

Filed in German · English published by the European Commission

This is insane to have different systems within EU countries for packaging. Surely the benefit of us all being in the EU is to share the same system? Further, to charge an annual fee per country is ridiculous. Why can it not work like the VAT system? This will stop small businesses from operating within the EU, they will become restricted to trading solely within their own country.

As a small online trader, I am deeply concerned about the new registration and extended producer responsibility requirements in each EU Member State. I expressly support the environmental objective. It goes without saying that small businesses must also take responsibility for the packaging they place on the market.

Filed in German · English published by the European Commission

The rule itself to reduce waste on packaging is not the problem, thats good. But to register in every country, with too high costs of 300 plus per country for a business that relies on international business to other countries thats not what the EU stands for. It should help us to grow and not to destroy business with laws that are standing in the ways of the businesses.

It is deeply and deeply saddened by this regulation I now have a small company for over 16 years that sells 2 of the hand audio equipment. I sell this on the German eBay. This regulation forces me to stop 27 of the 23 countries in the EU! Simply because the costs do not stand up to what I would pay in those countries if I continued to sell there. At least 300/600 per year per country.Some countries are e.g.

Filed in Dutch · English published by the European Commission

In my view, the EU should simplify procedures between Member States. This is not the case here. On the contrary, it results in smaller traders losing part of their turnover and thus also of their visibility abroad. Please ensure a uniform system of packaging licensing for all countries and the exemption of representatives for small firms.

Filed in German · English published by the European Commission

Opinion on EU packaging and EPR obligations for micro-enterprises I support in principle the objective of reducing packaging waste and promoting more sustainable packaging. However, I consider the current design of the cross-border EPR and packaging obligations to be disproportionate for micro-enterprises.

Filed in German · English published by the European Commission

I am running a small onlineshop in Germany since 2003 with one co-worker. The PPWR will affect our business deeply and comprises an extreme amount of bureaucracy and cost that does not stand in any reasonable proportion to its true objective. It creates new limitations within the EU and creates an extraordinary amount of extra work especially for the huge amount of small businesses.

I operate a small handmade business in Germany and sell through an online marketplace. I send around 10-12 parcels a year to 5 other EU countries. My turnover from these countries is around EUR 600. I would probably pay at least EUR 650 per year for registration and authorised representatives in these countries.

Filed in German · English published by the European Commission

I strongly support the PPWR’s objectives of reducing packaging waste, improving recycling and making producers more accountable. However, from the point of view of a small business, I see a significant need for action in the practical implementation of extended producer responsibility and national producer registers. Small enterprises do not have their own legal or compliance departments.

Filed in German · English published by the European Commission

As a small European craft company, we support the objective of reducing packaging waste and promoting recyclable packaging. However, the current design of the scheme means that small producers and manufacturers will have to stop shipping to many EU Member States.

Filed in German · English published by the European Commission

Dear EU team, while I am a big fan of recycling and sustainability and believe it is the utmost import thing we need to do for our planet I have huge problems with this new act: Being a small ecommerce shop I have stopped all EU activities and from now on only ship nationally - I cannot afford to register in all those countries where in some I might be delivering 5 in other 10 and in other 25 products over the…

European e-commerce must not become a bureaucratic trap! Our business model is fundamentally exactly what the European Union should promote: We are a small European company, creating jobs, paying taxes and selling our products within the European single market. We are innovative, we work for our livelihood and for a beautiful, diverse Europe!

Filed in German · English published by the European Commission

1. The PPWR should clarify that the return shipment of a consumers own repaired property does not fall within producer-responsibility obligations where the business is providing a repair service and is not placing a new product on the market. 2.

I strongly support the environmental objectives of the Packaging and Packaging Waste Regulation and the principle that businesses should take responsibility for the packaging they place on the market. However, I am deeply concerned about the disproportionate administrative and financial burden that national producer registration requirements can create for microbusinesses and very small producers selling across the…

I am the owner of a micro-enterprise in the Azores, Portugal, with a small team. We sell made-to-order products online to customers in several Member States. I support the environmental objectives of the PPWR and I am not asking to be excused from paying for the packaging we place on the market. My objection is to how the fixed costs of compliance fall.

Feedback from a micro-enterprise in e-commerce based on Terceira Island, in the Azores. The question I would like the Commission to weigh is simple. What is the marginal environmental benefit of requiring an operator who places a few hundred kilos of paper and cardboard on a national market to enter a national register, pay entry and maintenance fees, file annual reports and, in several Member States, retain a paid…

Ladies and gentlemen, the PPWR undoubtedly pursues important environmental objectives. However, in its current form, it disproportionately affects one-person companies and small businesses. The requirements for documentation, recycling rates and labelling requirements require human and financial resources, which we simply lack.

Filed in German · English published by the European Commission

Ladies and gentlemen, on the planned requirements for the national producer registers under the PPWR, I would like to draw your attention to the burdens this may entail for small online traders. First of all, however, I would like to make a general remark: Since January 2023, it has been mandatory to appoint an authorised representative for shipments from Germany to Austria, which we had already done at the time.

Filed in German · English published by the European Commission

Distant red tape destroys micro-enterprises and destroys the EU’s internal market Opinion: The present regulation on the Packaging Ordinance is a stark illustration of the progressive failure of bureaucratic regulation in the European Union.

Filed in German · English published by the European Commission

Ladies and gentlemen, I run a small online shop in your constituency. The EU Packaging Regulation will apply from 12 August 2026. I send 100 parcels per year to hundreds of other EU countries. I need a separate registration and an authorised representative for each of these countries. Expenses: several hundred euros per year per country. My total foreign turnover is EUR 4000 per year. There is no de minimis limit.

Filed in German · English published by the European Commission

I run a micro-business on Terceira Island in the Azores, an outermost region of the European Union. We sell personalised products online, mostly to the Portuguese diaspora living across the Member States. For a company based on an island in the middle of the Atlantic, online sales to the rest of the EU are not one channel among several. They are the only way to reach a market large enough to survive.

Ladies and gentlemen, it is practically impossible for small businesses to meet your packaging requirements. Red tape and costs are immense – with relatively small quantities of packaging. In my case, the costs significantly exceed the profits – between 1 and 10 parcels per EU country.

Filed in German · English published by the European Commission

This regulation drives small businesses out of business, because a small business will have no resources to make all the administration this regulation requires. Basically a one-person micro business, such as mine, have to make the same admin as a large, multi-million euro business.