Implementing rules on registering in and reporting to the register of producers
2388 submissions from 2178 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
Who showed up
2312 submissions from industry — companies and their trade associations — against 10 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 231.2 industry submissions for every one from civil society.
Industry 2312Civil society 10Public authorities, academia, other 66
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation is open — 11 days leftto submit. It closes on 10 Sept 2026.
Responding? PolicySpeak drafts consultation responses grounded in your organization’s own positions. Request access.
This new set of rules makes it hard to scale small businesses in niche markets with little monthly transactions, so that new jobs can be created, bigger investments can be realized. Please make the rules applicable without imposing barriers to EU citizens. This regulatory setting is only helping big associations that can afford to increase prices on microscale.
It makes sense to encourage more recycling and significantly reduce the use of packaging materials with harmful environmental effects. However, this regulation does not go in the right direction. An EU regulation with national registrations is a contradiction in itself. It is not a good idea to regulate normal shipping boxes directly via the consignor.
Filed in German · English published by the European Commission
PPWR disproportionate burden for micro-enterprises I run a micro-business in the Netherlands selling jewellery online. I sell approximately 100 items per year in total to consumers across the EU. I fully support the goals of the PPWR: reducing packaging waste and improving sustainability.
This system is a disjointed, shambles, created by IDIOTS who have never ran a micro business. It is massively cost prohibitive, confusing, unfair when the chinese giants who pollute Europe have all the means and staff to be compliant. It unfairly effects sole traders, microbuinesses and SMEs of all sectors, it will directly cause your economy to fail, it will create unemployment, homelessness and suicides.
I consider this regulation to be absolutely essential in order to reduce the amount of waste produced by large distributors such as Temu, etc. But there is a difference to be made with SMEs, companies like us, which, even before the first package per EU country, have to register for Torres with each of the 27 EU countries, and the bureaucratic requirements that have to be met per country are too heavy for small…
Filed in German · English published by the European Commission
As a very small handmade business based in Poland, I strongly support the objective of reducing the administrative burden created by different national packaging producer registration systems across the EU. I sell handmade ceramics online to customers in different EU Member States.
We support the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR), but we believe the regulatory and financial obligations being introduced are disproportionate and should not apply to micro and small enterprises in the same way as they apply to large corporations. We are a Swedish company with four employees. We sell our products to customers and small businesses across the EU.
I am a self-employed micro-business owner based in Spain. I support EPR and responsible packaging waste management, but requiring separate registrations, reporting, fees and representatives in every EU country creates a disproportionate burden for small businesses. A small business may make only a few sales per year in a particular country, while compliance costs could exceed the revenue from those sales.
I am writing as a self-employed product designer and ceramic and glass artist based in Germany. I produce handmade, small-scale products and sell them directly to customers. Each year, I send only approximately 20-50 parcels to customers in other EU Member States, in addition to my domestic sales.
Good afternoon. Do you really want to have soon only groups like Amazon as international trading companies? This law puts small businesses at a disadvantage to such an extent that it is a scandal! Who should be able to afford an authorised representative for packaging in another country if he sends only two packages per year to that country?
Filed in German · English published by the European Commission
The PPWR in the announced version is not proportionate for micro-enterprises. The already small profits for micro-enterprises will be destroyed by this Packaging Ordinance. As a result, many micro-enterprises are faced with the question of whether they should continue to operate at all or whether they should stop operating.
Filed in German · English published by the European Commission
1. There should be a single EU database for registering companies, with a single fee for the whole EU, and now each country has its own rules and fees. 2. Fees should be charged only once to producers of foliops/boxes/labels, now the same packaging is taxed several times, and the retail client pays again for the same garbage at the end of the day. 3.
Filed in Polish · English published by the European Commission
As micro-enterprises, we fully support the PPWR’s objective of increasing sustainability, but the current design puts our existence at risk. Without pragmatic de minimis thresholds, the European Packaging Regulation is hitting us hard: The obligation to register, report quantities and appoint local representatives in each EU country of destination creates a bureaucratic and financial burden that small businesses…
Filed in German · English published by the European Commission
I am a small Dutch entrepreneur and sell my own card decks and books through my online shop and online sales platforms. My sales are mainly in the Netherlands and Belgium. I understand the purpose of the PPWR and consider it important that we handle packaging and packaging waste responsibly.
Filed in Dutch · English published by the European Commission
Studio Koter is a UK childrenswear brand. We sell wholesale and direct to consumer into 12 EU countries. Four are wholesale markets. In the other eight we average 14 direct to consumer orders per country per year. Total turnover is around £250,000, of which roughly 25% is EU. Most of the EU revenue is wholesale, on margins already tightened by post-Brexit duties. Registration is per country, and that is the problem.
This legislation will single-handedly destroy thousands of small businesses (and countless dreams) in the EU. 1. Please exempt us small small business owners from having Authorized Representatives in each individual member country. It is a disproportionate measure for those of us who don't ship high volumes of packages to different countries and would be an enormous financial burden that most cannot afford.
What happened to the concept of a single Market: a border-free internal market where goods, services, money, and people move freely. These regulations put up barriers to trade within the union. They may be small barriers to big businesses but they are insurmountable obstacles to micro enterprises. Micro enterprises that bring these benefits to the economy.
I have been the founder of a small company in the field of home textiles since 2024. It was only a few months ago that I changed my mind: internationally, I wanted to win the European market for me. With the new regulation, this is hardly possible for me as a small label, as the first orders from Austria, the Netherlands, France and Spain, for example, arrive with me, but around 1-10 pieces, so I do not currently…
Filed in German · English published by the European Commission
The proposed EPR and PPWR regulation, in its current form, threatens the existence of micro-enterprises. It particularly affects a particularly vulnerable and at the same time vulnerable economic group: traditional crafts as well as the many creative small businesses led by women and FLINTA (Creative Woman/FLINTA-owned Businesses).
Filed in German · English published by the European Commission
I am a sole trader running a small 3D-printing business in Germany as a secondary occupation. I manufacture custom parts and prototypes, often as one-off orders or very small quantities. One of the things I value most about the EU Single Market is being able to accept unusual small projects from customers throughout the EU.
The current rules are very unclear and unnecessarily complicated. As far as I can tell at the moment, the costs are too high for small webshops, making it no longer worthwhile to ship to neighbouring countries. On top of that, businesses have to register separately in each country and deal with different rules and systems. Surely this could be organised much more efficiently through one EU-wide system?
We are a small business (leather goods) based in Berlin. Production and materials come entirely from Germany, we create jobs domestically and we strive to comply with all rules. Our shipment to other EU countries is minimal: max. 5 parcels/month to France, 5 to Belgium, no hundreds of parcels, as the rules actually require. Since the pandemic and crises, our economic situation has been strained anyway.
Filed in German · English published by the European Commission
As a small, owner-run online shop for textiles, I also rely heavily on my European customers. I can no longer afford to meet the conditions laid down and fear that this loss of turnover will make it impossible for my business to continue.
Filed in German · English published by the European Commission
I am a creative craftsman and I am the sole manager of a French micro-enterprise for the creation of handmade jewellery. I fully support the goal of reducing packaging waste and making businesses more accountable. However, the obligations laid down for cross-border sales are likely to have disproportionate consequences for micro-enterprises such as mine. My activity is very small.
Filed in French · English published by the European Commission
Hello. I am an entrepreneur and in the company I create various kinds of crafts of wood. Now that I am going to send these to other European countries, the new law will make it more difficult for me to send these goods as I will have to pay a fee per country. Of course, I think the environment is important and only use recyclable packaging materials.
Filed in Swedish · English published by the European Commission
These rules are completely disproportionate for micro and small businesses. A business shipping a few kilos of packaging to another EU country should not face hundreds of euros in fixed fees, separate registrations and mandatory local representatives.
As a small second hand business I am all for recycling and sustainability. But as many others suggest this new law will kill so many small businesses. I would dare to say it will wreck the EU economy as we know it. It will completely destroy creative and sustainable businesses selling online. Large corporation will just pay their fee and keep polluting like they have always done.
Ladies and gentlemen I operate a small jewellery label in Germany. I have no employees, no legal department of my own and no 7-digit turnover. The new Packaging Ordinance has good approaches, unfortunately it hits small businesses like me disproportionately hard. How should my company grow, how should I continue to sell my jewellery if I have to make such a financial and bureaucratic effort on a single package?
Filed in German · English published by the European Commission
I strongly support the goal of reducing packaging waste and encouraging sustainable packaging. However, I am concerned that these regulations creates a disproportionate burden for one-person businesses, independent makers and artists. Small businesses may send only a few packages per month and produce only a few kilograms of packaging waste per year.
We are distributing laboratory reagents to research institutions, universities and pharmaceutical companies across Europe for cancer research. We have no private consumers and only place very small quantities of packaging on the market in each Member State often only a few kilograms of cardboard and plastic per year.
I have a small company with 4 employees Since 2023, I have had a solution for Austria that costs me around 150 a year. I also hide around 30 parcels a year there, which then makes a difference. In the rest of the EU, I send around 1-2 parcels a year. Customers often also send me parcels, where I make a baby carrier as they wish.
Filed in German · English published by the European Commission
We are a small owner-run company with three employees and around 1640 products in the range. Through our online shop, we sell products and accessories to customers in Germany and other EU countries. We support the objectives of the PPWR and the responsibility of companies for the packaging they place on the market. However, we are very concerned about the continuing national and very divergent implementation of EPR.
Filed in German · English published by the European Commission
I support environmental protection, but this system is completely disproportionate for microbusinesses. I am a sole trader sending approximately 1,000 parcels annually across the EU, mostly in simple cardboard packaging. Requiring separate registrations, reports, fees and authorised representatives in every Member State costs more than the profit earned from sales in those countries.
This new scheme is designed to protect the environment. But the fact is that this may have a big impact. In the case of our small individual fighters, who in any case look as little as possible at the cost of packaging, always use the appropriate carton and, for the most part, already used cartons, which in any case have already been licensed, the new law is a bureaucratic and financial monster which cannot be…
Filed in German · English published by the European Commission
While I fully support environmental sustainability, Regulation (EU) 2025/40 creates an unfeasible barrier for micro-businesses in cross-border B2C trade. Requiring an authorized representative and separate EPR registration in every single EU country is financially impossible for small entrepreneurs.
I run a small, one-person business in the UK. If this legislation goes ahead, from 12 August I will no longer be able to ship into the EU. As a small business, I have always used biodegradable and recyclable packaging and paper tape (with no plastic).
This new scheme is designed to protect the environment. But the fact is that this may have a big impact. The new law is a bureaucratic and financial monster for small traders who, in any case, look as little as possible at the cost of packaging, always use the appropriate carton and, for the most part, try to use used cartons which have already been licensed anyway.
Filed in German · English published by the European Commission
Ladies and gentlemen, as a self-employed artist and small entrepreneur, this law prevents me from continuing to sell in the EU. In fact, it is now easier to sell my artworks to non-EU countries than to my immediate neighbours. This is not financially possible for small businesses. This is more than bad and certainly not the purpose of this law. I very much hope that it will be revised again. (Complimentary close)
Filed in German · English published by the European Commission
Dear EU, As a small Spanish business that is about to launch its sales this month, the new law forces us to incredibly devastating amount of admin, compliance, and cost burden. Youre obliging us, micro businesses/ one person businesses / sole traders to go through the same amount of paperwork and obligations as big traders/corporations.
This regulation is disastrous for my micro-enterprise. I sell ceramics, formerly to all over the world, now that customs clearance has made it almost impossible to ship them to the US, the EU is also working to close the internal market. The quantities that I send are in a ridiculously low range. Perhaps 3 to 5 consignments per year per other EU country. A total of approx. 5-7 kg of cardboard and paper.
Filed in German · English published by the European Commission
While I do feel the importance to regulate the packaging waste with the increasing amount of shipped items, this regulation needs to be reasonable to the amount of packaging waste. Small and micro businesses from the A.R rule as it is disproportionate towards micro businesses. Or provide measurements that small businesses can afford.
THE COST OF PLENIPOTENTIARIES IS MANY TIMES HIGHER THAN THE PROFIT OF OUR FEW PARCELS TO FRANCE OR AUSTRIA. WE CALL FOR ALLOWANCES FOR SMALL FARMS: THOSE WHO ONLY SEND SMALL QUANTITIES TO OTHER EU COUNTRIES SHOULD BE EXEMPTED FROM EXPENSIVE FOREIGN REPRESENTATIVES AND DOUBLE REGISTRATIONS! A SINGLE EU PORTAL + SIMPLER FORMS INSTEAD OF MULTIPLE INDIVIDUAL APPLICATIONS.
Filed in German · English published by the European Commission
I am the founder of a small, one-woman glass jewellery business based in the Netherlands, where every piece is handmade in my own atelier. Sustainability has been central to my practice from the start: I work to minimise the embodied energy in producing each piece, and I package everything using recycled paper, cardboard, and parcels collected from friends, family, and acquaintances.
This is unmanageable for small enterprises and will significantly affect the economies of all EU countries and trade between the EU and external countries. A more onerous and convoluted approach to business is hard to imagine. If the EU is about unity why not come up with a frictionless unified approach that actually makes business easier? Please re-think this it's crazy.
**Opinion on the Implementing Regulation on national registers of manufacturers of packaging (PPWR)** I operate a small online shop for handmade historical jewellery in Germany as a small entrepreneur. My products are produced by hand and sold in very small quantities. I support the objectives of environmental and resource protection and prevention of packaging waste.
Filed in German · English published by the European Commission
To treat all importers in exactly the same way is a total nonsense. Larger companies can easily absorb the cost of these fees whereas small and micro businesses simply cannot. As an artisan I personally rely on sending many products to the EU but now with the administration fees in each of the 27 countries this would be totally pointless.
Ladies and gentlemen, this regulation is an extinction of all Mirco and mini-holdings in the EU. I have been working on a board game myself for years and have invested all my savings. If this regulation is adopted in exactly the same way, I will simply not be able to sell my board game in the EU. Please reconsider this. Thank you, Stefan Ströbinger
Filed in German · English published by the European Commission
I run KnifeMaterial.at, a one-person webshop in Austria selling knifemaking materials to makers across the EU. From August 12, 2026, I'll have to register and pay fees separately in every EU country I sell to, no single EU-wide system exists. This could easily cost me thousands of euros more a year. Worse, many of my customers are small makers who buy my raw materials to build finished knives.
I was preparing to launch a one-person online vintage clothing business in Germany within the next few weeks. Renting a physical shop in my city is already unaffordable, so online sales are essential. I realistically expect to send fewer than 100 minimally packaged parcels in my first year. I am now unsure whether I can afford to launch at all. I have no objection to paying a proportionate recycling contribution.
I am a Danish micro-enterprise producing handmade jewellery in very small quantities and selling directly to consumers online. I fully support the objective of reducing packaging waste and ensuring that producers contribute fairly to the cost of collecting and recycling the packaging they place on the market.
I am an independent contemporary botanical artist based in Luxembourg, operating as a micro-enterprise within the Greater Region, where cross-border sales are part of everyday reality for a small operator. Environmental responsibility is already central to my practice. My creative work focuses primarily on locally sourced botanical matter, and I recycle the organic waste generated by my activity.
Ladies and gentlemen, I would like to thank you for enacting laws to protect the environment. Nevertheless, it is not important to treat all companies equally. Small businesses or, like me, self-employed women live on the fact that we have customers within the EU. Honestly, the EU also lives on the exchange of goods and services between us.
Filed in German · English published by the European Commission
As an EU-based micro/small enterprise selling e-commerce products, I strongly support the ecological goals of the PPWR and product circularity. However, the current framework mandating separate national registrations, fragmented reporting formats, and localized Authorized Representatives creates a completely disproportionate administrative and financial barrier.
I have a little Shop that I'm trying to get off the ground since last year and I had plans to expand my portfolio quite a bit. It's a one person side hustle with the wish to go full self employed one day. But I probably have to close down if this stays the state of the law. I don't have an income to speak off and can't just buy a licence for every country I might send to in the future.
This initiative, in its current form, will kill small and micro-businesses operated by creatives and craftspeople. The fact that the proposed law does not meaningfully distinguish between companies like Amazon and a one-person creative business sending just a handful of orders per year to support a hobby or be a small source of income is a grave oversight.
I am writing as a very small, independent artist and business owner based in the UK who sells handmade and illustrated products directly to customers in the EU. I fully support the environmental aims behind the Packaging and Packaging Waste Regulation.
While the idea of reducing waste from large companies is well intentioned, the way it is being implemented right now is absolutely devastating for small and micro-businesses. Small and micro-businesses bring at least a little joy to everyday life, and they have a much greater cultural importance than many people realize.
I am a small business in the United States who is highly affected by the PPWR & EPR regulation changes. I have many customers in EU countries who purchase and collect plushies that I create and sell. Small businesses like myself cannot afford the costs, and consumers in the EU will no longer be able to purchase from small businesses outside of the EU.
I am an artist and run a very small business in Germany. Like many other artists and small businesses, I sell my products on a very small scale and sometimes have customers from other EU countries. I understand and support the goal of the PPWR. Reducing packaging waste is important, and I am happy to do my part.
I have been running a small business for 15 years, and it has provided me with a good living. However, the new Packaging Regulation is preventing small businesses like mine from continuing to grow. As a small business, I cannot bear the costs and administrative burden of appointing an authorised representative in every EU country, as well as fulfilling registration and reporting obligations.
Generally, I love this idea. It's great and I for my company I buy all my boxes and plastic from certified and traceable producers. I mostly also reuse all of my packaging, which is even better, BUT why do I have, as a tiny one woman business, to register my company for being able to send parcels to all EU states? I ship, at max.
I'm an EU citizen and this new law literally makes it impossibe to sell my products within the EU. I'm a handmade seller from Spain and sell my products to other countries. Yearly I have 10-50 orders/country in the EU, and sell at least to 12 countries. I work alone, have no employees. My packaging waste/county is 1-2 kg/year.
Feedback on the EU EPR Regulation I fully support the PRINCIPLE of EPR and the objective of reducing environmental impact. HOWEVER, the current country-by-country EPR requirements place a disproportionate burden on small and medium-sized businesses.
I am a small business based in the UK, and I have been trying to provide EU shipping for my Etsy customers for about a year now. The changes to GPSR have already made this an extremely difficult, expensive and admin-heavy task, so I have been researching thoroughly and working to find an EU representative so that my business can be compliant.
I am a micro business who depends on intracommunity purchases to create my products, and I prefer to support fellow small businesses. Being from a small island nation, I fear suppliers and small businesses will stop shipping to my country because of these initiatives, further isolating us. It would also gravely limit the ability to grow into neighbouring EU markets, as the cost would far outweigh the potential gain.
We are a small Austrian company selling craft supplies and creative materials to customers across the European Union. We fully support the environmental objectives of the PPWR. However, the current country-by-country system for EPR registration, reporting, licensing and authorised representatives creates a disproportionate administrative and financial burden for micro and small businesses.
Dear European Commission, I fully support the goal of reducing packaging waste and making packaging more sustainable. However, I am concerned about the impact of the new Packaging and Packaging Waste Regulation (PPWR) on micro and small businesses. For large companies, additional registrations, reporting requirements and compliance obligations may be manageable.
As good as the intentions of this law may be, it will ruin small businesses. In potentially 27 EU countries, one should pay a packaging commissioner, who should be able to afford it? The large companies pay this incidentally or in any case have branches there, but my annual turnover/profit does not make this worthwhile and I can stop selling abroad directly.
Filed in German · English published by the European Commission
Disproportionate bureaucratic burden threatening the livelihood of small businesses and micro-enterprises The present rules on national registers of producers under the Packaging Ordinance (PPWR) go far beyond the objective. In its current form, the requirements for small and medium-sized enterprises (SMEs) and micro-enterprises are simply unaffordable.
Filed in German · English published by the European Commission
Hello. I do understand the reasons, and goals, of such an initiative. A thorough management of waste, recycling, haardous products, is long time needed. Really, I do. However: The way it is implemented will kill small businesses. Pure and simple.
Hello, it is a regulation that makes absolutely no sense. All those involved in trade are affected from the smallest to the largest. I sell on ebay and it is my main activity that I do about EUR 20 000 in CA over a year, with your measure I will have to pay more than EUR 2 000 to continue selling in EU countries that accounts for 40 % of my turnover. 10 % of my turnover for what?
Filed in French · English published by the European Commission
Feedback on EU EPR Requirements for Small UK Businesses Selling to EU Consumers I support the objectives of Extended Producer Responsibility (EPR) and understand the importance of ensuring that businesses contribute towards the collection and recycling of packaging waste.
This regulation is the death of small online shops and the end of freedom of exchange between the countries of the European Union. Where the EU should be a force that supports its small entrepreneurs and the talents of their countries as well as their business power through a privileged system, the EU decides to make trade impossible, blaming micro-enterprises for costs that can only be covered by large companies.
Filed in French · English published by the European Commission
I am a part of a small bussines in Greece, selling mostly on online markets, as our own market is very limited. Even though we see the goal of reducing waste and we align with it, we strongly believe the means to do it are very disproportionate when it comes to the impact created for micro businesses.
This proposal is another example of EU regulation becoming increasingly detached from the reality of small and medium-sized businesses. For a small company such as HAPA Design, selling products across the European Union should be one of the main benefits of the Single Market.
I am concerned that the proposed requirements for national producer registers under the PPWR place a disproportionate administrative and financial burden on small and micro-businesses. A small business selling relatively low volumes of packaged products across several EU Member States may be required to register separately in multiple countries, appoint authorised representatives where applicable, pay registration…
Ladies and gentlemen In addition to the costs and the fact that, as a small online trader for spare parts for bicycles, we have to stop international shipping to most countries, which is painful and may lead to job cuts, the biggest hurdle is the administrative burden involved. We have around 8000 spare parts in our range. In other words, we need to collect the data from all our suppliers on each item packaging....
Filed in German · English published by the European Commission
The Single Market is broken for small creators. It is now easier, cheaper and less bureaucratic for an independent artist to ship a parcel across the globe than to send a letter to their neighbor within the European Union. The Extended Producer Responsibility (EPR) was meant to make big polluters pay.
I am not registered as a business, but I sell my physical media such as music cassettes, tshirts, vinyl records, and this will seriously compromise any sales. This whole legistlation seems to be designed for big ugly corporations like ebay and amazon to monopolize even more and undermine independent small vendors who are just trying to sell their music and art.
I run a small British business. I've sold into the EU happily for years, and from 12 August this legislation ends that. Not because I don't care about packaging waste, but because the way you've built this makes it impossible for a business my size to comply.
Without a derogation for micro and small enterprises and a proportional increase in costs based on the amount of packaging, this Regulation undermines free access to the European small trade market. In its form, this Regulation is not feasible for a large number of small enterprises and leads to a significant loss of turnover.
Filed in German · English published by the European Commission
This regulation has been constructed in a way that subverts a core advantage of EU membership - the open market, for a large % of EU entrepreneurs. As of the introduction of this regulation, it is now an easier and less involved process for an ecom business to ship an order to a non-eu country, than a fellow member state. This can only be described as laughable.
We have an online shop where we produce and send designed clothes. The new Packaging Regulation poses incredible challenges for small businesses such as ours and makes it impossible to continue to exist. The cost of red tape for sending to individual countries significantly exceeds profits. We sell well below 10 parcels per year to individual EU countries.
Filed in German · English published by the European Commission
This rule is simply not sustainable for small businesses. The idea that a small company needs its own authorised representative in each EU country to which it sells is completely disproportionate. Such a requirement does not promote the European single market, it creates new borders within the EU and makes cross-border trade practically impossible for many small traders. Please do not implement this rule.
Filed in German · English published by the European Commission
As an artist living in Germany, I sold my art to approximately six different countries during the last twelve months. I will now have to stop selling to European countries as the administrative and financial burden of individual registrations, flat fees, and compliance reporting in every single country completely outweighs the revenue from small-scale sales.
This law is a travesty! It penalizes small entrepreneurs who are the backbone of the European economy. This law establishes heavy commercial tariffs and will render void many businesses built over the past 2 decades. It effectively ends free trade for all but large multinationals, many of them from overseas.
My current understanding is that to ship to another EU country I must pay a representative in that member state to verify my packing. For a small company who has to sign up for this it would cripple our business.
I am all for tracking the supply chain for the packaging that we use but this is an example of a truly European bureaucratic act that really doesnt help anyone. it will create more cost for the consumer in an already challenging environment for no real benefit suppressing enterpreneurship and risk takig seems to be the goal of the EU
The law seems to be more relevant for bigger businesses. Many smaller businesses or freelance workers and artists can be heavily impacted with the taxes to pay in order to have the right to ship packages in other EU countries where sometimes they only get to ship a couple of packages a year towards specific countries, and having to pay dozens of even hundreds of euros to be able to ship maybe 3 packages in one…
Since 2003, I have operated the German micro-enterprise Fly-Style Jewelry with around seven employees and sold jewellery and piercing items within the EU. I welcome the objective of harmonising national producer registers under the PPWR. What is crucial, however, is that it provides real relief.
Filed in German · English published by the European Commission
We are an organisation importing household goods and we wanted to sell across the EU. With the new PPWR, making us register in each of the countries we would like to sell to makes actually no sense, maybe starting from a certain volume that would make a bit of a sense. But you cannot make same rules for each company as there exists different types and sizes of businesses.
As a micro-business owner based in Austria, I fully support the European Union's efforts to enhance environmental standards and promote a circular economy. I am more than willing to pay my fair share for environmental compliance and fulfill my Extended Producer Responsibility (EPR) in my primary markets, such as Austria and Germany.
This makes NO sense what so ever as a law being equally applied to everyone right down to micro businesses. The administration and monetary burden on small traders and sole traders is totally disproportionate cost wise. Only companies like Amazon, Temu et-al can afford it. I've seen quotes of 6K + to register in all 27 member states and that is BEFORE we've even sold a single product.
I am one of many small businesses owners whose livelihood will be seriously put at risk with this law. It is unacceptable that it is easier and cheaper to ship all across the world than within the EU to our neighbours. All this will do is force consumers to purchase more and more from big corporations who are the primary polluters in the first place, as well as purchase from way further abroad.
Feedback on PPWR bureaucracy is holding back the European single market. The current implementation of the PPWR creates a lot of incomprehension and uncertainty for many traders. The OSS procedure already required businesses to pay their VAT correctly to the relevant EU Member States.
Filed in German · English published by the European Commission
Despite such lofty intentions as the reduction of waste and single use packaging this legislation will have a catastrophic impact on individual families and the wider economy. The administrative and financial burden for my business when I ship less than 100 orders per year to even my biggest EU market is simply untenable so I will no longer be able to sell to most other EU countries.
I support the environmental objectives of the PPWR and believe businesses should take responsibility for the packaging they place on the market. However, as a one-person micro-business based in Germany, I am deeply concerned that the current cross-border EPR system is creating a completely disproportionate burden for the smallest businesses.
These new regulations make it incredibly difficult for small and micro businesses to stay open. When they're the one that need the support from the EU, not the bigger companies. These regulations make it really expensive for small businesses to be able to send packages to neighboring countries. Because they only have a few orders in other countries.
I'm a UK-based micro business (sole employee) making & selling my own cosmetic products with a turnover of under £100k, and have always been pro-EU. I lost a significant amount of EU revenue post-Brexit, but have a few loyal EU customers who place occasional orders (amounting to a few hundred pounds per year in a few EU countries).
As the founder of a small sustainable business, I fully support the environmental goals of the PPWR. However, the current EPR implementation places a disproportionate administrative burden on micro-businesses selling only small quantities across EU borders.
I fully support the principle of extended producer responsibility and am absolutely willing to pay appropriate recycling fees based on the packaging we place on the market. My objection is not to environmental responsibility; it is to a fragmented and disproportionately expensive administrative system.
Good afternoon, although I understand the objectives of the Directive well and do not consider it wrong, this Directive places enormous pressure on small businesses in particular, both in terms of costs and administrative burden. I set up a business myself last year, together with two friends, and we are in the process of becoming established.
Filed in German · English published by the European Commission
I am a small starting business and the requirement to have a EPR representative in each EU country I ship to (from the Netherlands) means I need to stop selling to other EU countries besides the Netherlands. Simply because the overhead costs outweigh the revenue. This law will kill small businesses. Further the law is to complex and not environmentally friendly.
I am a ceramicist and own a small business in France. I regularly ship my products to B2C clients, resellers and galleries located in different EU countries. The adoption of this initiative as it is would make it impossible for me to continue shipping to my customers based outside of France in the EU and would mean stopping my ongoing wholesale collaborations with other EU businesses.
It is unacceptable to apply this regulation on the same scale to a multimillion-dolar business as to a small business that makes occasional shipments or handles fewer than 1,000 packages a month. Theyre going to put all of us small businesses that have managed to survive out of business. The European Union is supposed to be a free-trade zone.
Dear European Parliament, I am contacting you today as an independent designer and artist and micro-business owner. I would like to alert you to the dramatic, unfair, and disproportionate consequences of the new PPWR regulation and the multiplication of Extended Producer Responsibility (EPR) taxes on very small businesses (often making less than 12,000 in annual turnover).
Subject: In my view, the EU Packaging Regulation places a disproportionate burden on micro-enterprises Hello, ladies and gentlemen, and the new EU Packaging Regulation (PPWR) places a disproportionate burden on micro-enterprises, thus jeopardising market diversity, entrepreneurship and the free European single market. I strongly support nature conservation and environmental protection.
Filed in German · English published by the European Commission
The new rules of EU law on the Packaging Regulation are a huge problem for small shipping companies. We have been sending salt lamps and gift items mainly within Germany for over 20 years, but also occasionally to customers in Austria, the Netherlands, Czechia and other EU countries. In total, there are no 100 parcels per year, i.e. well below 100 kg of packaging material.
Filed in German · English published by the European Commission
As a small, one-woman business owner, I am extremely concerned about the PPWR packaging law plus the obligation to have a representative in every EU country. This requirement is financially and logistically impossible for a microbusiness, and thousands of small businesses will have to stop selling to countries in our own EU.
The Single Market is broken for small creators. It is now easier, cheaper and less bureaucratic for an independent artist to ship a parcel across the globe than to send a letter to their neighbor within the European Union.
Feedback on PPWR bureaucracy is holding back the European single market. The current implementation of the PPWR creates a lot of incomprehension and uncertainty for many traders. The OSS procedure already required businesses to pay their VAT correctly to the relevant EU Member States.
Filed in German · English published by the European Commission
Opinion on the planned EU Packaging Regulation (PPWR): Ladies and gentlemen, I operate a micro-business in Austria in the food-manufacturing sector and manufacture handmade cakes and cakes. I do not send goods myself within the European Union. Nevertheless, I will be significantly affected indirectly by the planned scheme. For my work, I rely on numerous specialised suppliers from other EU Member States.
Filed in German · English published by the European Commission
I am the co-owner of a small independent clothing brand based in Luxembourg. We sell finished garments online, including to customers in other EU Member States. I am extremely concerned about the increasing administrative and financial burden associated with packaging EPR requirements when selling across EU borders.
Hello, we are a small company from Germany and have so far sent goods to the EU internal market. Mainly France, Spain and the Netherlands. The new regulation forces us to stop shipping to another EU country because we cannot afford to have an authorised person in each country. In my view, it is very counterproductive, as we are effectively stopping trade in the EU’s internal market.
Filed in German · English published by the European Commission
Subject: Opinion on the PPWR from the point of view of a small business As a small business, we reject the currently planned implementation of the PPWR. In particular, the obligation to appoint an authorised representative in each EU Member State and to pay additional fees results in a disproportionate financial and administrative burden. The resulting costs are disproportionate to the returns in many countries.
Filed in German · English published by the European Commission
There needs to be some sort of exemption for small businesses, it will DESTROY small businesses in the EU if they have to pay to register with every country they send to! a lot of the businesses in my sector send all over the EU, but only a few parcels per year, and only small value items, how can we keep our heads above water if we have to shoudler these fees?
Cost-wise, this is simply inappropriate for small businesses. It goes against the idea of the European Union as a single market and of facilitating free trade across Europe. There should be one universal, proportionate system across the EU, with fees based on the actual amount of packaging or goods placed on the market.
Hello, I am the manager of a newly created small Belgian company, benefiting from the VAT exemption scheme due to its low turnover. I have just discovered the new packaging obligations applicable to sales in other Member States (via social media!). I fully understand and support their environmental objective. I am very careful not to overpack my packages and to use mainly cardboard and paper.
Filed in French · English published by the European Commission
This initiative will completely destroy small businesses. I ship between 1 and 20 parcels to each EU country every year but I am meant to pay exacty the same as big companies who ship thousands of parcels. That doesn't make any sense! I am based in France and for 50 parcels a year, I pay the same as a company that ship 9 000. I am registered in Germany and was paying for everything I ship there.
As a small mail-order trader (retailer, Austria), I supply customers in several EU Member States with small quantities of packaging, well below 10 tonnes per year. I would like to make the following comments on this draft: 1.
Filed in German · English published by the European Commission
I am a small, one person sewing business from Spain. I ship anywhere from 1 to 5 padded envelopes the size of an A3 paper sheet each month. This is my only source of income, and has been for almost five years now. EU packaging and EPR rules will make cross-border trade practically impossible for micro-businesses such as mine.
I strongly support the objective of addressing the excessive use of materials in packaging. However, I do not believe that the proposed approach is the right way to achieve this, as it places a disproportionate burden on microbusinesses and small retailers. Small retail businesses are already struggling with declining numbers of customers in physical stores.
This law is causing enormous damage to all artists and small businesses, as they have to pay to send even one parcel for each country. We are forced and shut down part of our gain because it is unsustainable as most of us have few orders a year and every order has an average value of 10. Imagine having to spend hundreds of euros per country and then send us 1-3 parcels a year.
Filed in Italian · English published by the European Commission
Dear Sir/Madam, As a self-employed worker, who sells online in various marketplaces and on his own website, especially within the EU, and after having reviewed the regulations and spoken to several SCRAP companies in several European countries to find out about the costs of a representative in those countries, etc., I find the regulations contrary to the European common market, as self-employed and small businesses…
Filed in Spanish · English published by the European Commission
Hello, as a micro-entrepreneur and creator, I would like to submit this official opinion on the critical impact of the Packaging Regulations (PPR) and the future PPWR Regulation on micro-enterprises in the European Union. At present, the uniform application of extended producer responsibility (EPR) schemes imposes a disproportionate financial and administrative burden on very small craft and online traders. 1.
Filed in French · English published by the European Commission
Even by EU commission standards this one is utterly insane, and thats up against some pretty stiff competition! Like many comments here, i thoroughly agree with the aims of this directive, but as per usual the way it has been applied is ludicrously heavy handed and indiscriminate.
As a small owned business who strives for sustainability, these new measurements have an incredible impact. I own a vintage clothing shop, and I provide my customers with second hand tote bags with their purchases in my physical shop. However, when it comes to shipping abroad, I often opt to reuse carton wine boxes from restaurants and so fort, these orders always come with a small written note and wrapped in paper.
We have already stopped direct shipments to other EU Member States because the administrative and economic costs for small quantities are no longer acceptable. The new PPWR structures exacerbate this problem. A simplified declaration of quantities of less than 10 tonnes does not eliminate the crucial fixed costs.
Filed in German · English published by the European Commission
I run a micro business dyeing yarn with plants. I ship to countries across Europe, I collect and pay VAT to the respective countries. I am only one person and do not have the resources to understand and implement the new packaging rules which means that I effectively have to stop shipping my goods to other countries. I ask for simple, collective rules for micro businesses and a place to get help.
I am a mail order trader (under 1 million annual turnover, 2 employees) and am shocked by this rule. I have 2 main markets (Germany and Austria). I also supply the other 25 EU countries. These are the issues at stake here. None of these 25 countries has a significant turnover, but all together account for a significant proportion of my company’s turnover.
Filed in German · English published by the European Commission
I do not see a point in this law and it need a major discussion with all parties involved before being applied. Bringing thousands to close their little business will only favor a few big companies who will actually don't care for that law. Did people really thought this one through ?
I fully support the EUs environmental objectives and the need to reduce packaging waste and promote sustainable packaging. However, I strongly believe that the PPWR risks placing a disproportionate and potentially unsustainable burden on micro-enterprises.
This directive going live will effectively kill our business within the EU. We're a small band selling merchandise (shirts and records) to fans in Europe and outside, and these new regulations have effectively caused us to stop selling merchandise to EU countries effective immediately.
Im a designer and illustrator, and I currently run a micro business where I also sell my own creations. Im planning to develop a new line of merchandise and branding, but regulations like this are making it increasingly difficult and demotivating to continue growing as a small business owner.
I am a small business owner based in Belgium, and I am writing to raise a serious concern about the compliance burden the PPWR places on small and starting businesses. As it stands, PPWR requires me to register separately in all 27 member states, and pay registration and reporting fees in each of them, simply to demonstrate that my packaging is compliant. For a business my size, this is not a manageable cost.
I am a small business owner from the Netherlands, who illustrates and designs her own products. Because of the mandatory EPR registration fees and cross-border bureaucracy, this law would make it impossible for small independent businesses like me to sell across EU borders. Besides the enourmous paperwork, the costs are exponentially high for the little packages I sometimes sent to another EU state.
I run a small business in Sweden selling foraging supplies, outdoors gear and art. I've been looking into setting up my online store at svampskogen.com, but I've realized that the new EPR rules make it impossible for me to ship outside of Sweden. I'd have to pay several hundred euros for every single country I'd want to ship to, as well as file individual reports, to cover recycling costs on the order of cents.
I find this regulation absolutely ridiculous. I have a small business running here in Germany. My packaging has been all recyclable and reusable since i started. THIS REGULATION SHOULD BE APPLIED ONLY FOR BIG COMPANY WHO CAN AFFORD IT!! I hope you can understand
The new requirements impose a considerable additional administrative and financial burden on us as micro-enterprises, in particular as a result of differing requirements in individual EU countries. In the case of small consignments, some of these costs and costs are disproportionate to the turnover. Consequence: We must stop shipping to EU countries for the time being.
Filed in German · English published by the European Commission
As a small Dutch webshop owner, I support reducing packaging waste, but these rules are disproportionate for micro-businesses and make cross-border EU trade unnecessarily difficult and expensive. Europe should encourage consumers to support small European businesses and buy closer to home, not create barriers that push them away. Please introduce a simple EU-wide system or meaningful threshold for micro-businesses.
As a small business owner in the UK, I agree with the principle of these legislations, however, their execution has been ill considered and is going to damage small business both in and outside the EU. The cost for small businesses having to register in each country with the added cost of hiring a representative in some locations is too prohibitive for many of us to continue selling to the EU.
this regulation discriminates against small business and is anti-competitive. Small businesses would be required to use a disproportional amount of their revenue to comply and a significant administrative burden due to each country having different and unclear processes. This also goes against the principle of the single market.
As the owner of a small business dedicated to promoting certified organic cotton products, with care for the environment at its heart, of course I'm supportive of packaging rules intended to promote less plastic etc. However, the practical outcome of this bureaucracy is that it will stifle small business activity into and around the EU, and small business is often the driving force of change for good.
I have a small business as a side business in Germany and sell homemade jewellery online via the Etsy platform. So far, I have also sold my jewellery in other EU Member States. I expressly support the environmental objectives of the Packaging and Packaging Waste Regulation.
Filed in German · English published by the European Commission
While we appreciate and support the spirit of this policy, it fails to recongnise the realities and capabilities of small and micro businesses. This will, without a doubt, result in a significant increase in limitations for existing and new business trading within the EU, and further opening the door for non-EU commerce.
As an enterprise operating within the EU single market, we fully acknowledge and support the sustainability objectives of the Packaging and Packaging Waste Regulation (PPWR). However, the practical mechanics of establishing producer registers separately across multiple member states present severe operational and economic frictions for small and medium-sized enterprises (SMEs).
I oppose the planned implementation. For smaller traders and manufacturers, the burden of registrations and settlements in each country is completely excessive. Many traders will have to stop their EU transit operations. An EU-wide solution would be needed.
Filed in German · English published by the European Commission
As a small/medium-sized enterprise, we generally welcome the objective of harmonising extended producer responsibility schemes across the EU and creating uniform formats for registration and reporting. A single procedure can indeed help to reduce the current patchwork of 27 different national requirements.
Filed in German · English published by the European Commission
This law will not effectively serve to minimise waste. The fee for representatives is a pittance to any company that could realistically be causing waste on a grand scale, but is condemning small, upstart businesses to death, especially artists such as myself.
I have a teeny tiny business with hand dyed yarn. I dye it naturally so of course I am all for having biodegradable or recyclable packaging and not using more packaging than necessary. However, the bureaucracy of this whole process and also uncertainty and in no small part the cost is unbearable for small businesses like mine.
I run a very small stationery business in Lithuania and sell lightweight products such as postcards, stickers and paper goods directly to customers across the EU. I fully support the principle that businesses should take responsibility for the packaging they place on the market.
Hello, I am self-employed and sell my products through Etsy and b2b platforms. That is what I can live on ok. I am also a single mother and I am very satisfied with what I do and how I can spend this time as a mama. Now PPWR arrives tomorrow. It is difficult that hardly anyone understands in detail what is actually changing. There is little communication and uncertainty.
Filed in German · English published by the European Commission
My feedback is that this will destroy small businesses who are already attempting to be environmentally friendly, and give more power to Temu, Shein, Aliexpress and so forth. As a Norwegian micro-business of one person, I cannot feasibly cover all the costs of registrations, representatives, and paperwork.
I have a micro-enterprise and handmade products that I sell through an online platform. Although EU shipping only concerns a small proportion of my turnover, my customers in 5 EU countries will unfortunately have to give up my articles from 12 August 2026, because, in the case of 25 parcels per year to 6 other EU countries with a turnover of less than EUR 1000, I will simply not be able to meet the expected costs of…
Filed in German · English published by the European Commission
Hi, I am a small business owner from the Netherlands who is shipping very low quantity orders to other countries within EU. My works for launching a new brand that will increase these shippings to other EU countries was ongoing, but this new law makes it so much harder to make this new business feasible.
The PPWR, which will enter into force on 12 August, de facto excludes small businesses from the EU’s single market. Registering for 27 national packaging exemption systems and appointing almost the same number of notarially certified authorised representatives is not reasonable in terms of cost or time.
Filed in German · English published by the European Commission
I would like to start my feedback by saying that I see a need for legislation, and for producer responsibility. But as I see it, it creates unfair barriers to trade for small businesses. As a small business, it is extremely difficult to understand which pieces of legislation meet and legal aid is difficult to obtain if incomes are low.
Filed in Swedish · English published by the European Commission
This law is imprudent and disproportionate. It is simply not possible for small traders who send only individual parcels abroad to bear the costs and red tape. Derogations are needed for micro-volumes (5 parcels per country) and a single centralised registration for the whole EU! Similarly, there is a need for exemptions for small quantities of packaging material in Austria far below the flat rate of 1.5 tonnes (!).
Filed in German · English published by the European Commission
Subject: Disproportionate impact of packaging producer registration requirements on individual artists and micro-producers. I am an independent artist who sells occasionally an original artwork to a customer in an EU Member State. I fully support the objectives of reducing packaging waste and ensuring that producers take responsibility for the environmental impact of packaging.
Dear EU legislators, I understand and absolutely support the need to reduce packaging waste, especially plastic, but this new legislation is a nightmare for micro businesses. If a small maker who wants to sell some hand made stuff to a few hundred customers a year, to any country in the EU (not wanting to limit the scope of their market), they'd have to go through the hoops of registering and tracking separately for…
This law is imprudent and disproportionate. It is simply not possible for small traders who send only individual parcels abroad to bear the costs and red tape. Derogations are needed for micro-volumes (5 parcels per country) and a single centralised registration for the whole EU! Similarly, there is a need for exemptions for small quantities of packaging material in Austria far below the flat rate of 1.5 tonnes (!).
Filed in German · English published by the European Commission
Reducing waste, increasing recycling rates and protecting our enviroment is more important than ever. As a small business owner, I already make sure to reduce waste, I recycle every packaging material that I receive from suppliers, I exclusively buy packing like cardbord boxes that has been produced with as much recycled material as possible.
To Whom It May Concern, I run a small, one-person business making handcrafted wood-turned pieces and handmade notebooks, and I'm writing to raise a concern about the upcoming Packaging and Packaging Waste Regulation. I understand the reasoning behind it, and for large companies shipping thousands of parcels a day, it makes sense. But the reality for someone like me is very different.
Understanding how to avoid packaging waste – this rule completely ignores the purpose of the matter! Here, the distinction between EU countries is being pushed forward, and certainly not harmonised trade between countries. For large companies, this may not be an issue, but all small to medium-sized companies are airborne. It is not ‘only’ about paying the enormous costs.
Filed in German · English published by the European Commission
I am a French artist-author running a very small micro-business. I sell original paintings and art prints online to customers in different EU Member States and outside the EU. I fully support the objectives of the PPWR, including reducing unnecessary packaging, limiting empty space and improving recycling. My shipments already use packaging adapted to the size of the artwork, with very little or no empty space.
These new rules risk placing a disproportionate administrative and financial burden on thousands of small businesses across Europe, particularly in the creative, artistic and handicraft sectors. Many of these businesses are microenterprises, often operated by a single person who is responsible for every aspect of the business: creating the products, production, marketing, sales, accounting, customer service…
Hello, I am an artist/author and sometimes I sell my works with appropriate packaging, which I send all over Europe and sometimes outside Europe. For the time being, I have not generated any profit from these sales. I try to amortise the costs of setting up a “business”, knowing that they accumulate every year (need raw materials, repair my equipment, etc.).
Filed in French · English published by the European Commission
Unfortunately, this new law on packaging is missing out on my goal! It disproportionately affects small businesses and makes it impossible for them to sell their products in the EU. As an artist, I bear the same costs as Amazon, OTTO, Zalando and CO, which are responsible for this huge package effort and free returns! My pictures are packed and sent 1x wisely, that’s what it was.
Filed in German · English published by the European Commission
I totally understand the need of such a regulation as it is a lot of waste. However, the burden admin and cost for small business is just not possible. This will be killing any small business trying to have a living sending few item into Europe. Small business should be exempted of this regulation. They already try their best to be cost efficient, using smallest parcel as possible and with recycle material in mind.
I oppose the current approach to cross-border EPR compliance for small and medium-sized businesses. I run a small business that ships parcels across Europe. We fully accept that businesses should contribute to the costs of recycling and packaging waste. The problem is not the contribution itself, but the way it is being implemented.
This regulation risks turning the EU internal market into a market where millions of micro-businesses can realistically sell only in their own country. A one-person business might make 30,000 a year, pay all its expenses and barely pay itself a living wage.
I operate pocket-manufacturing in Germany and sell through an online marketplace. I send 100 parcels per year to 10 other EU countries. My turnover from these countries is EUR 8900. I expect to pay EUR 3400 per year for registration and authorised representatives in these countries. Because the fixed costs exceed the profit from my foreign turnover, I have completely stopped shipping to other EU countries.
Filed in German · English published by the European Commission
I am a micro-entrepreneur in France and I manufacture and sell homemade jewellery in very small quantities. I understand and share the objectives of the PPWR: reduce unnecessary packaging, improve its recyclability and empower businesses. But when I sought to understand my obligations, I was faced with regulation that was difficult for a very small business to understand.
Filed in French · English published by the European Commission
I have been a sole trader since 2009 and I have been self-employed in online sales with my own productions in the sector of sewing accessories. The packaging laws of recent years had already prevented me from supplying many of the EU countries (e.g.
Filed in German · English published by the European Commission
I support the European Commissions objective of harmonising Extended Producer Responsibility (EPR) requirements across the EU. However, as a very small independent manufacturer selling products directly to customers across Europe, I am concerned that EPR compliance can still create a disproportionate administrative and financial burden for micro-enterprises.
The regulation as it stands right now puts small and micro EU businesses at a significant disadvantage and is not compatible with the freedom of movement of goods within the EU. A minimum threshold for registration and AR obligations, as well as a harmonisation of fees and processes needs to be implemented ASAP. Ideally, registration would be harmonised at an EU level similar to the OSS-system for VAT.
Hello, my name is Patricia and I run my own small business of handmade polymer clay art in Portugal. I've been building my online business over the past 4 years and it has become my full time job 3 years ago. My customer base is 100% EU based. I regularly ship to multiple EU countries. I work completely alone. The new regulations mean for me that I have to close my business completely.
I am a Swedish citizen with sole proprietorship in Norway. Though Norway is not technically part of the EU, they follow almost all regulations put in place. If Norway is considered a country outside of EU for this regulation, then this will negatively impact me regardless.
As the owner of a small online shop, I am writing to draw your attention to the disproportionate impact of the EU Packaging Regulation (PPWR, Regulation (EU) 2025/40) on micro-entrepreneurs like me. 1. As a micro-enterprise without a legal department, I cannot afford an authorised representative required for distribution to other EU Member States.
Filed in German · English published by the European Commission
How are any micro/small businesses/organizations be able to work with all the legal obligations on reporting all of the required documents? The packaging waste limits are defined in above and below tons, and that is towards massive companies who can play by the rules for having enough money for it already. It's not a problem for them, but everyone who works in a lot smaller scale it becomes a full stop.
Making small businesses pay nearly 7k a year in processing fees for recycling is nonsensical and goes against what the EU is trying to do in regulating waste. Small businesses have been struggling since COVID to get back up on their feet. I propose having one unified fee for extremely small micro businesses and larger ones for larges businesses that can simply soak up that fee.
Feedback on the rules on national producer registers (PPWR) Threat to the existence of micro-enterprises in cross-border cultural trade. As owner-run, independent record and merchandise dealers and concert organisers from Germany, I would like to express my urgent concerns about the current implementation of Extended Producer Responsibility (EPR) under the PPWR.
Filed in German · English published by the European Commission
I am a one-woman independent fashion business based in Germany, and the EU is my main market. I do everything myself, I have no legal, compliance or logistics department to handle complex regulations in every Member State. The new PPWR/EPR requirements would not only mean registration fees in multiple countries, but having to appoint a representative in every EU country I sell to.
I recently founded a small coffee e-commerce business in Austria, and I would like to provide feedback on the implementation of Extended Producer Responsibility (EPR) requirements from the perspective of a new micro-enterprise. First, I would like to acknowledge the positive intention behind EPR legislation aiming to ensuring that environmental costs are accounted for.
Feedback submitted on behalf of ZENAE s.r.o., a small ceramics studio in Bratislava, Slovakia (micro-enterprise, founder-run). I fully support the environmental objectives of the PPWR and of extended producer responsibility. My studio was founded on sustainability and responsible craftsmanship handmade ceramics, minimal packaging, local production.
As the operator of a passionately run small online shop for action figures, I must urgently warn against the devastating impact of the Packaging and Packaging Waste Regulation (PPWR). For small merchants who have built their customer base through years of hard work, this regulation is practically impossible to implement and threatens our very existence.
I am an independent artist and designer based in Portugal, running a small business producing handmade, limited-edition ceramic works. I sell my pieces both directly and through international platforms, including to customers in other EU countries. I fully support the EU's environmental objectives and the reduction of packaging waste.
Dear European Commission, I am an independent artist running a small handcrafted business with low product quantities. I am writing to express my concern regarding the proposed rules for national registers of producers under Extended Producer Responsibility (EPR). Many of my friends and colleagues are in the process of closing their online shops, at least for the EU market.
As a small undertaking in the secondary sector, it is organisationally and financially impossible for me to meet the requirements of the new Packaging Ordinance. Employing and appointing a packaging agent for each EU country would ruin me. I will therefore stop deliveries to other EU countries from 12.08.26.
Filed in German · English published by the European Commission
Hello, I am an independent artist who starts selling my creations in the European Union. Being a small business fr, beginner and not having many sales, the PWR/REP legislation makes it almost impossible for me and other colleagues and friends to start.
Filed in French · English published by the European Commission
How is it possible for a small business to be able to operate within the European Union? We make a few kg of waste per year, in shipping material, to our customers within Europe. We are not giants of billionaires, with branches spread across Europe. We are just a small business lucky enough to be able to operate an e-commerce shop in the 21st century. It makes no sense for small volumes to pay so much.
Filed in Portuguese · English published by the European Commission
I am a small business owner/artist focused in selling my illustrations and other art based products and this mandatory EPR registration fees and cross-border bureaucracy make it impossible for small independent businesses to sell across EU borders. I come here to ask you for a de minimis exemption or a simplified One Stop Shop system for micro-entrepreneurs so this won't kill our businesses and growth prospects.
Since free trade is a core principle of the European Union, this new regulation goes directly against everything the EU stands for. As a small business owner, this means I won't be able to ship throughout the entire European Union anymore. We will lose so many small businesses with this regulation, and I feel like this regulation wasn't meant for them.
I am a retailer from Germany with a small brick-and-mortar shop and an online shop. I have 3 employees and our economic prospects for the stationary retail sector are rather bleak. Online business is another way for us to remain in business. As we send floristics and produce just in time, we cannot plan to send them to EU countries, nor can we include the registration licences in any way in our prices.
Filed in German · English published by the European Commission
I wonder why the EU is working on this for such a long time without considering small businesses. It will create chaos and uproar (and who wants that?) Thousands of small independents will go down and the potential buyers do not even understand yet that they won't be able to buy anymore! WE ARE EUROPEANS AND THE EU PUSHES US TO STOP SELLING IN EUROPE ??
In fact, it was a good thing: I was also able to send a small shop to all EU countries without any problems – ‘just like this’. That’s what the EU stands for. Now the effort is no longer worthwhile, so we have limited our dispatch to Germany. Outcome: Customers from other EU countries are now angry with the EU. Presumably, therefore, one does not have to be surprised by a certain anti-EU sentiment.
Filed in German · English published by the European Commission
I am writing about the new PPWR rules. This scheme is a wonderful and important step towards less waste and more sustainability. Unfortunately, in my opinion and in the opinion of many self-employed artists, you have missed the target. As a result of this new regulation, they are destroying the livelihoods of mostly small and micro-enterprises in Europe.
Filed in German · English published by the European Commission
This is an absolute destruction of what the EU stood for, being an open trade amongst countries. You have effectively ruined not only the art community by destroying any chance for any small artist to sell their art as prints and other handmade goods. But you have effectively ruined any and all independent businesses who are already environmentally conscious.
Day, I think this will be an impossible scheme for small craftsmen, the packaging is not a problem, but paying extra to send to other countries in Europe is a bit too much, I myself as a craftsman have up to 2 orders per year from France and then I have to pay 80/jaar as a Belgian craftsman, this means that the open borders within Europe are closed for craftsmen with a web shop
Filed in Dutch · English published by the European Commission
I am a small business based in Austria. Due to this new regulation I will stop shipping EU-wide and reduce it to a couple of countries. Why? Because I can not handle the administrative burden and expenses to get a representative and report to every country individually. The environmental benefit of my exit is nil. My customers will buy elsewhere, packaged elsewhere, shipped in the same materials.
We fully support the environmental objectives of the PPWR and the principle that businesses should take responsibility for the packaging they place on the market. We welcome the Commission's efforts to harmonise registration and reporting formats and the simplified reporting proposed for producers placing less than 10 tonnes of packaging per year on a Member State's market.
Creating a uniform system to do more in the field of packaging to protect the environment is a great thing. But then it should also be uniform. This systematic mistake on the part of the EU puts a huge strain on SMEs across Europe, especially, of course, those operating across borders. The new PPWR creates unnecessary costs and time for both entrepreneurs and public authorities.
Filed in German · English published by the European Commission
I have been a small business since 2022, and from day one, that the sustainability and environmental impact of the entire shipping chain is considered and mitigated. From recycled and savoury cardboard packaging, non-customised product packaging, and order design designed to use as little material as possible.
Filed in Portuguese · English published by the European Commission
I operate a small handmade business in Germany and sell through an online marketplace. I send parcels to 150 other EU countries in 2025. My turnover from these countries is EUR 3200. I expect to pay EUR 2100 per year for registration and authorised representatives in these countries. Because the fixed costs exceed my turnover abroad, I have stopped shipping to other EU countries. This draft is under REFIT, i.e.
Filed in German · English published by the European Commission
If you decide to implement such a useless and impactful rule, you should make sure that: 1. Everyone knows about it 2. Knows where to find information 3. What is expected per country and how to arrange it. 4. Where to find support from an official government organisation. I found out about this rule on TikTok of all places.
The proposed harmonisation of national producer registers is a welcome step, particularly for companies operating across several EU Member States. However, a common data format alone will not be sufficient to reduce the current administrative burden. Companies still face different national requirements regarding the scope of information, packaging categories, reporting procedures and supporting documentation.
This is a ridiculous initiative, undertaken by people who have not been elected by the taxpayers! Yet again, you are doing everything to weaken European economy and kill small businesses! Meanwhile China, India et all, will still over produce plastic and polute like theres no tomorrow!
With great concern, I have looked at the planned PPWR rules and the associated costs for businesses over the last few days and weeks. As a co-founder of a very small start-up, I am far from being able to afford the licensing and representation fees and must therefore immediately place my online shop for all EU orders outside my company’s headquarters, which significantly prevents me from scaling up and makes it very…
Filed in German · English published by the European Commission
I own Plückefinken, a small company from Germany. We develop and sell household textiles and parpetery through our own online shops to private customers and retailers. Our annual turnover is around EUR 300.000. I support the objectives of Extended Producer Responsibility. In Germany, I am registered in the packaging register and share my shipping packaging in a dual system.
Filed in German · English published by the European Commission
This Regulation is being implemented absurdly. For small and medium-sized enterprises, it effectively excludes them from the internal market. Shein, Temu, etc. thank the EU and the national alleys for not sending us anymore within the EU from 12.8.
Filed in German · English published by the European Commission
The proposed rules on national producer registers in their current form represent a huge financial burden which is simply not sustainable for small and medium-sized enterprises. What is intended as a tool to better track packaging responsibility is in practice becoming a costly bureaucratic patchwork that hits precisely those companies that have the least financial reserves to bear these costs.
Filed in German · English published by the European Commission
Good morning, I would like to stress very strongly that the new PPWR is impossible to implement for small, creative businesses. Impossible, because the amount of administration, the fees to be paid per year per country, the contact persons to be arranged per country – it is in stark contrast to the value and turnover of our creative products.
Filed in Dutch · English published by the European Commission
I strongly support the aim of reducing packaging waste and improving recycling across Europe. However, I am deeply concerned that the current approach will disproportionately damage creative businesses, micro-businesses, independent makers and other small enterprises. Small businesses like mine are not the problem these regulations are intended to solve.
Opinion on the Packaging and Packaging Waste Regulation (PPWR) Threat to the existence of small and medium-sized enterprises (SMEs) Honourable Members, as owners of a family business with a long tradition, I am writing to you today with great concern about the cumulative impact of current EU regulations, in particular the new Packaging Regulation (PPWR).
Filed in German · English published by the European Commission
Hello, I have a small 3D Printing business and I paint miniatures as comission for both I ship parcels to all around the world. Now with the new rules I have to pay so much money to deliver a few parcels to small eu countries? How can it be that the small business has the same costs than huge companies. How should I continue my work?
I strongly support the EUs goal of reducing packaging waste. However, as the owner of a very small, one-person business, I am deeply concerned that the PPWR and its implementation may threaten the viability of my business. The costs and administrative burden are disproportionate for small businesses.
Unfortunately, the new rules are a disaster. We are completely stopping shipping to the EU, as the costs incurred are no longer proportionate to the turnover. There would be enough solutions: De minimis thresholds for small traders, e.g. What is more: Any packaging material I receive will in future already be licensed by the manufacturer, but only for the country where I am shipping (Germany).
Filed in German · English published by the European Commission
As a small business owner in the Netherlands, these new rules will be detrimental to my ability to function in the EU. I am a full time artist, one person operation, and I ship less than 6 packages to most of the EU member states per year. I cannot afford the packaging registration or representative fees for the majority of them, as the costs would exceed the revenue I make from these locations.
This ruling is going to absolutely ruin my small business. I ship a small number of games and pieces of art to customers (100-1000 max per year), and am literally going to have to shut down my store now as I cannot afford to pay the proposed rates for different European countries. Many of my friends and colleagues are in the same position.
Honourable Members, I am a small businessman and would like to draw attention to a problem that affects many small independent companies. Mandatory EPR registration fees and additional red tape when selling cross-border within the EU make it practically impossible for many micro-enterprises to sell their products to other EU countries. For many, this legislative change would remove the ground under the feet.
Filed in German · English published by the European Commission
Apart from the usual trouble small businesses encounter with your new PPWR rules, I have to add another problem: As a painter I cannot comply with the demand of max 50% empty space in the box. People buy my canvases stretched on wooden bars, they want the art ready to hang, without them having to find a profesional stretcher where they live (not a common thing to find in not-big cities).
Environmental matters are increasingly important, and I fully understand the need for EPR regulations. However, applying the same requirements to a one-person small business and to a multinational company such as Amazon is neither realistic nor proportionate.
As a sole trader shipping various small products to several EU countries, this rule is an absolute presumption. How can I afford it all? The entire organisational effort is in itself an encouragement for small businesses. But the real problem is the costs involved. This is not sustainable and will cause businesses like me to suffer or to give up altogether, as shipping is no longer expected.
Filed in German · English published by the European Commission
I fully support the goals of the European Union to reduce packaging waste, encourage the reuse of packaging materials, and create a more sustainable circular economy. As a small business owner, I am also concerned about the environmental impact of packaging and want to be part of the solution.
These new rules are effectively banning small companies from selling into other EU countries. For us, our internal market is no the only place in the world where we cannot legally do trade. These rules must be changed as soon as possible so that small businesses are still able to conduct their business at all.
Hello, I have a small business in Germany and the new PPWR Regulation hits me hard. I have to stop all shipments to all EU countries except Germany, as I cannot afford the costs of the licences and agents. This is also the case for many other small businesses, which are the ones most affected by this rule.
Filed in German · English published by the European Commission
I am writing to you about the effect the EPR system is having on small and micro business who may only be sending out minimal packages per year. I myself am a micro business owner who produces around 15kg of packaging waste per year, and sends out about 12 packages per month.
What kind of bureaucratic weakness is this PPWR? Is the Commission currently not listening to the rise of thousands of small and medium-sized traders who are bearing the costs of this PPWR? —... And this refers not only to the costs of the respective packaging licences and their notarial authentication, but also to the many small ancillary costs involved: — for the person responsible for the waste management of…
Filed in German · English published by the European Commission
As a small business, we have already completely eliminated non-recyclable materials from both our products and transport packaging. We therefore support the objectives of the PPWR. However, the current implementation risks imposing a disproportionate administrative and financial burden on micro and small enterprises.
Filed in Dutch · English published by the European Commission
I don’t give my consent because I am a micro-entrepreneur selling my handicrafts where I don’t send parcels, as I send cartons are already in use. My shipments are small and the cost would be higher than my income. I already have charges in my home country and I am engaged in undeclared activities.
Filed in Polish · English published by the European Commission
As a micro business, I'm one person running my entire shop on top of a full-time job. I do not have a legal team, nor do I have unlimited funds to register in every country. The current proposed PPRW is comprised of confusion legal jargon (as evidenced by the various posts with misinformation circulating) Additionally, the requirements for a micro business like my own, or a multinational like Amazon, appear to be…
I have a small business and it would make no economic sense to continue supplying other EU countries if the administrative burden is more costly (in particular by the authorised representatives) than the actual costs of packaging disposal, especially as it is not yet clear whether the recipient disposes of or re-uses the cuverts or cartonboard.
Filed in German · English published by the European Commission
As the owner of a small enterprise, I welcome, in principle, any attempt to standardise the registration and reporting obligations under Article 44 of the PPWR. However, the current draft harmonises only the format of the notification. It does not change the underlying structure of the national registers, the obligation to register in each Member State and the related subsequent costs.
Filed in German · English published by the European Commission
To the EU staff who drafted this law, has any thought been given to the consequences that the introduction of these rules will bring for small businesses? I have been the owner of an online shop selling sustainable products for 17 years. For all those years, I have taken the recyclability of my boxes and shipping bags into account when packing my orders.
As a dress designer/ maker I will be forced to shut down my dress business because of this new regulation. For example, I make and sell dress, which cost 30Eur, to Belgium. It happens once per year. And then i sell dress to Netherlands which happens 2 per year. So now i have to buy licence to send to two countries and they will cost me more than 1000eur for both. All 3 dress will cost 90eur.
I am just one person running a micro business. I there is a few EU countries I only ship one order a month to. I simply cannot afford all these fees to support those countries. The need to have a representative is making me have to withdraw from the EU market entirely
I am an artist and small business owner and I am writing as one of the many micro-enterprises this draft act will affect most. I support the aim behind it. Packaging waste is a real problem and producers should take responsibility for what they put on the market. But this regulation is built around how large corporations operate.
Although a good initiative, by not making a distinction between big corporation/large businesses and small/micro businesses this does more economic harm than good. Having to find a legal representative and pay them along with the annually fees, that quickly amounts to thousands of euros.
I'll start by stating that, as a woodturner, my livelihood and passion depend upon the sustainability of our forests and environment. I support every single initiative that would reach this goal. However... current regulations, coming into effect tomorrow on the 12th, with regards to the EPR's PPWR lack the nuances necessary to differentiate between corporations and micro-businesses like mine.
Please stop madness! We are a very small vinyl shop in Berlin (revenue 4000 per month). We send out about 10 packages per month(!) to EU countries. This is a tiny amount. These new regulations are an incredible burden to small businesses throughout the EU. Please, rethink these regulations, they will destroy the European economy even further.
I am the owner of a one-person business – my earnings from handicrafts, which I build up to pay high ZUS taxes and income, are alive. The new rules on shipments entail huge red tape and costs for a very large number of small businesses, like myself, which do not have lawyers’ facilities!
Filed in Polish · English published by the European Commission
I created my micro entreprise almost a year ago now, and i have only started running my business about 3 months ago. Needless to say i have yet to make my first sale as getting the publicity and customer trust needed to run a business is a long process.
The basic initiative is very good, but administrative implementation is a nightmare, especially for the smallest companies, which will not be able to pay the costs. It is also too complicated and a single site with all the steps to be taken for each country concerned would be much simpler than having to find out about each country’s platforms and have different mediators each time as well.
Filed in French · English published by the European Commission
As a UK based small business I am shocked and severely concerned at the proposed registration and fees attached to the PPWR Initiative. Whilst I understand and fully support the initial idea of helping to promote greener business practices regarding packaging and the recycling thereafter (many of which small businesses were already doing themselves without needing to be regulated), the fees for each individual state…
I am a Swedish micro-business owner running a small handmade business alongside my regular employment. I create and sell sewing labels for people who sew and make their own clothes. I fully support the environmental goals of the PPWR and the principle that businesses should take responsibility for the packaging they place on the market.
These new regulations will strangle small businesses like mine, whereas large corporations (who create the vast majority of packaging waste) will be easily able to absorb the various costs and continue as normal. All of my packaging is already plastic free & recyclable, which costs me more to buy in than the cheaper plastic based options. There should be exemptions for small businesses eg.
I am a small business owner in France (micro-entreprise status). I sell hand-sourced vintage and antique objects to the EU, UK, and USA. I use 50% recycled packaging and allow customers to group items over time in their orders to make as few shipments as possible. I take sustainability seriously and do my best to make good decisions for the planet in both my personal and professional life.
For years I have been saying I figured out a way to have a small scale farming business without the need of any European funding money and built this up completely by myself and my family. The key to success was the availability of internet so we could sell straight to the consumer, taking out the distributor, agent or any inbetweens taking a large cut of the profits need to feed my family, pay taxes and basically…
The new Packaging Act is the corporate death of all micro and small businesses, as the de minimis threshold can no longer be financed. No micro-entrepreneur, such as an artist for Beispuel, can afford to pay an authorised representative for the possible intra-European sale of a picture or product in each country and register in advance for a full year.
Filed in German · English published by the European Commission
As a solo artisan and registered independent creator based in Belgium, I am writing to express my deepest concern regarding the practical implementation of the PPWR and EPR regulations across the European Union. For individual creators and micro-businesses operating with extremely low volumes, the current decentralised system is a major barrier to the EU single market.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.