Implementing rules on registering in and reporting to the register of producers
2973 submissions from 2734 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 7,133 submissions on this file. Shown here: the 2,973 from organizations. Not shown: 3,848 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 312 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
Who showed up
2843 submissions from industry (companies and their trade associations) against 22 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 129.2 industry submissions for every one from civil society.
Industry 2843Civil society 22Public authorities, academia, other 97
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations: a body that filed twice is counted twice. An identical text filed by several organizations counts once: 11 submissions here repeat 8 texts word for word and are folded into them.
What the room declares
109 of 2734
in the EU Register
341
full-time lobbying staff
€53.1M+
declared costs a year
204
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 10 Sept 2026; it ran from 6 Aug 2026.
Policy area
Sustainability (DG ENV)
Where it stands
Awaiting adoption
Adoption expected
31 Mar 2026
How it got here
Draft implementing regulation10 Sept 2026
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.
2 blocks of text on this file were submitted, identically, by three or more organizations. Shared text is a fact about the filings; what it means is for the reader.
4 organizations: Adatele, Launil, Puru, UAB Sodo nuotaika
“The current packaging rules place a disproportionate burden on micro-businesses. Many of us are one-person businesses receiving only a few orders per year from each EU country. Requiring separate registrations, fees, reporting and potentially representatives in every Member State makes no financial or practical sense. In some countries, compliance may cost more than the total value of our annual sales there.”
3 organizations: AVENIR COMMUNICATION SAS, DELTA, GOODIE-D
“The PPWR must not create new administrative barriers within the European market. Media object companies work with several European countries on a daily basis. The obligation to appoint a representative and to carry out specific procedures in each Member State creates a significant administrative and financial burden, particularly for SMEs.”
Showing 25 of 250 submissions on this page · page 9 of 12 · 2,973 across the file. Search the whole file
Ladies and gentlemen, Honourable Members of the European Parliament, as a small owner-run company with just eight full-time employees, we see our economic existence threatened by the current and in practice completely delimited provisions of the EU Packaging Regulation (Extended Producer Responsibility – EPR). We strongly support the protection of the environment and the reduction of packaging waste.
Filed in German · English published by the European Commission
In my view, the effort required, particularly for micro-enterprises and craft businesses, is disproportionate to low-value contracts. This concerns in particular the necessary research into the different regulations in the individual Länder and, where appropriate, the appointment of an authorised representative.
Filed in German · English published by the European Commission
I run a small Austrian online shop and am fundamentally committed to reducing packaging and promoting recycling. However, implementation must not lead to small businesses being excluded from European trade by red tape. For shipping to different EU countries, I have to deal with different registrations, packaging systems, notifications and fees.
Filed in German · English published by the European Commission
This initiative is a complementary administrative layer and will generate unbearable costs for European artists and VSEs. Dare to cut off hands (and throw away parasites that produce nothing and love collecting data) in an already complicated context. This is a completely unnecessary regulation that should be repealed.
Filed in French · English published by the European Commission
Ladies and gentlemen, I would like to comment briefly on the new Packaging Regulation. I myself have a small business rather than a small business and currently have a turnover of around 1000. Therefore, it is not possible for me to meet the condition for the new Packaging Ordinance and therefore harms my company.
Filed in German · English published by the European Commission
As a small entrepreneur and student running a very small creative business from Berlin, I am extremely concerned about the practical and financial impact of packaging requirements on micro-enterprises selling within the EU. I fully support the environmental objectives of regulation and strongly believe that companies should take responsibility for the packaging they put into circulation.
Filed in German · English published by the European Commission
My husband and I run a second hand goods shop online which ships all over the world. We are very conscious of the ecological impact of consumer goods in general which is a huge part of why we chose to sell second hand products. In keeping with this spirit, 90% of the packaging we use is from packaging we receive, as we know that reusing is ecologically optimal.
Sustainabillity and slowing the climat crisis is on top of all priorities and I believe small businesses are the ones who cares the most! We do need strong regulations for the large companies who uses upp all resurces and creates massive waste for products that is not even good for the planet in the first place.
Dear Sir or Madam, It is virtually impossible to meet your packaging requirements. The bureaucratic burden for small companies with low packaging volumes is immense. For example, our company only markets cardboard boxes, plastic bottles containing IVD products, and shipping packaging. Even for very small quantities under 1 kg, we sometimes have to pay more than the revenue generated in that country.
I operate a small jewellery shop in Berlin and make jewellery and wedding rings by hand and on order. Our main market is Germany, and we occasionally send it to other EU countries. The new packaging rules impose a disproportionate financial and administrative burden on micro-enterprises. For example, we send only around 10 parcels per year to France.
Filed in German · English published by the European Commission
Its like your doing your very best to kill small traders at the precise time europe needs to be competing more. All these schemes should be scrapped. This will result in many companies and individual traders from just not bothering to try. It will also lose more tax than it generates while creating more pointless business that just charges to run the schemes.
Dear EU Committee I operate a new micro-business in Germany in the handmade sector and sell through an online marketplace. I wanted to send a few packages (estimated at 10-50 per year) to other EU countries in the future. My turnover from these countries is estimated at EUR 50-250. Because the fixed costs exceed my foreign turnover, I will not start shipping to other EU countries. This draft is under REFIT, i.e.
Filed in German · English published by the European Commission
In the context of the consultation on the planned requirements for national producer registers under the PPWR, I would like to draw your attention to the burdens this may entail for small online traders. I am a small e-commerce business and would like to sell my products to customers in other EU Member States. However, I am deeply concerned about the registration and reporting obligations associated with the PPWR.
Filed in German · English published by the European Commission
As a sole trader running a very small creative business with a smaller annual turnover, I am extremely concerned about the practical and financial impact of the new packaging requirements on microbusinesses selling across the EU. I fully support the environmental aims of the regulation and believe that businesses should take responsibility for the packaging they place on the market.
Dear EU Regulators, I run a small craft business selling my products through marketplaces (Etsy) and my website worldwide. My business cannot survive this enormous regulatory burden. I must stop selling my products to EU countries due to the costs associated with compliance and joining all national waste management systems. These costs can exceed the profits I make in those countries.
I have not been a small businessman since last year. My volume of shipments to EU countries is well below the OSS border. Perhaps there are a total of 100 parcels to all countries. The red tape involved in applying for LUCID everywhere outweighs my benefits. I simply cannot provide an authorised contact person in all these countries... For example, I send around five parcels per year to Italy or Slovenia.
Filed in German · English published by the European Commission
Subject: Disproportionate EPR burden on micro-producers I support the environmental objectives of the PPWR and the principle that producers should contribute to the recycling of the packaging they place on the market. However, the current EPR system can create a disproportionate financial and administrative burden for very small manufacturers and individual producers engaged in occasional cross-border sales.
**Respondent: The Crofthouse Knitwear / Aktepe Ltd UK micro-business and B Corp certified business** We welcome the EU's efforts to reduce packaging waste, increase recycling and establish a consistent Extended Producer Responsibility (EPR) framework. As a small, sustainability-focused business, we support the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR).
Hello, with this law you managed to kick off virtually all micro-entrepreneurs from the European online buisness. Congratulations on this for the first time. It is hardly possible to rule more clearly bypassing the very good objectives. In my circle, I do not know anyone who can maintain European trade under this law. Amazon and Co.
Filed in German · English published by the European Commission
I refer here to a submission from the IT Law Registry and I fully agree with the arguments put forward. For us, shipping to EU countries is neither finance nor manageable for small and 1-women/man companies. As part of the consultation on the planned requirements for national producer registers under the PPWR, I would like to draw your attention to the burdens this may impose on small online traders.
Filed in German · English published by the European Commission
As Single Female Owner of a Small Business creating and selling dog gear. For me those new measures- paying from 100-500 a year per country, and finding a representative in those countries (which of course also wont be for free) are unbearable. I just started and of course I need to collaborate with some creators in different countries, I need to send promotions to different dog shops.
As a one-person company and independent artist just starting to build sales, these new rules are absolutely crippling and absurd. Under this regulation, I am forced to manage a magnitude more legal representatives, reports, and bureaucracy than I do for my entire first-year startup. The financial burden falling on my small business is enormous: up to 300+ for Germany, 550+ for Sweden, and 650+ for Denmark.
Ladies and gentlemen, as solo self-employed, I fully support the protection of the environment. However, the planned bureaucratic implementation of the PPWR is absolutely untenable in practice for one-person companies. It is completely disproportionate that micro-enterprises should be subject to the same burden of proof and registration as large groups with their own legal departments.
Filed in German · English published by the European Commission
We support the EU's objective to reduce packaging waste and increase recycling. However, the current system of national producer registers and packaging fees creates a disproportionate burden for small businesses like ours. There is no uniform European system. Each country has different registration procedures, reporting requirements and fees.
Today, like many small craftsmen from France and Europe, I am angry and busy. On 12 August 2026, the European PPWR Law entered into force. If you’re noble, you’ll tell me... But in reality, for small businesses like mine, open less than a year ago: this is another hard blow.
Filed in French · English published by the European Commission
Pro-environmental solutions are necessary, and reducing packaging waste is absolutely the right direction. However, this should not come at the cost of disproportionate administrative and financial burdens for small businesses.
I would like to express my great concern and opposition to the new rules on the taxation of small businesses selling their products within the European Union. I lead a small business which is my livelihood. I do all my work myself, from product preparation, to contacting customers, to packaging and sending orders. It is not a large company that can easily incur additional, high costs.
Filed in Polish · English published by the European Commission
I believe that trying to reduce waste is a very important step forward for a more sustainable future. But this initiative destroys small businesses across Europe. The obligation is far too expensive and too complicated for a small business. An exemption threshold of any kind would be a perfect solution, as small businesses would still be able to carry the international transit.
Filed in German · English published by the European Commission
PPWR: an administrative and cost monster on the back of small businesses! For EACH EU country, new registrations, fees, notifications and expensive agents, even if only 1 package is sent there. Large corporations pay this out of the Portokasse, small traders are pushed out of EU trade. This destroys businesses rather than packaging waste! Is that really the intention?
Filed in German · English published by the European Commission
As a freelance artist, the new rules make it no longer possible for me to offer my art throughout the EU, as I simply cannot afford the bureaucratic and economic burden of registering in 27 different systems plus one authorised person in each Member State. A derogation for small and micro-enterprises would be desirable.
Filed in German · English published by the European Commission
We are a small Belgian online shop selling vintage and second-hand goods to customers across the EU. We support the environmental objectives of the PPWR, but the current cross-border EPR requirements are disproportionate for micro-businesses.
I strongly support the initiative to create a harmonised and simplified EPR system for small businesses as part of a broader joint initiative by entrepreneurs. The current EPR framework is unnecessarily complicated, fragmented and, in many cases, unfair to small businesses.
As a small creative business, we want to share our concerns about how the proposed PPWR would affect microbusinesses like ours. We fully support the environmental goals behind this regulation. Reducing packaging waste and moving toward a more circular economy are things we believe in, and we already try to reflect that in how we work.
As a micro-entrepreneur and artist from Austria, I am severely restricted by the new Packaging Ordinance (PPWR). The fact that there are no de minimis limits for small shops and that we have to pay hundreds of euros per year in fixed costs for bureaucratic ‘authorised representatives’ in the destination country for cross-border B2C shipping completely destroys the free EU internal market for small businesses.
Filed in German · English published by the European Commission
Seems to me this new and bureaucratic regulation didn't even consider small businesses. As much as I'm keen to protect the environment, this is not an ideal way to go, making it harder for small producers and people that chase special materials and packaging to call themselves sustainable when in reality huge corporations like Amazon, Temu, Shein and so many others are the real ones polluting.
I operate a small handmade business in Germany and sell through an online marketplace. I send around 30 parcels a year to 5 other EU countries. My turnover from these countries is EUR x. I am expected to pay more than EUR 1000 per year for registration and authorised representatives in these countries. Because the fixed costs exceed my turnover abroad, I have stopped shipping to other EU countries.
Filed in German · English published by the European Commission
PPWR means I have to stop shipping into Europe. Full stop, end of story. I run a microbusiness, making and selling things from my home (in the UK). The administrative burden of PPWR is so overwhelming that I cannot possibly comply, therefore I cannot possibly sell to Europeans. I'm set up to comply with GPSR. I can just about absorb the 3 tariff on every package. This is too much.
I am a UK sole trader selling a low-volume consumer object direct to end users in the EU. My total packaging placed on the Union market is under 20 kilograms a year across all Member States combined. A harmonised format is a genuine improvement, but it reduces only the marginal cost of each filing. For the smallest producers the binding constraint is fixed, not marginal.
Can it not be imposed on packaging suppliers that they pay a fee to the local authority and that that fee is placed in a European pot and distributed among the countries? This is then passed on to the importers of the goods. The suppliers of the packaging also know much better all the weights, etc.
Filed in Dutch · English published by the European Commission
This is another step forward for the EU, where the rest of world trade is deadly and we Europeans are even worse off. I am an online store system provider and my customers will be faced with new tasks with every new EU rule. Only a very large trader can cope with this in the first place. Every smaller person is once again prevented from growing. Yes, to survive.
Filed in German · English published by the European Commission
The objectives of the PPWR are very good – the law is more than deficient. It leads to the death of many small retailers, weakens the EU’s internal market, effectively restricts the free movement of goods and imposes enormous financial and human burdens. The following amendments should be included. A number of things are already being done at the tax level in the OSS. 1.
Filed in German · English published by the European Commission
The current rules place a significant burden on small and medium-sized enterprises and will severely restrict cross-border trade within the EU. For shipments to several EU Member States, we need to register separately in each country, pay different fees and comply with country-specific reporting requirements. In addition, there are different national requirements and administrative procedures.
Filed in German · English published by the European Commission
I am a European micro-enterprise selling small quantities of handmade products online across the EU. I fully support the environmental objectives of the PPWR and the principle of Extended Producer Responsibility.
It is self-evident that we all need to pay attention to environmentally-conscious packaging when it comes to shipping, but for this we cannot trade small businesses with new complicated bureaucracy and high costs. We have built our company with heart blood for years and with constantly new regulation you make everything unnegotiable.
Filed in German · English published by the European Commission
I do not understand how frivolous the EU is for almost all small businesses and forbids micro-enterprises from selling within the EU, as the burden and costs for PPWR are disproportionate. My conclusion: However, the laudable idea of sustainability is reckless and not at the end of the day a concern for small businesses.
Filed in German · English published by the European Commission
While standard point-of-sale labels are generally considered "integrated components" without altering EPR allocation under Art. 3(15)(a), large adhesive labels applied at processing plants or retail stores create technical challenges: Recyclability (Art.
As a small business owner sending products to many EU customers in different countries, I have to say that mandatory EPR registration fees and cross-border bureaucracy make it impossible for small independent businesses like me to sell across EU borders.If our businesses generating tax money are to survive, we need a de minimis exemption or a simplified One Stop Shop system for micro-entrepreneurs urgently.
I operate a small handmade business in Germany and sell through an online marketplace. I send around 20 packages a year to 5 other EU countries. My turnover from these countries is EUR 1500. I expect to pay around EUR 850 per year for registration and authorised representatives in these countries.
Filed in German · English published by the European Commission
The new law makes it disproportionately difficult for micro/small businesses to continue, it would be better to have an exception or smaller measures. For example, I just started my business and send up to 10 parcels a year to EU countries outside the Netherlands. Furthermore, one of the EU’s aims is to be able to act freely, and this law is diametrically opposed to this.
Filed in Dutch · English published by the European Commission
I give my feedback as an independent maker/artist who lives in Northern Ireland on the border and who voted against brexit. Due to the fact that I cannot afford to register or have AR in various countries, I will now have to stop shipping to the EU. This includes my neighbours who live a few minutes away in ROI.
This new regulation does not take small businesses into account. It is impossible for us to pay management fees plus an annual fee for every country in the EU, regardless of whether I send 2 or 200 packages a year. Despite its good intentions, this measure could push many small and medium-sized businesses out of the market. Why not set a threshold?
Unfortunately, small and one-person businesses have been completely forgotten here – or there is a deliberate attempt to remove the very small traders from the market. If, as a small shop for me, the first countries to expand are the UK and Switzerland, because there is too much red tape and costs within the EU that militate against it, this makes the idea of the EU absurd for me.
Filed in German · English published by the European Commission
The changes that are forced upon us on August 12th are a death sentence for the majority of small sellers in Europe. The majority of us who want to support small businesses within the EU now cannot do that because small businesses are closing their door to the EU because of the incredibly high cost of these changes, and those of us who want to sell to the EU are forced to close our shipping and focus on countries…
Recycling, contributing and awareness is great. However for small businesses this rule is impossible. It is not clear/transparant. It should be EU wide not per country. It is very costly (to register etc) and time consuming (and also costly). And simply not easy accessible as it is very fragmented information and lots of it is unclear and difficult to find.
The requirements effectively exclude small businesses from the EU market. Registration in each country is often only possible in the national language and the costs of appointing agents per country and, in addition, the costs per country for joining a waste management company exceed any acceptable framework (not only for packaging, but also existing and future producer responsibility issues such as Texil, etc.).
Filed in German · English published by the European Commission
I am co-owner of a small business founded in may 2026. We recently wanted to try selling physical products of our designs. however the new packaging regulation makes it literally impossible to even try. Even though we would only be using paper envelopes in small quantities. This regulation either was never really thought through properly or distinctively tries to kill international acting sme.
Ja, **das gehört unbedingt rein**, weil es die zweite Seite des Binnenmarkt-Problems zeigt: Du kannst nicht nur schlechter **hinausverkaufen**, sondern wirst auch beim **Einkauf aus anderen EU-Staaten** eingeschränkt. I strongly support the environmental objectives of the Packaging and Packaging Waste Regulation.
Starting August 12th, new EU packaging regulations (PPWR) require registration, local representation, and recycling fee payments in every individual country you ship to. For a small creative business selling just one painting a month to different destinations, this overhead makes selling within the EU completely unsustainable.
This regulation seems like insanity - it is impossible to follow for any small businesses. The only option is to remove certain EU countries for shipping, which hurts all small businesses and the economy. I really wonder what kind of disconnected people come up and greenlight these kind of ideas.
I am the owner of a very small, one-person business where I personally make and sell handmade, personalised products. I have been running my business for many years and have no employees. I fully support the objectives of the PPWR, particularly the reduction of packaging waste and the principle that businesses should take responsibility for the packaging they place on the market.
I hereby object to the new PPWR Act. I am a small start-up entrepreneur. I upcycle artisanal discarded furniture from wood to new niche products. I send it with packaging material that I also collect and reuse. For these niche products, I need the EU region to achieve sufficient market outlets. There is a high risk that I will have to stop my business due to additional PPWR registration fees and registration time.
Filed in Dutch · English published by the European Commission
I am the head of a very small French company that I run alone. I sell my creations online and occasionally place orders in different countries of the European Union. I support the environmental objectives of the PPWR and the principle of extended producer responsibility. My concern is about its implementation for micro and small enterprises with low volumes of cross-border sales.
Filed in French · English published by the European Commission
We are a small business from Germany, creating and selling handmade jewellery online. Like many others we now have to stop shipping to other EU countries since the mandatory EPR registration fees and cross-border bureaucracy make it impossible for small independent businesses to sell across EU borders. I demand a de minimis exemption or a simplified One Stop Shop system for micro-entrepreneurs.
As a creator of micro-businesses, selling almost exclusively online, I am directly affected by these PPWR laws. While there is no debate about the need to regulate the parcel flow and the many wasted items that it entails, once again laws that have been removed from nowhere take the problem upside down, without any consideration for small businesses.
Filed in French · English published by the European Commission
I am a small businessman and this arrangement poses insurmountable financial hurdles for most of us. First of all, it is very good that corporations, including the food industry, are finally held accountable with their useless and pointless many packages. However, we small entrepreneurs not only look for sustainability with convictions, but every piece of paper also costs us real money.
Filed in German · English published by the European Commission
In the context of the consultation on the planned requirements for national producer registers under the PPWR, I would like to draw your attention to the burdens this may entail for small online traders. I have a small online shop in Innsbruck (AT) and would like to sell my products to customers in other EU Member States.
Filed in German · English published by the European Commission
I run a small EU-based business selling online across the Single Market. I support EPR and the principle that businesses should contribute to the cost of managing packaging waste. However, requiring separate registrations, authorised representatives and fixed compliance costs in multiple Member States creates a disproportionate burden for micro-businesses making occasional cross-border sales.
I operate a micro-business in Germany in the buying and selling sector and sell through an online marketplace. I send 500 parcels per year to 6-10 other EU countries. My turnover from these countries is less than EUR 1000. I expect to pay around EUR 2500 per year for registration and authorised representatives in these countries.
Filed in German · English published by the European Commission
In the context of the consultation on the planned requirements for national producer registers under the PPWR, I would like to draw your attention to the burdens this may entail for small online traders. I am a small e-commerce business and would like to sell my products to customers in other EU Member States. However, I am deeply concerned about the registration and reporting obligations associated with the PPWR.
Filed in German · English published by the European Commission
They call it "environmental policy," but let's be real- this has nothing to do with saving the planet and everything to do with crushing small businesses. The insane packaging requirements and mountain of paperwork won't stop climate change.
Creating at least one sustainable flat rate that is aligned across all member countries for micro and small businesses or, better yet, exempting them entirely from these new requirements, is the bare minimum, in my opinion. This insane way of handling the situation would mark the end of Europes small businesses.
Honourable Members of the European Parliament, we are writing to you as a medium-sized online trading company from Münster, which has for years sold pool and water-recreational products and games through its own shops and marketplaces, such as eBay, Amazon, Otto and Kaufland.
Filed in German · English published by the European Commission
These new regulations are completely not thought through enough, were any of the EU small/local businesses kept in mind at all when implementing this? Big corporations like amazon, temu and shein need to be taxed i 100% agree, but not the small businesses who rely on each individual order to sustain themselves.
While I support the goal of reducing packaging waste, I strongly believe that the initiative requires greater consideration for micro and small businesses. This will severely impact and damage micro businesses that can't justify and absorb the costs involved.
I have been running a small, sole-proprietorship art business for many years. Selling through Etsy and the ability to ship my products to various European countries has so far been one of the main ways to grow my brand and share my passion with others. The new PPWR regulations completely exclude me from this growth; the proposed solutions are unmanageable for small businesses.
"Dear Sir or Madam, As part of the consultation on the planned requirements for national manufacturer registers under the PPWR, I would like to draw attention to the burdens this may place on small online retailers.
Dear European Commission, as an online trader, I am constantly trying to package my packages as environmentally friendly as possible, to reduce my return rate and to use boxes several times. And I am absolutely in favour of every trader working for it. However, the PPWR law created a bureaucratic monster that makes it even harder for small traders like me to survive alongside the big players.
Filed in German · English published by the European Commission
When coming up with laws, does anybody think about the unnecessary complexity, administrative burden, and costs that it adds to small businesses in the EU? The EPR tax (because this is what it is; it's not a fee) is one of the most abusive taxes ever put on small businesses in the world, under the pretext that we have a responsibility to do good for the planet.
We are a small family-run scrapbooking and craft supplies business based in Spain, operating since 2013. As a micro-business that occasionally sells to customers across the European Union, we are increasingly concerned about how the PPWR and the different national EPR requirements will work in practice for businesses of our size. Our European cross-border activity is very small.
I strongly support the inclusion of micro-enterprises in EPR for packaging. However, the current design goes beyond the financial and administrative framework for the smallest market participants. A micro-enterprise with few individual consignments per year to other EU countries cannot be equated with a large online trader or international marketplace, neither in terms of its environmental impact nor in terms of its…
Filed in German · English published by the European Commission
Feedback from an EU micro-business I am the owner of a one-person knitwear and hand-dyed yarn business based in Denmark, selling directly to customers across the EU. I fully support the environmental objectives of the Packaging and Packaging Waste Regulation. Sustainability is already an important part of my business. I deliberately minimise packaging and primarily use simple recycled paper-based packaging.
This new law has a great goal but was VERY badly executed and is weakening the EU and its commerce relations. With the ongoing tariffs happening with the US, right now is a pivotal time for EU commerce and consumers to stand together and help each other out, but instead this new law is dividing the union. This new law is only hurting small businesses who arent even the big problem when it comes to packaging waste.
As the owner of a small, family-run handmade business in Greece (handcrafted Byzantine icons and artwork), I am directly concerned about the practical impact of this initiative on micro-businesses like mine. I regularly ship orders to customers in Germany, Austria, Italy, the Netherlands, and several other EU member states.
Every big or medium company started out small, stop killing small/micro businesses. Stop robbing artists, musicians and creators from a livelihood. How about the small publishers, the zine makers, the artist selling work without being robbed by a middle man? Thinking about the environment is a great cause and all for it but the problem is a big business problem.
As a small local shop with an online shop, the new PPWR scheme is a catastrophe for shipments to other EU countries. We send around 20 parcels a year to other European countries. Total. Austria, Switzerland, France, but very rarely. Appointing and paying an authorised representative for each of these countries is disproportionate to our small volume of consignments.
Filed in German · English published by the European Commission
As the owner of a micro business in Germany, I fully support environmental protection and sustainable packaging. However, the current implementation of the European Packaging and Packaging Waste Regulations (PPWR) regarding national producer registers is creating insurmountable barriers for small European businesses like mine.
I'm very happy to see that steps are taken to reduce pollution from packaging. As someone who runs a one-person business on the side, I wouldn't mind paying an appropriate amount, but registering separately for each country is not practical for maybe 1 or 2 sales in a year. We're one EU, and pollution doesn't see borders, so there should be one entity handling this for the entire EU.
As the owner of a micro business in Germany, I am directly and significantly affected by the new European packaging requirements. I fully support environmental protection, recycling and the responsible use of packaging. Small businesses should contribute to these goals. However, the obligations must be proportionate, affordable and practically manageable. For my business, this is no longer the case.
This entire law is a monster of bureaucracy. As a small sole trader, it will no longer be possible for me to send consignments to EU countries from 12.8. I used to have around 10-20 orders per month from different EU countries. Registering in all EU countries and providing a proxy would cost me around 6000 per year. This makes no economic sense at all. Should the EU not facilitate internal trade?
Filed in German · English published by the European Commission
For years, we have built our business and produced unique products for the global market and sold them to almost all countries in the world. The EU is now introducing the obligation to appoint a representative in each Member State to which it sells its products and to spend tens of thousands of euros only on this representative, regardless of the number of products sold, in addition to the considerable bureaucratic…
Filed in German · English published by the European Commission
I run Blütenkonfetti, a German micro-enterprise producing natural dried flower confetti and handmade decorations, mainly for weddings. I sell through my own online shop and Etsy, including to customers in other EU countries. I fully support the environmental objectives of the PPWR and I am willing to register, report my packaging quantities and pay fair EPR contributions.
Please protect micro and small businesses from disproportionate packaging obligations! I am asking the European Commission to reconsider how these rules will affect micro and small businesses, especially independent makers, artists and craftspeople who sell their products online across the EU. I am one of them. I work alone, from home, creating and selling my own products.
Ladies and gentlemen, the PPWR complies with many of the rules that we have complied with since our foundation. The obligation now to have this compliance checked by paid experts/agents in each individual EU country will prevent our participation in the EU internal market as a small company (www.alasiesta.com) in the future.
Filed in German · English published by the European Commission
I think the thought to reduce package waist is amazing but unfortunately for our artistic jewelry business this kills every chance to do business in Europe. As many other small businesses we ship few packages per year to different European countries. We are two people doing everything on our own and just dont have enough resources (time, money) to deal with this new law.
Filed in German · English published by the European Commission
PPWR & Small Business Reality I opened my online store to customers across Europe, but PPWR made crossborder selling unexpectedly difficult. Instead of one EUwide system, there are 27 different packaging responsibility schemes, each with its own registrations, fees and reporting. For a small business, this is not manageable. I already use minimal, plasticfree and fully recyclable packaging.
I think the thought to reduce package waist ist amazing but unfortunately for our artistic jewelry business this kills every chance to do business in Europe. As many other small businesses we ship few packages per year to different European countries. We are two people doing everything on our own and just dont have enough resources (time, money) to deal with this new law.
Unfortunately, small and one-person businesses have been completely forgotten here – or there is a deliberate attempt to remove the very small traders from the market. If, as a small shop for me, the first countries to expand are the UK and Switzerland, because there is too much red tape and costs within the EU that militate against it, this makes the idea of the EU absurd for me.
Filed in German · English published by the European Commission
This regulation is extremely problematic for small businesses who sell to EU member states. We might be selling in very small volumes and need to dedicate a lot of time - and, in many cases, fees - to register with all the member states we sell into and then report tiny amounts of packaging. It fails the principle of proportionality.
As a stand-alone ceramic and owner of a sole trader, I support the objective of the PPWR: less packaging waste, more reuse and a more sustainable packaging system. As a small entrepreneur, I really want to contribute to this. For this very reason, I am concerned about the current set-up of the Extended Producer Responsibility (EPR).
Filed in Dutch · English published by the European Commission
As the owner of an online shop, I am writing to you today with serious concern. The current rules of the Packaging Act (VerpackG) threaten the existence of micro-enterprises and start-ups in Germany. However, implementation is extremely bureaucratic and costly.
Filed in German · English published by the European Commission
I strongly oppose the disproportionate burden that these new regulations place on micro-businesses. I am a one-person business. I design, create, package, manage orders, deal with customers, handle shipping, marketing, administration and absolutely everything else involved in running my business. There is no legal department, compliance team or administrative staff behind me.
As of yesterday myself and many other small businesses have had to completely suspend our services to the EU and its been terribly upsetting to see. I am a lone worker for my small online shop, working from home to provide for my disabled child and these new regulations will cripple our income as a significant portion of my orders come from EU countries.
This law is devastating blow to small businesses and sole traders- who are already struggling as it is. I am a one man business, creating and selling art prints. I am already using environmentally-conscious packaging.
I am writing as a German micro-business owner to express my serious concern about the practical impact of the PPWR and associated national EPR requirements on very small businesses selling across the EU. I fully support the environmental goals of this regulation. I run a one-person ceramics business and I use only biodegradable packaging.
I strongly oppose the implementation of the PPWR in its current form because it places a disproportionate financial and administrative burden on small and micro-businesses, particularly those engaging in low-volume cross-border e-commerce. I fully support reducing packaging waste, increasing recycling and encouraging businesses to use recyclable and responsibly sourced materials.
I strongly support the objective of harmonising producer registration requirements across the EU. However, I am concerned that the current system will create a disproportionate administrative and financial burden for very small businesses selling products across EU borders, particularly small e-commerce businesses. I run a very small Dutch sole proprietorship selling handmade and small-scale products online.
Thanks to this new regulation, it is impossible for me, as a jewellery designer with handmade unikates with individual core customers abroad in the EU, to continue to serve them. My turnover will be reduced as a result of the fact that the EU’s single market, which has been promoted for years, has been discontinued. It is a testament to poverty that small businesses are thrown out of the market altogether.
Filed in German · English published by the European Commission
These new rules will be the end of many small/ micro businesses in Europe! I have worked in environmental education for the past 2 years and am in general very supportive of the new EU environmental regulations. But this one is a nightmare for micro businesses who, like myself, dont even make in one month what it costs to register for this new programme in a country.
The way this ruling was elaborate reflects how unaware people in the EU parlament are when it comes to commerce on the European Union. Making people need to pay thousands to send things to multiple EU countries because there is no minimum, no centralized system like OSS and creating a new market for companies to represent you in each country is so bad.
The goal of these laws is good - making companies responsible for their contribution to waste. Unfortunately, the execution makes free trade within the European Union impossible for small businesses. The first big hurdle for small businesses is the registration. The law currently will require a different method of registration for every country. While the plan is to synchronize the EU, the practice is still divided.
What are you thinking with this nonsense regulation? In the most regulated part of the world, something that even you have expressed that is limiting Europe competition for companies, now you want to destroy all small businesses that need to ship to other countries? I think it is time to start being radically anti "European Union".
While the general objective of protecting the environment is undoubtedly worth supporting, the current extent of the bureaucratic burden constitutes an unsustainable hurdle for small and micro-enterprises. It is simply not possible to meet these requirements in their current form. The core problem regarding online retail and shipping lies primarily with large corporations.
In the context of the consultation on the planned requirements for national producer registers under the PPWR, I would like to draw your attention to the considerable burdens this entails, in particular for micro-enterprises and one-person enterprises. I sell only a small online shop in Germany, I am subject to VAT and I sell mostly hand-made parpeterie items.
Filed in German · English published by the European Commission
I am an Austrian micro-enterprise and run a small retail shop and online store. I would like to highlight the disproportionate administrative and financial burden that the current EPR requirements can create for very small businesses selling cross-border within the EU. For example, in 2025 I shipped only 32 orders to customers in Germany, resulting in approximately 1.6 kg of packaging waste.
Filed in German · English published by the European Commission
I fully support the goal of reducing packaging waste and improving recyclability. However, I strongly disagree with the approach being taken to achieve it. Adding further layers of bureaucracy, registration requirements, fees, reporting obligations, documentation, and compliance work is a lazy and insufficient way to address the underlying problemparticularly when these requirements are applied to micro and small…
The PPWR is a textbook case of the EU adding another layer of bureaucracy that punishes the people who can least afford it: small, independent business owners. Instead of one simplified EU-wide system befitting a "single market," we now face up to 27 separate national registrations, 27 different portals, and 27 sets of fees for the exact same obligation.
This new legislation is killing small businesses. I'm selling products across the EU, but the need to register in every country, without the possibility to do this without local representatives will cut all the margin I make. With a revenue of less than 20.000 , and the cost of these registrations running up in the thousands of euros if you count all countries, it's better to just stop.
You have to make regulation that favors the small businesses not the big corporations! The way this is planned to be implemented is the same administrative disaster as VAT-MOSS. Why the need to register with 27 individual member states. Make a central EU register that handles the complexity of the member states. One registration for the whole of the EU.
# # # EPR and PPWR: as owner of a small Dutch company, I support the objective of the PPWR: less packaging waste, more reuse and a more sustainable packaging system. However, I am deeply concerned about the current design of Extended Producer Responsibility (EPR). For a microenterprise, the * * costs, administrative burden and huge lack of clarity * * are particularly problematic.
Filed in Dutch · English published by the European Commission
I run a small vinyl shop in the Netherlands (1 person only) and ship only a few parcels per month to other EU countries. Under the new PPWR rules I would be required to register in every member state and pay multiple fees, even though my packaging footprint is rather small. Obviously this go for many, many other small shops as well. This is disproportional and impossible for micro-businesses to absorb.
The current organisation is completely disrupting the lives of many small businesses and is only once again helping to spread and spread Temu and Shein. I call on decision-makers to reconsider the draft so that many small businesses selling in the EU will not be forced to close due to the entry into force of the current rules.
Filed in Hungarian · English published by the European Commission
Of course. I propose that you keep the substance critical, but formulate it in a sufficiently reasoned and constructive manner to ensure that it is taken seriously in a European consultation. I regret that this new regulation once again results in a disproportionate administrative and financial burden for micro, self-employed, craftsmen and very small structures.
Filed in French · English published by the European Commission
These new rules are already driving a lot of small businesses to quit shipping all over Europe, which will likely end these businesses all together. As union we should be considerate of artisans and craft persons who have to do business in other European countries. The fees are nothing for multimillion dollar enterprises with legal teams, but for the businesses run by one singular person this is completely undoable.
The basic idea behind the law is undoubtedly good, but the current implementation threatens the existence of thousands of micro and small enterprises and the cultural sector as a whole. It also makes the idea of the European single market absurd, as this law effectively closes it to the vast majority of businesses in the EU.
Filed in German · English published by the European Commission
In principle, we welcome a uniform European legal framework. The European single market offers great opportunities for small and medium-sized enterprises in particular and should facilitate cross-border trade. However, we see a significant need for action in the practical implementation of the new Packaging Regulation.
Filed in German · English published by the European Commission
I generally welcome the objective of the PPWR to reduce packaging waste and promote more sustainable packaging solutions within the EU. However, as a micro-enterprise, I would like to draw attention to a problem that particularly affects companies with very small volumes of shipments. I operate a small painting company and send my products only in very small quantities to professional dealers.
Filed in German · English published by the European Commission
I'm a micro seller based in the UK with an average turnover of £37k. I run the business as a sole trader, and the EU is my 3rd biggest market. I've already lost customers since Brexit, and if micro businesses like myself aren't exempt from the new packaging regulations, I will lose all my EU customers.
Hello! I just started a small business in Germany, specializing in restoring used instruments, and selling them with a small profit. So far 50% of my orders came from outside of Germany. I sold a few instruments to France, Greece, Romania, Slovenia, and Italy. Under the new regulation, I have to stop selling entirely to all EU countries outside of Germany because it's not financially sustainable.
For a small business, the regulations stemming from the PPWR and EPR pose an insurmountable obstacle to operating in the European market. The costs associated with registration, designated contacts, and waste disposal services would currently far exceed the revenue generated by the few packages I ship to other EU countries. Consequently, serving the EU market is not economically viable for me.
Dear all, I am a small independent creator and micro-business based in the EU, selling my own illustrated products mainly through Etsy. I fully support the goal of reducing packaging waste. Small creators like me often already make a significant effort to minimise their environmental impact. I reuse packaging materials whenever possible, choose recyclable materials and keep packaging to a minimum.
Hello, although I respect the initiative to seek to reduce the waste associated with the shipment of goods, I find it absurd to keep multinationals and individual companies in the same place. I am myself an illustrator in a self-enterprise; the whole process of creating, printing and sending orders is done by me alone, with my means, and I earn barely enough to live every month.
Filed in French · English published by the European Commission
The mandatory Extended Producer Responsibility (EPR) registration requirements under PPWR have made cross-border EU sales economically unviable for micro-entrepreneurs like myself. The regulation incentivizes consolidation, harming market diversity. Small businesses are not the target of PPWR large packaging producers are. We urge the Commission to implement exemptions for micro-entrepreneurs.
I wonder how the authors of that regulation could not have been aware that they thereby excluded a large proportion of European online traders from the internal market. How can EU bureaucracy be detached from reality? In any case, we will have to stop intra-European trade, as this vexatious regulatory burden is breathing the air in every respect.
Filed in German · English published by the European Commission
1. Business Context & Investment in EU Operations Weirdstock is an independent UK-based homewares and textile brand specialising in 100% organic cotton bedding. To ensure seamless, fully compliant trade with European customers, we have undertaken significant restructuring over the past two years: - Establishing an EU fulfillment partnership via a 3PL warehouse based in the Netherlands.
I operate a small owner-run business in Germany and produce personalised gift items. In Germany, I am registered in the LUCID packaging register and share my shipping packaging in a dual system. I support the objectives of the European Packaging Regulation to reduce packaging waste, improve recyclability and ensure appropriate producer responsibility.
Filed in German · English published by the European Commission
The way PPWR changes things is deeply concerning and should be inspected by CJEU as it looks like a lobbied regulation to eliminate small companies from EU-wide ecommerce. I am not against raising environment responsibility and awarness, but it shouldn't look this way which promotes only big companies for which complying with those new regulations will be much more easier than for other smaller ones. F.e.
British artist and screenprinter living in Germany. I am self employed, I make limited edition printed t-shirts and small artwork. The inability to ship throughout Europe would eliminate most of my income. I would have to register as unemployed. These rules are bad for all independent and small businesses.
I support the environmental objective of making producers contribute fairly to packaging-waste costs. However, EPR as currently organised has become a serious obstacle to the EU Single Market. A small EU business selling cross-border may have to register separately in every Member State in which even a small quantity of packaged goods is sold, deal with different authorities and producer-responsibility…
Urgent need for a de minimis threshold and simplified compliance for non-EU micro-businesses. As a UK micro-business creating contemporary jewellery, I am deeply concerned by the financial and administrative burdens of the Packaging and Packaging Waste Regulation (PPWR). While I support the green transition, the framework treats low-volume independent artisans identically to multi-billion-dollar e-commerce giants.
As a US-based artisan and small business owner, the new PPWR has made my decision very simple: It will no longer be worth either the time or expense to ship products to any EU countries outside of Germany. After today I will, with regret, be closing sales to the other 26 nations. Having discussed this with others artisans, I know I am far from alone in this decision.
Hello, I think the basic initiative is commendable, reduce waste and increase the “greenest” packagings possible. As regards the origin of the packaging, I am in favour. May be allowed some time for those who still have boxes that are not compliant, as it would ultimately be worse for the environment to dispose of them.
Filed in French · English published by the European Commission
The new rules on European transit, which apply from 12 August, are, to put it mildly, acceptable for small businesses. I closed my online shop for the EU territory tomorrow! The losses in transit do not amount to millions. But I still live there. Is there nobody who is concerned about how book binders, ceramics and all other manufacturing trades will now disappear from the European market?
Filed in German · English published by the European Commission
The current implementation of the PPWR creates a significant burden for small businesses and individual entrepreneurs who want to ship products within Europe. For many small businesses, it is extremely difficult to understand which registrations, applications, reporting requirements, and fees apply in each individual country.
As a small business with just one owner and worker, I cannot afford the cost of registrations in any Eu countries. This means I can now only ship within the Netherlands, where I am based. There must be a solution with exceptions for small businesses otherwise many will go bankrupt...
To whom it may concern. As an entrepreneur from Romania, I view the EU single market as the most important advantage of belonging to the EU. Being able to buy products from various vendors across the union is extremely important to the cohesion of the EU, and as a seller of custom goods, having access to 450 million potential customers ensures a higher chance of success, contributes to the growth of the business…
Hello, I am a homemade jewellery company in France, a solo company without employees, sending a few parcels a year to other Member States. Article 45 (3) of Regulation (EU) 2025/40 requires me to provide a service provider for remuneration in each Member State where a customer orders. I oppose this and support the suspension provided for in Article 2 of COM (2025) 982, calling for it to become a deletion.
Filed in French · English published by the European Commission
Dear European Commission, I am a one-person micro-business based in Berlin, Germany, where I have lived and paid taxes for the past ten years. I run a small independent record label, distributing vinyl LPs and CDs. I fully support the EUs environmental objectives and the reduction of packaging waste.
The basic idea is very good, but it is 1. Far too much time. 2. Online shops selling goods produced in the EU and generating less than 2000 sales in an EU country should be exempt for that country. 3. No authorised representatives, or EU agencies in the country, or foreign trade agencies are available. 4. Clearer rules. For example, we have disputes with some suppliers about who is a producer. 5.
Filed in German · English published by the European Commission
This legislation does not distinguish between large companies or micro-enterprises or small artists who want to sell their products, thereby only favouring the disappearance of small businesses because they are literally unable to meet the costs of this regulation, even making a distinction if they use biodegradable and locally purchased packaging, it is absurd.
Filed in Spanish · English published by the European Commission
We are happy to be part of the European Union. For small businesses in particular, Europe offers tremendous opportunities. The European single market allows us to develop, manufacture and sell products to other Member States without having to look at 27 completely different markets. This is why we are concerned about the PPWR. We strongly support the objective of greater harmonisation.
Filed in German · English published by the European Commission
- please excempt small businesses from having an AR, because its a disproportionate measure towards us. We cannot justify the costs. - Please harmonise the registration or exempt us from registration, because its a disproportionate burden on small businesses. We cannot afford to hire someone to do it for us, so we would have to do it ourselves - this goes against the movement of goods.
I am a small ecommerce brand. Almost all of my orders are sold in Spain. I sell one or two orders per month to France, Belgium and Germany. There is no way I will pay for a packaging representative in those countries. I think the EU have no idea the burden they place on small businesses to comply with laws.
The regulations on geo-blocking and PPWR do not fit in this way. It is impossible for small traders, traders and craftsmen to bear the costs and effort of registering in all EU countries. 10 % of my orders come from abroad, mostly from the EU. But in some countries I often send only 1 package per year, e.g. Bulgaria. And you don’t even know this in advance.
Filed in German · English published by the European Commission
Ladies and gentlemen, I am rather critical of the new, planned requirements for the national producer registers under the PPWR, especially for micro-enterprises, of which I am one. A micro-entrepreneur can hardly bear the additional costs of shipping to the relevant EU country to which he wishes to send under the PPWR, as well as the enormous red tape involved.
Filed in German · English published by the European Commission
This new initiative, although sounds like a good idea, is effectively going to kill small business. Ive been in business, shipping all over the world including the EU, for the past 18+ years. It will kill my small business. Im an artist/maker and cant afford the time nor the financial burden this will cause. Ive lost business and this has interrupted my shipping process already!
The proposal builds on the EU’s efforts to develop the circular economy and digitalisation. In reality, its adoption will mean that large firms will have to invest in IT systems linked to state registries, which is likely to simplify their administrative processes in the long run.
Filed in Czech · English published by the European Commission
I am a small business owner who just started selling my art and while I fully support the idea behind those new rules, I will also say that they are deeply unfair and will destroy many small businesses like mine while big companies will barely be affected by it.
Ladies and gentlemen, your intention to reduce packaging waste is something I can only support. However, implementation does not take place, as: Even if small shops and shops have to bear the same bureaucratic burden and costs as big players, trade, craftsmanship and thus cultural diversity will rapidly disappear.
Filed in German · English published by the European Commission
Notification of packaging and quantities is currently already mandatory in Germany for organisations such as Lucid. The purpose of an EU should not be to impose further barriers to trade or additional rules, regulations, etc. in the EU’s internal trade.
Filed in German · English published by the European Commission
I am a German micro-business selling genuine vintage and second-hand clothing online. My business is extremely small, and the income from it is my only source of income. I fully support the environmental objectives of the Packaging and Packaging Waste Regulation. I have always tried to operate in an environmentally responsible way.
It is fair to say that most small and micro business have been taking the environmental impact of their packaging seriously for years. We recycle and re-use as much as possible many of us alerting customers to this and encouraging further use of the same packaging. These new regulations will disproportionally burden small makers who are already being overrun by increased red tape processes.
The single market was a great idea and a small business was also able to sell niche products to customers and supporters across the EU via a webstore. Toll! However, the emphasis is on ‘was’. In the meantime, red tape, time spent on administration and the costs incurred in addition to the actual costs such as manufacturing, shipping, personnel, etc. are no longer proportionate to the turnover.
Filed in German · English published by the European Commission
I am a micro business based in the UK that has many customers in the EU. I have had to suspend shipping to the EU because the cost and time required to comply with the various packaging and waste-disposal regulations are unreasonable.
I am the owner of a small, owner-managed business. We have no dedicated administrative or compliance staff. We fully support the goals of the EU Packaging Regulation, particularly reducing packaging waste and improving recycling. However, the increasing administrative requirements are becoming disproportionate for businesses of our size.
What kind of EU is this that is essentially destroying the single market with excessive regulation? Environmental protection and the Packaging Ordinance > All of this is right and important! But if there is a united EU, then there should also be a single registration authority within the EU!
**Subject: Concerns Regarding the New EU Packaging Regulations and Their Impact on Small Businesses** I work for a small, independent business that has been operating for more than 40 years. Like many small businesses, we are facing increasingly difficult economic conditions. As inner city retail continues to decline in Germany, our online store has become an essential part of keeping the business viable.
The absence of a unified system to keep a micro or small business in compliance with EPR in all european country places a burden on micro and small businesses that is simply a death sentence for many, and a drag to any aspiring creator. Only big corporations have the means to comply to this new plan. It is dangerous for small artist, creators and cultur creator all around europe.
As the owner of a small, one-person French jewellery brand, I fully support the EUs objective of reducing packaging waste and making packaging more sustainable. However, the rules must remain proportionate to the size and reality of micro-businesses.
We are a micro-enterprise from Germany and sell our products online to customers in other EU Member States. For us, 12 August 2026, the date of application of Regulation (EU) 2025/40 (PPWR), is unfortunately a turning point in the negative sense. First: We do not question Extended Producer Responsibility as such. We believe that we pay for the packaging we actually place on the market and we strongly support it.
Filed in German · English published by the European Commission
As a small business from Germany selling online, the cost (in the lower 5 digits per year) and administrative burden of this new regulation is unbearable for us. A small business simply cannot afford it. It goes against everything that the EU stands for.
We are an Estonian SME engaged in e-commerce and direct B2B sales across the EU. In 2026 alone, we have already received orders from customers in 25 EU Member States. This is not because we operate 25 national businesses it is simply how the Single Market works: customers find our website and place orders from across Europe. The proposed harmonised registration and reporting format is welcome.
Grässlin Zeitschalttechnik GmbH welcomes the objectives pursued by Regulation (EU) 2025/40. These include, in particular, strengthening effective Extended Producer Responsibility (EPR), transparent collection of packaging quantities and promoting a well-functioning European internal market.
Filed in German · English published by the European Commission
The upcoming changes to the EPR regulations will have a disastrous effect on micro and small businesses. I own a fulfilment house and distribution company serving a niche market, shipping from the Netherlands to customers throughout the EU. Under the new system, nearly 80% of our customers will no longer be able to ship within the EU at all, because of the additional administrative burden and the associated costs.
We are keen to reduce packaging waste and already have packaging licences for Germany and France. We are also happy to pay for other packaging we send for the respective countries, but I do not understand what you need a contact person/authorised representative in each country? Can we be contacted by email at any time? If it is enforced as planned, we simply cannot send anything to most EU countries.
Filed in German · English published by the European Commission
The new regulation hits me disproportionately hard. I am a sole trader and in a few cases I also send material packages to other EU countries to support my digital products. I buy my (blank) shipping boxes both from Germany and from other EU countries.
Filed in German · English published by the European Commission
This new regulation is devestating to my small business. The minimum costs of registering and reporting in every single country is too high to be viable to small businesses. We don't have a problem with contributing to the recycling programmes, but to register in every country with high anual fees and authorised rep costs makes it impossible.
Moin! Sorry, this is the final curtailment of free trade. If years ago we were still able to send our customers around the world without any problems, it will be further constrained by ever-new rules. We are now a small company focusing on clothes with Eastoldtime motifs. We have always taken care to minimise the generation of packaging waste. We reuse a very large proportion of our cartons.
Filed in German · English published by the European Commission
Ladies and gentlemen, in principle, I support the objective of such a law and consider that greater responsibility for packaging would be appropriate. For micro-enterprises, however, practical implementation is a huge bureaucratic and financial burden. I run a business with only two people, I and an employee. We sometimes send only one to five packages per year to some EU countries.
Filed in German · English published by the European Commission
I support the environmental objectives of the PPWR and the principle that businesses should take responsibility for the packaging they place on the market. As a small independent business, I already make a conscious effort to minimise packaging, use recyclable materials, avoid unnecessary plastic and manage waste responsibly. I consider the environmental goals of the PPWR both important and justified.
It makes no sense to overburden its small business with such requirements – financially, how organisationally we are put on an equal footing with large corporations that have very different resources (also disproportionately contribute more to the waste issue!) – for us this can mean that we can no longer participate! If that is the aim, ok, if not then you will also have to think about something else!
Filed in German · English published by the European Commission
Environmental protection yes but it must remain manageable for small businesses I fully support the goals of the PPWR. Reducing packaging waste, increasing recycling and using resources responsibly are important, and small businesses should also do their part. The problem, however, is the bureaucracy that comes with it.
As a micro enterprise (sale of old books) based in France, currently operating 25 % of my figure in the EU, this measure is disastrous. Firstly, in terms of its cost: my bookshop will reduce its national markets in the EU, so as to keep only the 1 or 2 for which the balance of turnover and expenditure generated by the measure remains positive.
Filed in French · English published by the European Commission
As a slow fashion brand owner, running my small business alone, I truly think it is a good think there are now coming rules for packaging. I do my utmost already by choosing sustainable options in materials and for orders in NL I give my clients the option for reusable packaging as well. But this law will make it unable for me to continue shipping to other EU countries.
In principle, I agree that packaging waste should be reduced and that companies should be held responsible for this. However, I find it grossly negligent that ALL companies are packed together in this process. Large corporations are the ones that carry most shipping and packaging waste around the world. It is also these who can easily afford to comply with the new, stricter requirements.
Filed in German · English published by the European Commission
These rules make it prohibitive for any small business to sell to the EU. I can see how this could be an attempt to enforce more sustainability and reduce waste, and I realise that someone has to pay for proper disposal of packaging, but the requirements of this are ridiculous for a small business. It clearly favours the large corporations who have vast funds and resources to be able to comply.
disproportionate burden on micro-enterprises Dear Sir/Madam, I operate a small handmade business in Germany and I sell homemade personalised products also to customers in other EU Member States. In principle, I support the objectives of the PPWR in terms of waste prevention, recycling and more sustainable use of packaging. However, I am very concerned about the practical implementation of EPR for micro-enterprises.
Filed in German · English published by the European Commission
I am the owner of a small independent record label selling vinyl records directly to customers in several EU countries. I support the EUs environmental goals and already use minimal, recyclable cardboard packaging to protect records during transport. However, micro-enterprises should not be subject to packaging reporting obligations, registration requirements or additional packaging-related costs.
Ladies and gentlemen, as the owner of a small business in Germany, I would like to express my deep concern and dissatisfaction with the increasing bureaucratic requirements related to the new EU Packaging Regulation and its implementation in Germany. In principle, I support the objective of reducing packaging waste, promoting recycling and protecting our environment in a sustainable way.
Filed in German · English published by the European Commission
If this law continues, I can stop my business almost equally. I am now sending antiques and vintage across Europe and beyond. For each item, I need a completely different type of packaging. I have been using old boxes from supermarkets and other companies for many years now. Same for the filling material. I only buy the adhesive tape new.
Filed in Dutch · English published by the European Commission
Absolutely ridiculous to put micro/small businesses to ransom like this. This will kill business done throughout the EU. It is not financially feasible nor logistically feasible to make you have a representative in every EU country you may want to do business with.
I sell books and tabletop gaming products all over the world. Mine is a small part-time operation that can't sustain a full-time employee year-round. However, I provide work for nearly ten freelance collaborators. Half of our sales occur in the U.S. Since the tariff issues, we have refocused on EU sales, which now account for about 40% of the total.
We are a small Swiss cosmetics retailer selling cross-border to consumers throughout the EU. We fully support the environmental objectives of the PPWR and extended producer responsibility. We believe that businesses placing packaging on the market should contribute fairly to the costs of its collection and recycling.
I am one of France’s small businesses. I sell jewellery made of silver and natural stone and, in my turn, share with you my views on this new regulation to which we are subject. I am ok about reducing the impact of waste and have not waited for the law to apply it within my company. I buy my packaging from a French supplier, my cartons are 100 % recycled and recyclable, and the exact size of the products I send.
Filed in French · English published by the European Commission
I am a solo business of 1, Im an artist and writer and I sell my art and books all over the world, EU included. However there is no way that I can afford to do so with these new rules. I already use only recycled and recyclable packaging, the environment is so important to me, but like others, this will end any business I had remaining after brexit. Please reverse this and save our businesses.
I support reducing packaging waste, I already reuse as much packaging as I can and purchase only new if I have to.. Yet this EU regulation risks favouring large corporations over the very small businesses that make Europe diverse. I am a one-person leatherwork artisan, using locally sourced leather to create high-quality products by hand, which I then sell to customers across Europe.
The current A.R. rule disproportionately affects micro and small businesses. These enterprises should either be exempt or offered financially feasible alternatives. Furthermore, the PPWR/EPR registration process needs to be harmonized across all EU member states to prevent unreasonable administrative hurdles.
The regulation is unclear and thys cannot be executed or enforced. It seems to be aimed at hampering open trade cross-borders in Europe. Unclear if webshops who buy packaging for shipping products have to do anything. According to EU regulation, weshops cannot just point to terms and conditions, but have to specify in clear, understandable text.
I support the European Unions goal of reducing packaging waste and promoting more sustainable production and consumption. Businesses should reduce unnecessary packaging and use materials with a lower environmental impact. My concern is that the PPWR may create a disproportionate burden for micro, small and medium-sized businesses engaged in cross-border trade within the EU.
If the reporting obligation applies to all countries, the PPWR should provide a platform where the use of packaging materials can be reported to all countries in the same place. It is extremely difficult to register POs in their own language in their own country, let alone in each EU country. Our company, Kameratori Oy, sells products from Finland via e-commerce to all European countries.
Filed in Finnish · English published by the European Commission
This law goes against the Single Market benefits of the European Union and disrupts the small businesses and emerging businesses capacity to participate in the market. Every single citizen in the EU pays taxes including taxes related to waste management.
I have just set up my micro-enterprise and my treasury does not need this new tax. For all small businesses, this is a big sum compared to the turnover we manage to make. And for me, who has not yet started selling, it is even worse. All the more so as we have not been warned by any body and this is the total surprise. Please reconsider this tax below a certain turnover.
Filed in French · English published by the European Commission
Hello, this Regulation in its current form is a mere bureaucratic monster which basically restricts market access for micro and small businesses, as they cannot afford the costs of agents in countries other than their own. Why is there no central body such as ECHA?
Filed in German · English published by the European Commission
Sgduh, I do not fully understand this regulation. This is also the case for lawyers in Austria. So we have highly endowed lawyers in the EU Commission, who cannot write clearly, and highly endowed lawyers in Austria, who cannot understand what you prescribe. Everything at the expense of the population who works every day and pays the taxes you consume.
Filed in German · English published by the European Commission
Ladies and gentlemen, I run a small business in which I myself produce and sell 3D-printed products to private customers. My turnover with customers in other EU Member States is less than EUR 10.000 per year. The resulting packaging volumes are therefore very low.
Filed in German · English published by the European Commission
Dear European Commission, I am writing as a micro-entrepreneur based in Belgium, sending only 2 - 5 shipments per month exclusively in reused packaging. While I fully support the environmental goals of the new Packaging and Packaging Waste Regulation (PPWR), I am deeply concerned that its current implementation is disproportionately harming the smallest businesses during a period of economic hardship and labour…
This regulation is devastating for hundreds of thousands of micro businesses across the EU. We simply don't have the resources to handle the extra administration and the costs. It will put so many out of business and, very importantly, is a major barrier to the free movement of goods - surely a corner stone of EU policy?
We are an independent publisher and send some items abroad (inside and outside the European Union). We have always made a huge effort to ensure that the packaging in which you follow books has the lowest possible environmental impact. We reuse cardboard boxes, try to make the boxes small, reuse filling materials, etc.
Filed in Portuguese · English published by the European Commission
I am a microbusiness owner from Latvia, selling fishing lures as a oneperson independent entrepreneur. Mandatory EPR registration fees, separate national packaging systems, and complex crossborder compliance bureaucracy make it practically impossible for very small businesses and microenterprises to sell across EU borders.
Theben AG supports the objectives of Regulation (EU) 2025/40, in particular effective extended producer responsibility, transparent packaging volume data and a functioning European internal market. However, the implementation of the national registers of producers should not create new barriers to cross-border trade.
Filed in German · English published by the European Commission
The new PPWR regulation comes on top of already financially burdensome constraints for artists, craftsmen and micro-entrepreneurs. We already pay several hundred euros every year for parcels in our own country. It is difficult to manage when you are struggling to earn a salary that often does not even reach the smic.
Filed in French · English published by the European Commission
I must express my huge disappointment in the work and decisions of the EU with respect to introducing PPWR. This initiative literally destroys the small business I created 18 months ago. I call upon you to take action and stop this nonsense. Do you want competition, or do you plan to strengthen the monopoly of a few large cooperations? Sincerely, but utterly disappointed.
As a small company that sends few parcels a year abroad in Europe, we cannot pay an authorised person and bear the bureaucratic burden. We call for an exemption for small businesses that only sell small quantities and, in some cases, also recyclable packaging that would otherwise have had to be disposed of anyway.
Filed in German · English published by the European Commission
I am one of the many solo traders who will stop EU shipping with this. With a volume of less than 20 packages sent to other EU countries (in total, not per country) per year, this is more a customer service act than a source of revenue - especially as keeping up with regulations and postal fee changes already requires quite some time.
I am a one person business trading in vintage and antiques, and shipping very small amounts to different eu countries. I use a platform for this, with no possibility to restrict countries I can't sell to due to this regulation from others. And I can't afford to register in countries I might never sell to. So this will cut my entire possibility to sell anything other than to my own country. Is this free trade?
By appointing an authorised representative in each EU country I want to send to, the costs and bureaucracy go beyond any profit. It is laconic for 500 turnover (not profit) to pay 200 to a person who does exactly what? Compare a number? Amazon’s incredibly good lobbying. What they paid for and thereby win, respect. Honest. This completely destroyed the European idea. Congratulate.
Filed in German · English published by the European Commission
Hello, this regulation is a disaster for all small, micro and craft enterprises. These small, often one-person, structures do not have the means at all to pay the fees in each country to send possibly one or two parcels per year.
Filed in French · English published by the European Commission
I have recently started a very small handmade ceramics business in Portugal. My sales volumes are still low, and the amount of packaging I place on the market is extremely small. I would like to sell my products to customers across the EU through my online shop. However, the packaging EPR requirements under the PPWR make this increasingly difficult for a microbusiness like mine.
Hello, I also have a small business, which is now forced by the new Packaging Act, like most of my competitors, to give up shipping to EU countries. For us small traders, it is financially impossible to pay an authorised representative for each country across Europe. Has the EU been set up to remove trade barriers? I would ask you to put in place practical arrangements for small-scale farmers.
Filed in German · English published by the European Commission
I feel like these new regulations are being too harsh on small businesses, that send only a few packages a year to other eu countries and will no longer be able to profit from trading inside the eu. I already saw a lot of businesses closing their sales outside the borders of their home country, including myself.
Im writing as a solo, self-employed illustrator running a small online shop that ships physical goods (prints, stickers, small paper products) to customers across many countries, including several EU member states. I want to flag the disproportionate impact this initiative will have on businesses like mine. The core problem: compliance scales with country count, not with size.
Feedback from a small cross-border EU business I am a small sole trader established in the Netherlands, selling my own products directly to consumers across the EU. My packaging quantities are extremely small, typically only a few kilograms per Member State per year. My main concern is the requirement to appoint an authorised representative for EPR in each Member State where this is required.
I am writing as a small business owner based in Lithuania to express my serious concern about the practical impact of the new Packaging and Packaging Waste Regulation (PPWR) and, in particular, the administrative burden its implementation places on small businesses selling across the European Union. I fully support the goal of reducing packaging waste and making packaging more sustainable.
Its frankly impossible for most micro-businesses to comply with this and as a consequence most tiny (sustainable, eco friendly, artisan) EU and third country companies will stop shipping outside their own country and/or into the EU. This cant be the intention surely?
My partner and I run a micro manufacturing business in the UK, making cycling components. A major part of our business is supplying EU-based national cycling federations, professional teams and amateur riders. Our margins are small, because we manufacture everything from scratch in the UK.
Feedback on the implementation of the EU Packaging Regulation (PPWR) We are a small business in Germany and trade in carefully selected vintage and design objects. Our products are mostly individual items, so we only send comparatively small quantities and do not send standardised goods in large quantities.
Filed in German · English published by the European Commission
For a small vineyard such as ours, the Packaging Regulation cannot be implemented. The additional bureaucracy makes our EU exports completely unprofitable, as the delegation for each EU country exceeds the profit. This makes it difficult for small businesses such as ours to access the EU market. Taking into account the current crisis in the wine sector, this is a disastrous signal.
Filed in German · English published by the European Commission
This law is an absolute catastrophe for small businesses, solopreneurs and freelancers, including their customers and clients, the economy of each of the european countries and more. While I understand the need for recycable packaging and more mindful handling of waste, bigger corporations usually cause much more harm in that area and small business owners will be forced to shut down their operations because of the…
I run a microbusiness in the Netherlands selling small craft supplies to customers in different EU countries. I already register where required and pay packaging recycling fees. I am not against EPR or paying for the packaging I put on the market. The problem is that every country has its own system.
As someone with a small art business, this change will impact me very negatively. I depend most of sales from EU based customers and these extra charges will not sustain many of us small artists. Please reconsider this decision and think about the thousands of small businesses that may no longer be with us due to this change.
From the perspective of a sole proprietor, the proposed EPR framework risks creating a de facto fragmentation of the EU Single Market. The administrative and financial burden appears out of all proportion for micro, small businesses and sole proprietors.
I operate a micro-enterprise in the creative sector in Germany and sell through an online marketplace. I send out totals each year 20 parcels to 10 other EU countries. A total of less than 3 kg of cardboard is produced for disposal. My turnover from these countries is total. EUR 2000. I am expected to pay totals for registration and authorised representatives in these countries. EUR 5000 per year.
Filed in German · English published by the European Commission
Obligation to act as an authorised representative: disproportionate burden and de facto barrier to entry for micro-enterprises We are an Austrian cosmetics manufacturer with two employees and develop, produce and fill themselves. Our main markets are Austria and Germany.
Filed in German · English published by the European Commission
This is the end of the EU’s single market for small and medium-sized online traders. The PPWR and the obligation to appoint national representatives are the de facto exclusion of micro and small enterprises from the EU internal market.
Filed in German · English published by the European Commission
I make handmade jewellery in silver and gold. I was going to provide worldwide shipping, but I guess it's no longer going to happen. I cannot justify paying hundreds of euro's to ship maybe once or twice a year to a single country. Let alone to 27 countries. This law only makes sense for big corporations like Zalando, Shein and AliExpress, but not to small or starting businesses such as mine.
As a small business and artist (see), I generally welcome the objective of upholding environmental standards and harmonising Extended Producer Responsibility (EPR) schemes. However, I would like to stress the immense hurdles that such schemes pose for micro and small enterprises.
Filed in German · English published by the European Commission
I am a micro-business owner running a handmade studio that creates handcrafted accessories from natural, high-quality materials. Unlike fast fashion, my products are made to last. I fully support the EU's environmental goals, but this new packaging regulation will unintentionally crush small artisans. My volume is tinyI send only 1 to 10 parcels a year to a single EU country.
There is an urgent need to introduce a micro-enterprise and small-business exemption before this law moves forward. This legislation will disproportionately harm small businesses like mine that are already struggling to survive.
Feedback on the EU Packaging and Packaging Waste Regulation I am the owner of a small craft kit business based in Scotland, UK, and I am writing in support of the many small and microbusinesses, makers, artists and independent creative businesses across the EU who will be affected by these new packaging requirements.
You urgently need to add a micro enterprise/small business exemption before continuing ahead with this law. This will destroy small businesses like mine. The administrative demands on top of the financial burden or registration in each EU member country is unviable. We will have to stop shipping to the EU. Thats crazy. Why would you want to destroy internal trade (the very opposite of the original goal of the EU).
I handmade jewellery, plastic-free, sustainable, high-quality materials. When it comes to shipping, I pay great attention to the environment, GoGreen Label, as well as all plastic. As a small business, it is absolutely impossible for me to cover the costs of the representatives of each EU country. I would only work to be able to send.
Filed in German · English published by the European Commission
We produce natural soaps in the manufacturing plant. The Cosmetics Regulation obliges us to affix a paper tape in order to declare the ingredients. The new rules on packaging mean that our EU internal market business, which is only just growing, is being disrupted, while competitors from outside the EU are increasingly entering the market with allegedly sustainable products by air freight from overseas.
Filed in German · English published by the European Commission
I am a small business owner in France. I am fully committed to complying with regulation, and I strongly support initiatives aimed at reducing packaging waste. I am also prepared to pay meaningful contributions toward the environmental cost of the packaging we place on the market. That being said, the current approach to EPR compliance for cross-border businesses is simply not workable.
Hi, I'm a small business, based in the EU, and only ship small quantities outside of the EU, and very little inside. Most of my products are drop-shipped by other companies. Small businesses such as mine already have so much to contend with because of many new EU laws, and this is just one more that makes life very complicated. Can you please give very clear guidance on what to do, and make the costs achievable.
I have been working in cosmetics for 20 years. We were looking forward to this regulation to really make single market a reality by: - unifying labelling requirements for recycling for the whole of the EU - not done - unify packaging standards (so that France especially doesnt come up with random local rules) - not done Instead of prioritising what really matters to the companies to access the single market, the…
I operate a small business and produce hobby items for RC models. https://buerokratieabbau.bvmw.de/iele Customers come from the EU. Leaving aside the question of whether one is a producer or a producer, the procedure for notifying participation in the national packaging system in each Member State is de facto an exclusion of all small businesses from the internal market and will lead to the cessation of EU transit.
Filed in German · English published by the European Commission
This scheme is a catastrophe for small online traders like me: I send it almost to all EU countries, but sometimes only small turnovers of a few 100 per year. If I had to register with an agent in all these countries, this would cost me a number of 1000, disproportionate to the turnover achieved in each country.
Filed in German · English published by the European Commission
As a sole entrepreneur, I am deeply concerned about the disproportionate burden the Packaging and Packaging Waste Regulation (PPWR) places on cross-border micro-enterprises. Micro-businesses are not the primary cause of packaging waste.
Ladies and gentlemen, I welcome in principle the aim of the new EU Packaging Regulation to reduce packaging waste, improve the recyclability of packaging and make companies more responsible for the packaging they place on the market.
Filed in German · English published by the European Commission
I am concerned about the new regime for micro-enterprises. An authorised representative in each EU country is administratively and financially unfeasible for small businesses. Only with several hundred orders per year in a country could the costs be absorbed. In general, small businesses are already struggling to deal with the big players, and with such a regulation the smaller ones will be even smaller.
Filed in German · English published by the European Commission
EPR compliance was alerady a buden on our small Amazon business. Now that it is being enforced in countries across the EU, with each country requiring it's own registration, this is a huge problem. It is costly and time consuming and promises very little reward.
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