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EU consultation

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 Also not shown: 312 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their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

  1. Draft implementing regulation10 Sept 2026

Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.

Filed word for word by several organizations

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

KI

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

LinkedInX
A

Anonym

· · filed 12 Aug 2026 · source

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

LinkedInX
A

Anonym

· · filed 12 Aug 2026 · source

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

LinkedInX
PD

PR DESIGN WORKS

· · filed 12 Aug 2026 · source

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

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S

Shoshanahandart

· · filed 12 Aug 2026 · source

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

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CF

Cosic Fashion

· · filed 12 Aug 2026 · source

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

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OS

Oldities SAS

· · filed 12 Aug 2026 · source

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.

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ED

Emmy Design AB

· · filed 12 Aug 2026 · source

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.

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SD

Specialty Diagnostix GmbH

· · filed 12 Aug 2026 · source

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.

LinkedInX
CM

Cirer Manufaktur

· · filed 12 Aug 2026 · source

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

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NN

N.Nickells

· · filed 12 Aug 2026 · source

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.

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M

MoKiMon

· · filed 12 Aug 2026 · source

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

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AV

Ars Vivendi OHG

· · filed 12 Aug 2026 · source

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

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SS

Sentient Stories

· · filed 12 Aug 2026 · source

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.

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D

Demagica

· · filed 12 Aug 2026 · source

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.

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W

WildKrautWelt

· · filed 12 Aug 2026 · source

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

LinkedInX
A

Artist

· · filed 12 Aug 2026 · source

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.

LinkedInX
AL

Aktepe Ltd (T/A The Croft House)

· · filed 12 Aug 2026 · source

**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).

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TC

this charming man records

· · filed 12 Aug 2026 · source

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

LinkedInX
KH

Kleiner Handarbeitsbetrieb/Versandhandel

· · filed 12 Aug 2026 · source

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

LinkedInX
UD

UrbanTails Dog Gear

· · filed 12 Aug 2026 · source

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.

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KS

KATRA Studio

· · filed 12 Aug 2026 · source

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.

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E

Einzelunternehmen

· · filed 12 Aug 2026 · source

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

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FB

Fluxmotion BV

· · filed 12 Aug 2026 · source

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.

LinkedInX
IC

IUNICORN CREATION

· · filed 12 Aug 2026 · source

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

LinkedInX
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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed”. You read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.