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

I am a disabled ceramicist working from home in France; I sell my sculptures to customers all over the world. The new PPWR requirements are entirely impossible for micro-businesses to manage, especially as they arrive on the heels of the increasingly complex tariff situation with the US. There is absolutely no way that I can afford the new registration fees.

I understand and support the EUs goal of taking action against large marketplaces such as Temu, Shein and Amazon, and I also understand the need for better environmental standards and fair competition. But I feel that these rules are not suitable for very small businesses and artists.

Ladies and gentlemen, I am not at all satisfied with the new Regulation on the transit of goods within the EU. As an establishment which is currently implementing my business idea in an extreme niche market (sport trophies), I cannot afford to have an authorised representative in all or even in another EU country who is doing the entire paperwork.

Filed in German · English published by the European Commission

Dear Sir or Madam, We remain fully willing to comply with all applicable environmental regulations. However, each additional registration and reporting obligation places a disproportionate burden on SMEs, making it increasingly difficult for small businesses such as ours to operate.

I have a small online shop in the secondary sector. Registering and plenipotentiary in each EU country would cost me more than EUR 8700 per year. There is also then the licensing of the packaging itself in each individual EU country, not to mention the bureaucratic burden and the valuable time that companies have to spend as 1-persons. My pre-tax profit is EUR 20.000 – EUR 25.000/year.

Filed in German · English published by the European Commission

MonXolo Ltd welcomes the Commissions work to establish a harmonised format for registration in and reporting to national producer registers under Article 44 of Regulation (EU) 2025/40. We support the requirements for open standards, machine-readable information, interoperability and data portability without vendor lock-in.

Thanks to the new EU Packaging Regulation, small businesses (especially one-person self-producers) have no chance of remaining competitive on the market! Purely physical sales are not sufficient for specific products because, on the one hand, a far too small group is targeted (especially in Austria) and it is difficult to implement in time – so you are dependent on online sales (in digital times like this).

Filed in German · English published by the European Commission

Splendid isolation. This is a step in a wrong direction for sure. I run a very small online bookstore, ship around 50 small packages/week. Once in a whole theres a parcel for other EU countries but that will have to end immidiately, and many small Companies thinks the same, a counterproductive law, opposite to everything what EU is suppose to stand for; promote and support trade for all EU businesses, a shot in the…

We are a small German retailer and have so far regularly supplied customers in other EU Member States. The new PPWR requirements, in particular the national registration and EPR obligations and the obligation to appoint authorised representatives, have created significant additional costs and red tape. As a result, we had to stop shipping to all EU Member States outside Germany.

Filed in German · English published by the European Commission

To: European Commission Directorate-General for Environment (DG ENV); Members of the European Parliament (Committee on Internal Market and Consumer Protection - IMCO). Dear Sir/Madam, I am writing to you as an independent artisan and sole trader from Portugal, specializing in handmade silver jewelry.

I am the owner of GabiArtwork, a Hungarian micro-enterprise producing handmade premium scenery trees for model railways. My products are manufactured individually in a small workshop in Hungary and sold through my own online shop. I fully support the environmental objectives of the Packaging and Packaging Waste Regulation.

I would like to raise a practical concern about the impact of the PPWR on small e-commerce businesses selling low volumes across several EU Member States. For a small online retailer, the European Single Market makes it possible to sell a few orders per month to customers in many different countries.

This is a terrible implementation. I run a small business which has been selling into the EU, and I reuse all packaging I can. The fees per country are far too high compared to the profit I make from selling there, the total fees would potentially even cost me more than I'd make.

This PPWR law in its current form affects small entrepreneurs disproportionately hard. I am a self-employed entrepreneur in the creative sector and my customer base within the EU is not big but diverse. My work is unique, made with materials produced in Euopa, and is lifelong. It varies greatly from year to year to which country I sell more, but I value each customer.

Filed in Dutch · English published by the European Commission

Exceptionally disappointing way to do things. And it is worrying that all Brussels can not see the mess this creates. Which brings you to think..if same people decide about more serious things - not too hopeful. But the packaging law should be like simple, yearly payment of 60eur for example. Many of us just put out few kg of so to say waste. Should be taxed accordingly.

Honourable Members of the European Parliament, I am writing to you as an small business owner residing in Portugal to request that, on the Omnibus proposal (COM/2025/982), you suspend the requirement for an authorized representative under Article 45(3) of the Packaging and Packaging Waste Regulation (PPWR) until 2035. This goes against the EU "Think Small First" principle.

Hello I have been an artistic activity, a sole trader, for 30 years. MII has been open to the European, American and Asian markets for a long time. Shipments are always an important item for the customer and in any case I pay attention to the use of environmentally friendly and compliant packaging material. Materials which obviously have a higher cost.

Filed in Italian · English published by the European Commission

The PPWR pursues important environmental objectives and is justified in principle. However, its current implementation places a disproportionate administrative and financial burden on SMEs, particularly in cross-border trade. Even small packaging quantities can trigger extensive national EPR registrations and fees, putting European companies and traders at a competitive disadvantage.

I am a freelance artist, and my activity is diverse in the field of painting and a small stationery business that is just emerging. My profession is entirely supported by my forces and this regulation would break her legs in the early days, because it is untenable from an organisational and economic point of view.

Filed in Italian · English published by the European Commission

The PPWR decision does not in any way concern me with the idea of being a micro enterprise, already uses 100 % recyclable cartons and even the idea of participating proportionally in recycling is not an aberration in itself. What is, on the other hand, productive and clearly a death sentence for all small self-entrepreneurs is the disproportionate application of financial and administrative burdens.

Filed in French · English published by the European Commission

As the owner of Willow Tree Reborns, I would like to give feedback from the perspective of a very small UK business. We are a small handmade reborn doll business, currently selling around 12 dolls per year, alongside accessories, and we are hoping to grow. Like many small businesses, we take environmental responsibility seriously.

Dear, As a small bussiness owner from Czech Republic, handcrafting unique items and just planning to expand abroad - as this is the only way to make the bussiness grow into something meaningful, this new rule literary broke our spine.

I'm a hobbyist sewist, and I have a small online shop where I sell handmade veils and mantillas. I frequently use second-hand, reclaimed and deadstock fabric for sustainability. Most of my items are sold to buyers in other EU member states. I only sell several items per month, sent in a simple bubble envelope.

These are regulations to be applied to large companies. I am an artist, my activity could occasionally involve small sales in Europe, and I find the activity totally unsustainable with increased costs on packaging materials. Finds it crucial to oblige the use of fully recyclable materials for packaging, but European small and individual companies must be supported.

Filed in Italian · English published by the European Commission

We have also sold used toys/model railways in transit since 1987. As we also do this to save resources, we usually send the goods with used shipping boxes, which we collect from partners in the neighbourhood. As a small enterprise with eight employees, we are unable to meet the flood of regulations to limit the EU’s internal market, not least the PWWR.

Filed in German · English published by the European Commission

Regulation (EU) 2025/40 has, since 12 August 2026, for all practical purposes brought an end to the functioning of the European Unions Single Market for micro and small enterprises that have until now sold small quantities of their products to customers in other Member States.

The PPWR pursues important environmental objectives, but the national design of EPR/producer registration places a disproportionate burden on German companies when it comes to cross-border trade. Already small quantities of packaging require extensive national registrations and fees, which exceeds the administrative burden.

Filed in German · English published by the European Commission

The implementation of the Packaging and Packaging Waste Regulation (PPWR) creates profound operational burdens for Small and Medium-sized Enterprises (SMEs) while threatening to trigger unintended consequences that could paradoxically increase overall waste across the Union.

I own a small business in Germany, supplying niche industrial electronics for research, development and test/measurement applications where high accuracy is of critical importance. While many products are sold in Germany and abroad to businesses and government entities, it would essentially now be impossible for us to register for PPWR given the overall costs of appr. 20.000 Euro and annual fees at a similar level.

I am a small business owner with a modest turnover. The main reason for starting my own business was because my chronic illness prevents me from working for other people. I have no other means of supporting myself. As a single-person business I cannot afford to register with every country in the EU to handle the proposed rules. If there is no exemption for small businesses I will have to close my operation.

I run a sole trader business in Germany and even before 12 August 2026 I was effectively excluded from the majority of the EU single market, as I was already only shipping to those EU countries where either a de minimis threshold for micro-enterprises applied or where I was already registered.

I am the founder of a Swiss micro-enterprise preparing to sell one small electronics product in the EU. The current system effectively excludes small companies from the EU market. I have received quotations indicating fixed EPR compliance costs of around 15,000 per year for EU-wide Packaging and WEEE compliance (see price list of a trusted compliance company attached).

The PPWR pursues important and correct environmental objectives. However, from the point of view of a German micro-enterprise, the current national design of EPR/producer registration leads to a disproportionate burden on cross-border trade.

Filed in German · English published by the European Commission

You are about to put me and thousands of artits and creatives already struggling out of business with this crazy law! The rules are disproportionately burdensome for micro-businesses, sole traders, independent artists and small creative businesses that sell modest quantities across EU borders.

I'm representing a jewellery gallery in Estonia, representing more than 100 jewellery artists. We plan to increase our exports to other EU member states. We already declare our packages in our local register. If the requirement to register and find local representatives in all member states remains intact, it will significantly hinder our exports and effectively keep the EU internal market closed for single artists…

Hello, I am a manufacturer of shaving planes with my own brand and 125-year-old tradition. I sell b2b goods worldwide. From a dedicated online shop as a ‘producer show window’, I sell the razors across Europe from Estonia to Portugal or Romania. Last year, the volume of parcels we received abroad in Europe was less than 100 parcels per country.

Filed in German · English published by the European Commission

We are a micro-enterprise with fewer than 10 employees and do not have our own production. We act as a fully responsible supplier to our customers. Our manufacturing partners produce the parts ordered, purchase the necessary packaging materials, package the goods and send them directly to our customers. However, it is sent on our behalf, with our labels and delivery notes.

Filed in German · English published by the European Commission

Hello, What is the point of passing a law that will make small and micro businesses unable to sell within the EU? This entire project will make it economically impossible for small businesses to sell to other EU countries which just defeats the entire purpose of a free-trade zone. Companies under a certain revenue should be entirely exempted at the very least and a single unified system needs to exist.

For many craft businesses, cross-border deliveries are not mass market transactions, but individual customer orders or occasional online sales to other EU Member States. If already few deliveries generate high registration and administrative costs, there is a significant barrier to market entry within the European single market.

Filed in German · English published by the European Commission

We fully support the environmental objectives of the PPWR. Producers should take responsibility for packaging waste, recycling systems should be financed properly, and unnecessary packaging should be reduced. However, the current implementation risks undermining one of the EUs most fundamental achievements: the Single Market and the free movement of goods.

Ladies and gentlemen, I am writing to you today with a concern that has become very busy and increasingly burdensome for us as a small German packaging trader. I have already written a letter a few days ago to the relevant Commissioners, which I enclose with this letter. For months now, we have been working intensively on the practical implementation of the PPWR.

Filed in German · English published by the European Commission

Subject: PPWR disproportionate burden on micro-enterprises Dear Sir/Madam, as operator of a one-person e-commerce company, I would like to draw your attention to the PPWR’s completely disproportionate impact on micro-enterprises, in my view. I have been running my business for almost 15 years.

Filed in German · English published by the European Commission

I represent a German micro-enterprise that has also been selling goods to customers in other EU Member States for many years. We support in principle the objectives of Regulation (EU) 2025/40 on packaging and packaging waste, in particular packaging prevention, recyclability and producer responsibility.

Filed in German · English published by the European Commission

Ladies and Gentlemen, We have been a sole trader since 2018 and import and sell goods to Amazon. We have our own small brand. We also produce goods in the third country on behalf of advertising agencies and for their industrial customers. However, our turnover is manageable. As the name (sole trader) says, I handle the import almost entirely on my own.

Filed in German · English published by the European Commission

In my view, the seller of the packaging must pay tax on the packaging. In case of doubt, the product must be appropriately certified for countries. That is how I, as a buyer of packaging, can choose to package in my own country or abroad. The packaging may have a test stamp. Thus, the packaging is taxed, anyone can check the taxation directly.

Filed in German · English published by the European Commission

Ladies and gentlemen, I would first like to point out that the introduction of the PPWR rules is exemplary for many things that are going wrong in the EU and also within the Member States. Once again, it is a highly bureaucratic entanglement, with disproportionate costs for individual traders (authorised representative, minimum fees in some countries, etc.).

Filed in German · English published by the European Commission

We are an open Makerspace in Kaunas, Lithuania. Our goal is to accept everyone from our city into our community to build and learn together. We provide the facilities, tools and equipment, you are welcome to work on your projects. Without a fee. We rely on donations to survive. In the last three years we have started creating electronics projects, all made with the help of volunteers from within the community.

Ladies and gentlemen, as the operator of a small online shop, I would like to draw your attention to a particularly critical point of the PPWR: the obligation to appoint an authorised representative in cross-border sales. We have invested a lot of time and money in recent years to expand our webshop for the European market through translations, technical optimisation, better visibility on Google and advertising.

Filed in German · English published by the European Commission

Feedback on the proposed rules for national producer registers under the Packaging and Packaging Waste Regulation I am a small handmade business based in Spain, selling wooden wall décor through my own webshop and online marketplaces such as Etsy and Amazon. I fully support the objective of reducing packaging waste and making producers responsible for the packaging they place on the market.

I have to complain about the PPWR. Not only smaller traders suffer. Also the manufacturing sector, e.g. mechanical engineering. Spare parts are not available to the recipient; machinery stoppages, including in industry, occur simply because there are no spare parts at all, but they would have to be obtained behind the border, but will not come because of the PPWR.

Filed in German · English published by the European Commission

As the Germans say: Gut gedacht, schlecht gemacht. Well thought out, poorly executed. The execution is in direct conflict with the concept of a Single Market, one of the EUs founding principles. I would not be surprised if we see successful legal challenges against this over-bureaucratic monster. You are: Killing small initiatives and making it harder for small businesses to operate across borders.

As a small business owner, I strongly support the goals of reducing packaging waste. However, mandatory EPR registrations, fees and separate administrative requirements in multiple Member States create a disproportionate burden for micro-businesses. For very small sellers, these fixed costs and bureaucratic obligations can make cross-border sales within the EU economically impossible, undermining the Single Market.

I run a one-person registered micro-enterprise in Belgium specialising in handmade marbled paper, serving customers in Belgium, across the EU and internationally. It provides about half my income, and I have invested substantially in a professional home studio. I personally handle production and every aspect of the business. I fully support reducing packaging waste.

I am the owner of a French micro-enterprise selling physical products online to customers in several EU Member States. I fully support the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR) and the principle that producers should contribute to the collection and recycling of the packaging they place on the market.

CCTC contribution to the European Commission’s Have Your Say consultation on the implementing act concerning national producer registers under Regulation (EU) 2025/40 The Croatian Chamber of Trades and Crafts (CCTC), representing more than 148,000 Croatian crafts and small businesses, welcomes the Commission’s objective of establishing harmonised, interoperable and machine-readable formats for registration in and…

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

I am a manufacturer under the Packaging Act because I import well-known branded goods from third countries into Germany and sell them to final consumers. This means, for me, that I must first register all the brand names of the manufacturers in the LUCID register, which I sell myself and which are shown on the packaging boxes. I also need to find out how difficult the sales packaging and padding is for each item.

Filed in German · English published by the European Commission

Ladies and gentlemen, as managing director of a small German e-commerce company which also sells its products across borders within the EU, I would like to draw your attention to what I consider to be a particularly critical point in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

We are an SME online trader based in Germany and sell cross-border to consumers in many EU Member States through online marketplaces, in particular Amazon. We support the objective of Extended Producer Responsibility (EPR) and the ‘pay-as-you-throw’ financing of packaging disposal.

Filed in German · English published by the European Commission

As a small company producing individual packaging, we are particularly affected by the implementation of the PPWR. A large part of our orders consists of very small print runs of only 20 to 50 packages. However, the documentation and administrative burden is almost independent of the level of requirements.

Filed in German · English published by the European Commission

I am a UK-based SME, and have sold my own technology products into the EU for a decade. The products are responsibly packaged in recyclable materials and designed for a long life. The cost of meeting the directive as it currently stands - specifically the cost of registering across all member nations I sell to (the majority of EU members) makes selling into the bloc unaffordable.

We are an online trader in Germany and call us micro-enterprises within the meaning of the PPWR. We are well aware that the PPWR pursues important environmental policy objectives. However, its concrete implementation in the field of packaging, and in particular e-commerce, is unfortunately a prime example of bureaucratic overregulation by the EU; this is particularly true given the administrative burden per unit of…

Filed in German · English published by the European Commission

We are a small company selling natural products with the highest environmental and sustainability standards. In any case, we support the reduction of resources for protection. However, this directive is a red tape with unprecedented costs. In the current economic situation in Germany and Europe, it is another stumbling block to keep the company profitable.

Filed in German · English published by the European Commission

Ladies and gentlemen, as an operator of small online sales, I would like to draw your attention to some of the effects of the PPWR on micro and small enterprises, which in my view are particularly problematic. Selling abroad in the EU has been an obvious growth step for small businesses so far. The obligation to appoint an EPR authorised representative may significantly change this invoice.

Filed in German · English published by the European Commission

As the SCM and procurement manager for a larger, global entity, I have no understanding of the procedure. Please first ensure that European law is transposed into national law, define limit values for reporting obligations and create a central reporting master.

Filed in German · English published by the European Commission

We fully support the environmental objectives of the PPWR. But the administrative architecture risks making cross-border trade economically irrational for micro and small EU businesses. A small EU company wishing to sell throughout the Single Market can face its home-country registration plus up to 26 authorised representatives in the other Member States.

I have a small business in Germany since 1993, since 2003 I have an online shop, selling instructions and craft materials for porcelain doll makers worldwide. Most of my customers are in the US. All went well until Trumps tariffs when DHL stopped shipping Warenpost International up to 1000 grams to the US. I can survive that.

On behalf of D&D Sp. z o.o., a Polish medium-sized printing company operating Printnet.pl, I request urgent simplification of the extended producer responsibility (EPR) requirements arising from Regulation (EU) 2025/40 (PPWR) for SMEs sending small quantities of packaging to other Member States. We send approximately 3,500 consignments annually to 12 EU Member States.

The Packaging Directive violates the EU Constitution as a free trade area. In practice, this means that all smaller companies in the EU are excluded from essential parts of EU trade due to financial and administrative barriers. For my part, I can then only send books within Sweden and to the rest of the world EXPLANATORY FOR the EU.

Filed in Swedish · English published by the European Commission

DREGENO SEIFFEN eG www.dregeno.de Stellungnahme der DREGENO SEIFFEN eG zur Verpackungsverordnung (PPWR) Verhältnismäßigkeit und Belastungen für Kleinstunternehmen müssen stärker berücksichtigt werden Die DREGENO SEIFFEN eG unterstützt grundsätzlich das Ziel der Europäischen Union, Verpackungsabfälle zu reduzieren, Ressourcen zu schonen und die Verantwortung für Verpackungen entlang der gesamten Wertschöpfungskette…

Filed in German · English published by the European Commission

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

Hip-Hop Enterprise (BE 0690.711.759) is an independent Belgian record label and webshop, active since 2018, with no employees. We release around twenty titles a year on vinyl, CD and cassette and distribute for over thirty other independent labels, selling via our webshop, Discogs, direct mail orders and record shops worldwide. Vinyl is pressed in Portugal, CDs in Poland, our shipping packaging bought in Germany.

Antiquariat [name removed] [address removed] An die EU-Kommission Sehr geehrte Damen und Herren, als Betreiber eines kleinen Online-Buchhandels möchte ich die Gelegenheit nutzen, auf einen aus meiner Sicht besonders kritischen Punkt der geplanten Umsetzung der PPWR-Herstellerregister hinzuweisen: die Pflicht zur Bestellung eines Bevollmächtigten für die erweiterte Herstellerverantwortung beim grenzüberschreitenden…

Filed in German · English published by the European Commission

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

— It would certainly be much easier, if at all necessary, to implement rules on the Packaging Ordinance at the place of origin rather than for a company in all EU countries. Of course, this requires trust between the various authorities in the EU countries. Simplification on the basis of the size of the company is not appropriate. If so, it should be tied to the volume of consignment/packaging for each country.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

I think this is a good initiative to protect our continents environment. However, these measures should be realistic and proportionate to businesses of different sizes. It would make sense to enforce stricter requirements on large corporations, given that the amount of waste they produce is significantly greater and not even comparable to that of small businesses like mine.

Ladies and gentlemen, as an entrepreneur of a small business, I would like to give you my personal and honest feedback on the planned implementation of the PPWR. My impression is: In its current form and with the associated requirements, this Regulation risks becoming an existential burden for many small and medium-sized enterprises.

Filed in German · English published by the European Commission

As a small specialist trader in globes (cartographic products), we had an approximate profit of 6000 in the EU. As it is not economically viable to conclude a contract with 27 Member States on this scale, we stopped shipping outside Germany on 12 August 2026. It is all the more annoying that we have already introduced the Wero. The Wero is also a tool for strengthening intra-EU trade.

Filed in German · English published by the European Commission

Esponse to a Verpackungsgroßhandel : Everyone in Europe uses bags that meet all the necessary requirements. Don't assume that bags in Germany are any greener than those in any other country. The real issue is this: the manufacturer of these bags has already paid the so-called "ECO" or recycling fee.

I am a sole trader in France and I manage a small e-commerce business specialising in the sale of miniature collectors’ items on 1/43. The application of the PPWR to micro-enterprises selling in more than one Member State raises a major proportionality issue.

Filed in French · English published by the European Commission

Business profile: Small family-oriented niche e-commerce. Main sales model: Servicing the domestic market and cross-border mail order sales to other countries of the European Union. Market specificities: Offer to a narrow, specialised audience (collective/hobby) for which the purely national market is too small to ensure the viability of the business.

Filed in Polish · English published by the European Commission

Hypocritically, I would write: I support the EU in its efforts to reduce global pollution, but as a micro-level artisan, I feel that my legal access to the single European market is de facto banned, because the financial and administrative requirements set out in this packaging regulation are completely unbearable for me.

Ladies and gentlemen, as managing director of a family business with 11 employees and less than EUR 2 million turnover, I would say clearly: It is enough. The limit of the burden on small businesses due to ever-new rules, evidence and bureaucracy has been reached. We had to create additional human resources only to cope with regulatory requirements such as the PPWR.

Filed in German · English published by the European Commission

As long as system participation and disposal fees for packaging are not uniformly regulated across Europe, there are significant competitive disadvantages for companies that diligently fulfil their legal obligations. As an established company, we buy systemically involved service packaging or, in the case of imported packaging, carry out the required system participation ourselves.

Filed in German · English published by the European Commission

We sell small quantities online and have so far generated around 50 % of turnover in other EU countries. So far, unfortunately, on 12 August 2026 we had to stop this foreign business completely because of the PPWR, as the costs and burden of registrations, proxies, etc. are simply too high and do not bear any costs. For a small company like ours, this law is a complete disaster, and our business model is at risk!

Filed in German · English published by the European Commission

Ladies and gentlemen, we strongly support the European Union’s objective of reducing packaging waste, improving recycling and financing disposal costs in a polluter-pays-friendly manner. What we cannot support, however, is a system in which the management of packaging ultimately costs more than packaging, its disposal and, in some cases, even the turnover it generates.

Filed in German · English published by the European Commission

Micro enterprises can't afford this. You're killing the single market. Why would you implement anything if you don't already have a system designed and ready to go? Do you honestly expect the member states to ever accomplish anything? Look at Germany. It's 2026 and people still use fax machines regularly. Doctors still can't figure out how to send a sick note electronically.

As a small enterprise, the obligation to register in every EU country is a heavy bureaucratic hurdle. This was much better regulated in the case of turnover tax using the one-stop-shop procedure. The additional cost for an authorised agent in each EU country is much higher than the expected gains from selling small quantities. Here too, an OSS approach would be preferable.

Filed in German · English published by the European Commission

Ladies and gentlemen of the European Commission, The PPWR, which has now entered into force, completely runs counter to the idea of free trade within the European Union and impedes small and medium-sized enterprises from offering their goods or supplying them throughout the EU.

Filed in German · English published by the European Commission

Ladies and gentlemen, this type of legislation is EXAKT the reason why the right-wing parties across Europe are growing up. Ideation: good. Implementation: Shake out the child with the bath. Small side effect: Tens of thousands of small businesses are standing at the abyss. Absurd EU bureaucracy and regulatory quest with real, the same consequences for small senders, who have built something out of it in the niche.

Filed in German · English published by the European Commission

I run a small online specialised pet shop. I send several packages per month to retail customers in the EU, ensuring that the waste used is as low as possible and that the packages are filled as much as possible. My clients are often carers of sick and needy animals. The new rules, as presented, will put an end to this possibility for my business, which will be completely uneconomical.

Filed in Polish · English published by the European Commission

This is a really confusing piece of legislation and impossible for small businesses, (one-person-businesses, craftspeople, artisans and artists) to comply with. I will not explain the difficulties as all other respondents have done so very articulately. Why can't a recycling fee be included in the price of the packaging when we get it for our shipping?

Ladies and gentlemen, as managing director of 24/7 Handels GmbH, I have been trading online with EUFORY for many years, having its registered office in Hamburg. We send our goods not only within Germany but also to customers in other EU Member States and already meet the respective national packaging and registration obligations.

Filed in German · English published by the European Commission

I am an Italian artisan working alone, creating original commissioned artworks. Each piece is entirely handmade and every package I ship corresponds to a single artwork. Most of my commissions come from clients in EU Member States, but I don't ship annually to each country, and I rarely ship more than 1 parcel per year to the same country.

We have tried to implement this complex regulation for an industrial company that sends industrial products to the rest of the world. The number of packaging elements was still manageable, with 140 items. 50 % of packaging suppliers did not know how to proceed. We then took them to our hands, explaining everything and creating a form to return to us signed by them.

Filed in German · English published by the European Commission

Our company works exclusively in the B2B business and places transport packaging on the market. The packaging is sorted by our customers, partially reused and otherwise disposed of in a professional manner. The mandatory affiliation to producer responsibility organisations (actually a take-back organisation) upsets the current practice of how companies work with each other and generates disproportionate costs.

Filed in German · English published by the European Commission

It is increasingly clear that this Regulation has been so impractical that nobody knows how to implement it correctly. Even packaging producers do not understand the interpretation. In addition, the burden is also becoming more and more noticeable, especially for small and medium-sized enterprises. Our cartonboard supplier initially explained that it had nothing to do with producer obligations, i.e.

Filed in German · English published by the European Commission

Dear Sir/Madam, I represent the music PR agency Dr Music Promotion, Miriam Guigueno & Torsten Wohlgemuth GbR from Hagen, Germany. Unfortunately, we are also negatively affected by the PPWR Act. To date, we have been testing foreign music magazines and blog editors with promo CDs. For this reason, we would be directly affected by the Act, as for monetary and bureaucratic reasons we simply cannot afford the burden.

Filed in German · English published by the European Commission

Great job, EU! The new packaging waste regulation law is a bureaucratic masterpiece. Under the guise of saving the environment, you have successfully crushed sustainable, small-scale competition and handed a monopoly to global e-commerce giants.

PPWR: 124 pages of bureaucracy have someone actually read it before voting on it? The objectives of the PPWR may be useful. However, implementation works like a real bureaucratic monster: complicated, expensive and far from the reality of small and medium-sized enterprises.

Filed in German · English published by the European Commission

Als B2B/B2C-Mischbetrieb fordern wir dringende Nachbesserungen an der PPWR zur Entlastung des Mittelstands. Die aktuelle Bevollmächtigtenpflicht (Art. 44) erzeugt existenzbedrohende administrative Fixkosten bei Export-Kleinstmengen. Wir schlagen drei konkrete Lösungen vor: (1) Die Einführung mengenbasierter statt umsatzbasierter Bagatellgrenzen pro Zielland (z. B. <250 Pakete/Jahr).

This is murder! I am a solo entrepreneur and artist from Sweden, who sells my locally crafted items online to all over Europe, and one of those who offer customers a sustainable alternative to the giants such as Amazon and Temu. These new rules are devastating to us!

As an operator of a small individual company in the field of personalised textiles, we would like to draw your attention to what we consider to be a serious design error in the planned implementation of the PPWR producer registers: The obligation to appoint an authorised representative for EPR in cross-border sales is disproportionate to what it aims to regulate.

Filed in German · English published by the European Commission

The envisaged PPWR obligation to appoint an authorised representative for cross-border sales in each EU destination country puts a burden on small online traders through disproportionate fixed costs and high administrative burden.

Filed in German · English published by the European Commission

Assessment of Regulation (EU)2025/40 PPWR Bromberger Packungen is family-owned, one-site-company with approx. 100 employees, that is in business since 1904. Having intensively read the PPWR (trying to understand and implement it) and above all having received a lot of consistent input from customers, suppliers, competitors and associations, we would like to shortly formulate our summary and assessment (given the…

As a small German e-commerce company with cross-border shipments within Europe, we would like to highlight significant practical problems with the implementation of EPR for packaging. Some of our packaging and shipping volumes to individual European countries are low.

Filed in German · English published by the European Commission

We would like to express the impractical nature of the PPWR. It is easy for foreign traders to manipulate through an intermediary and puts all small and medium-sized businesses in the EU at a huge competitive disadvantage. Trade in the single market is becoming impossible for many. Even with the licences, there is no sense or transparency.

Filed in German · English published by the European Commission

I strongly urge the European Commission to think about what impact the EPR legislation has on hobbyists such as myself who create products that sell at a small price and volume (mine for instance sells for around 50 and makes about two or three sales per month) that ship around Europe.

Subject: Ref. Ares(2026)7688068 – 06/08/2026 Draft: Commission IMPLEMENTING REGULATION (EU) & ANNEXES Article 44 PPWR expressly provides for national registers of producers in the individual Member States. Accordingly, a manufacturer must register separately with the relevant competent authority of each Member State.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Hello, as a one-woman model-building company (self-employed), the new PPWR hits me hard, and I can no longer simply send it to the EU. My packaging materials used are compliant and I also have the company documentation for this, I am registered with Zentek and Lucid. Costs for proxies and registrations in all EU countries go beyond my business.

Filed in German · English published by the European Commission

It would be much easier to just tax the packaging material itself with an amount or percentage, to be paid directly to the EU by the packaging industry. This gets rid of all the bureacracy. The packaging inductry probably succesfully lobbied against this, leading to this insane solution, but please rethink.

Ladies and gentlemen, as the owner of a small online shop, we would like to contact you regarding an aspect of the planned PPWR producer register that is serious for small businesses: the requirement to have a separate authorised representative for each EPR for cross-border distribution. So far, expanding to other EU countries has been a logical development and build-up step for our business.

Filed in German · English published by the European Commission

Micro and small businesses are the backbone of the EU and the UK. This policy is not only discriminatory against micro businesses, it is discriminatory against buyers. Innovative products designed by families, husbands, wives, will no longer be able to be purchased due to these punitive costs. Entrepreneurs need to be supported, not destroyed. Please stop this madness and help out.

With regard to the typologies of packaging materials: it will be necessary for assistance or a reminder to be provided on the definition of ‘predominant material’. It is not enough to say that this is the material with the highest proportions in the packaging.

Filed in French · English published by the European Commission

Ladies and gentlemen, this is an unparalleled bureaucratic effort, which is exactly the opposite of what we want to achieve. Registering in all national registers because you send goods abroad, which you have to pack for transport, will further hinder internal trade. Regulation is completely weak.

Filed in German · English published by the European Commission

Ladies and gentlemen, this Regulation is once again an example of a good idea: Prevent and recycle packaging waste. However, implementation has once again failed catastrophically. We are a small specialised electrical wholesaler with a webshop. For decades, we have been using cartonboard from our suppliers. Equally old newspapers used as fillers. Both are now more or less impossible with your regulation.

Filed in German · English published by the European Commission

[name removed] [address removed] the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales. As a small entrepreneur for rare motorcycle parts, which no longer exist anywhere in the world, sales to other EU countries have so far been a fundamental building block without a legal department of their own, but with the aim of complying with the law…

Filed in German · English published by the European Commission

Subject: Threat to livelihood posed by PPWR (Regulation 2025/40) Microenterprises in the field of baby handling. As owner-run microenterprises, we hereby submit a complaint against the design of the EU Packaging Regulation (PPWR). In practice, the Regulation has the opposite effect of a free internal market: It forces us to stop EU-wide trade, puts jobs at risk and blocks training in baby care and obstetrics.

Filed in German · English published by the European Commission

This law is not working and it is killing free movement of goods in EU if EU based companies have to get authorized Representative in every EU country. I run a small business here in the EU, and while I completely get why we need better waste management and recycling, the way the current EPR packaging rules work in practice is honestly a nightmare for people like me.

Ladies and gentlemen, as a trader offering a very special range of products, many of which can only be obtained from us throughout the EU, I attach particular importance to cross-border online sales. This is precisely what I see as being jeopardised by the planned obligation to appoint a separate representative for each target country in the implementation of the PPWR.

Filed in German · English published by the European Commission

Together with my wife, I run the small, family-owned online business. We are not a large corporation and do not have our own legal department or the financial and human resources available to major online platforms. In principle, I support sensible measures to reduce packaging waste and improve recycling.

I operate a small online shop in Germany and, honestly speaking, I find the planned rule on the obligation to appoint a representative very problematic, especially for small traders. I would like to continue selling my products to other EU countries. However, the problem is that, with few orders per country, this is simply not expected to happen at some point.

Filed in German · English published by the European Commission

DR. JOHANNES HEIDENHAIN GmbH supports harmonised and interoperable producer registration and reporting under Article 44 of Regulation (EU) 2025/40. However, the draft's level of detail risks creating permanent administrative, supplier-data and IT structures without a proportionate environmental benefit. Recording the weight of every minor component does not in itself prevent packaging waste.

It is dissapinting and utterly exasperating. Small business owners simply cannot afford the cost or the administrative burden of the PPWR regulations. Who comes up with this sort of thing? It is no wonder that the EU is increasingly viewed with skepticism by its 450 million citizens and that support for it is waning.

Packaging rules are implemented from the wrong side, that impose costs on the most vulnerable party, instead of building sustainable base. A great example are plastic straws. They were simply banned and you can't buy them.

The most important problem for Cyprus is that there are no alternative solutions for manufactures and packing. So, though we pay the contribution to the authorized collector (Green DOT) there is no service they provide to us. We have no means to recycle packing from paints (metal drums) or bituminous emulsions (plastic drums).

In my view, the PPWR is hardly surpassed by its weakness! I am an online trader and deliver to more than 20 EU countries – or HIGH I deliver to 20 EU countries! Because thanks to the PPWR, I am now obliged to have an authorised representative for each country, who costs me 299, plus VAT per year. Plus licensing fees for the packaging itself. The plenipotentiaries alone cost me almost 8000, including VAT per year!

Filed in German · English published by the European Commission

Hello, Why is this again a bureaucratic ‘mountain’ of? For years, it was good that the manufacturer of the packaging we ordered paid the royalties. Why is this being made more complicated again? My proposal: Maintain the (German?) rule that we receive the royalties via the actual producer/our supplier. Why should we, as an artisan bakery, do this now, even though it was actually doing well?

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

Hurra, the EU Packaging Regulation is there! Finally, another big step to save the world and a small step towards insolvency for small traders. You are a small business and you may send 20, 50 or 100 packages per month? No problem! After all, you have far too much free time.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

This new regulation is an absolute disaster for small businesses and their customers alike. I sell vintage goods around the world, and I expect to lose at least 20% of my total income thanks to these new rules. Which are, once again, perfectly tailored for the needs of major players. Also, especially residents of the smaller EU states will be successfully excluded from the internal market from now on.

I would like to express my strong opposition to the new Packaging and Packaging Waste Regulation. The obligation for companies to register in all 27 EU Member States and comply with separate national systems, as well as the related fees and administrative obligations, are extremely difficult to justify for small companies operating at the level of micro-enterprises.

Filed in German · English published by the European Commission

I am writing as an artist - painting, fibre creations and writing - and a one-person creative business owner. While I support the environmental goals behind the new EU packaging rules (PPWR), I question how micro-enterprises, small studios, solo artists, secondhand sellers of any types of goods can afford to comply, or indeed can even logically think about complying.

Ladies and gentlemen, as the operator of a small online shop, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in cross-border sales, in particular without thresholds.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

We are a very specialised company selling our products worldwide through our online shop. Because our selection of products is very specific, we are not a high volume seller. We ship products to the entire EU region, but depending on economy usually just 2-3 items per year to a single country. The resulting turnover per country is significantly lower than the required registration cost we would need to pay.

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as a traditional business in the field of hat and hood crafts (Germany’s oldest hat specialist business, founded in 1534), characterised by decades of craftsmanship, regional roots and passion for quality, we would like to draw attention in this consultation to a critical misdevelopment for European small and medium-sized enterprises.

Filed in German · English published by the European Commission

Ladies and gentlemen, I operate an online shop and send fewer than 1000 items per year. I would like to draw your attention to an aspect of the planned implementation of the PPWR Producer Register which, in my view, is completely untenable: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

As an owner of a small ceramic business based in Poland, having to comply with PPWR would significantly complicate or even make it impossible to sell my works to other EU countries due to high costs. In my opinion, such regulations deny the idea of the European single market

I run a small business with me as the only owner/employee. This law is completely ridiculous for my type of company. I use about 500 worth of packaging material each year. It will force me to end my business. EU solution is way too complicated. For starters, it is ridiculous to have to file your use of packaging in each country you ship to seperatly.

Subject: Practical check PPWR: Red tape for small online traders through the obligation to have an authorised representative. Ladies and gentlemen, as operators of small online sales, I am writing to you today with an urgent request and a practical impulse to the planned implementation of the EU Packaging Regulation (PPWR).

Filed in German · English published by the European Commission

We support the environmental objectives of Regulation (EU) 2025/40 and the improvement of packaging collection and recycling. However, the current draft risks placing a disproportionate burden on small and medium-sized enterprises with pan-European supply chains. It is true that the registration and reporting formats are to be harmonised.

Filed in German · English published by the European Commission

The current packaging rules place a disproportionate burden on micro-businesses and working udr sefl employment status. 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.

Hello, as an individual company, I am a graphic designer usually engaged in the provision of services. In view of my turnover, which is falling freely with the use of AI, I intend to open an online shop with posters or other artistic creations of recycled materials, media and parcels (I intend to upgrade natural plants to make my own paper and make photoengraving with natural pigments).

Filed in French · English published by the European Commission

www.44elfweinspeicher.de 44elf Weinspeicher • Am Königsbrunnen 16 • 99867 Gotha An die Europ. Komission Stellungnahme zur PPWR aus der Sicht eines Weinhändlers 25.08.2026 die europäische Gesetzgebung hat das Ziel, den Binnenmarkt zu stärken und die Umwelt zu schützen. Die am 12.

Filed in German · English published by the European Commission

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

Absolute absurdity, willingness to fail small businesses. We will no longer be able to trade with either physical or legal partners abroad because the contributions are simply unbearable, most of our businesses will fail, many years of construction and entrepreneurship will simply fail.

Filed in Lithuanian · English published by the European Commission

I am writing as a beginning artist and a one-person creative business owner concerned about the practical impact of the new packaging requirements on very small businesses. I fully support the environmental goals behind these rules. I also try to make my own business as sustainable as possible: I reuse packaging whenever I can, avoid unnecessary materials and carefully consider how each parcel is packed.

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

Filed in German · English published by the European Commission

As a small-scale farmer and food processor, I am concerned that the proposed packaging regulation would create a significant additional administrative and financial burden for small businesses. The new requirements could be disproportionate to the scale of our operations and may discourage small producers from investing, developing new products, and expanding their businesses.

I welcome the European Commission’s aim to harmonise formats and data requirements for producer registration and extended producer responsibility reporting. From the point of view of a small producer, this harmonisation is necessary.

Filed in German · English published by the European Commission

This goes against one of the basic principles of the EU, free movement of goods. The only beneficiaries from this regulation are established multinationals because they have the resources to comply and thus it will limit competition. The consumer will have less choice and there will be less cross border cultural exchange. Not to speak about the footprint of this data and control operation by itself.

I have been selling small spare parts worldwide for 15 years. Above all, of course, also to the EU. It is not reasonable for me as an individual to appoint an authorised representative and to register and report in all 27 Member States alone. Neither the burden nor the costs are in any way proportionate to the size of my business or to the benefits of the new regime.

Filed in German · English published by the European Commission

Good afternoon, I am a retailer (online) and have no employees. As a result of my annual turnover, I am registered as a small businessman. My plan to expand the industry has been set back by the scheme. I had to stop shipping to the EU altogether (approximately 10 % of turnover so far).

Filed in German · English published by the European Commission

As a maker and buyer of products from small independent makers and producers I support Jeanette Koňarčíková`s well formulated feedback on this proposal and I copy her full argumentation and suggestions in support of our common case: To: the European Commission and the European Parliament "The Single Market is broken for small creators.

I support the objectives of the PPWR and the principle that whoever places packaging on the market should pay for its collection and recycling. My concern is that the registration and producer responsibility costs are fixed per country instead of proportionate to volume. For a business of my size they exceed the profit the activity generates.

As someone intending to start a micro business in the EU selling small hardware products, it is completely insane that I have to register with a bunch of different country beurocracies in order to sell a tiny amount of products. It is a fundament violation of the principle of a common market and you should be ashamed of yourselves for failing in your duties to advance the goals of the EU project so comprehensively.

Ladies and gentlemen, Modern Eves is a small jewellery boutique in the heart of Munich & distributes self-designed & made jewellery in small series. Our store has been in existence for over 20 years & employs 2 people.

Filed in German · English published by the European Commission

I would appreciate an exemption for small business to this ruling. It isn't feasible for me to register and pay fees to every country I may ship an order to, as there may only be a handful every year. I am already operating my business to reduce waste material as much as possible and package my orders with recyclable or compostable materials.

Call for reducing the burden on micro and small enterprises in the implementation of the PPWR. As a small business, we generally support the PPWR’s objectives of reducing packaging waste and promoting the circular economy. However, the envisaged registration, documentation and reporting obligations place a significant economic and time burden on micro and small enterprises.

Filed in German · English published by the European Commission

Our client number in the Transparency Register is: 7700812346 (but cannot be encoded)! Ladies and gentlemen, as a German manufacturer and a dynamically growing start-up, we would like to draw attention to a particularly critical point in our view regarding the planned implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in case of cross-border…

Filed in German · English published by the European Commission

We do job processing in the semiconductor industry. Our customers (national, EU, third countries) send good to us for processing, we re-use the packaging for sending the good back to their origin. However we do add small amounts of packaging material (like packaging tape or zip-ties) to re-seal parcels or re-usable boxes. The total amount of newly added material sums up to way less than 100 kg per year.

I am a small Dutch entrepreneur and sell my own books and card decks online. A small proportion of my orders go to consumers in Belgium. My company concerns only a few kilos of packaging material per year. Since 12 August 2026, I have completely halted my sales to Belgian customers as a precautionary measure due to the new PPWR/EPR obligations.

Filed in Dutch · 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

The new PPWR makes us, as small traders, more difficult than difficult. The workload and bureaucracy are almost impossible for us to grasp and do. Today, 25 % of our working time is spent on bureaucracy. The huge costs incurred by the new PPWR have forced us to stop shipping to EU countries, which means a sudden loss of turnover for us.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

IGEPHA welcomes the objective of an EU-wide harmonised format for registration and reporting under Extended Producer Responsibility (EPR). A uniform system should lead to a reduction in red tape for companies with cross-border activities.

Filed in German · English published by the European Commission

I am a sole trader without employees and operate an online shop for amateur accessories from my own 3D-printing production. By 12 August 2026, I had delivered to final consumers across the EU. Since that date, I have only been delivering to Germany. The reason is Article 45(3) PPWR.

Filed in German · English published by the European Commission

As a small business, we recognise the importance of EU regulations in bringing fairness and reducing barriers to trade, not just for big corporations, but also for small businesses like ours. Therefore our overarching feedback is that the implementing rules should ensure compliance costs are proportionate for micro and small businesses placing only small quantities of packaging on the market.

As much as I approve of the objective of the Packaging and Packaging Waste Regulations, they are simply impossible to follow as a small business owner. I just started my one-person business including an online shop for handmade and small quantity manufactured design products.

This Regulation is neither financially nor administratively affordable for any small manufacturer. Their ideas and regulations have in the past been more than inconsistent and incoherent, e.g. the imprudent VAT method of distribution in the EU, a procedure for declaring a few boxes to each individual EU country puts the crown on this list.

Filed in German · English published by the European Commission

Good afternoon at the new PPWR, I am extremely disturbed by the fact that, as a small consignor for a few parcels per year, I have to register in different EU countries. The administrative burden is far too high and too expensive: Authorised representatives, provide all information, etc. This costs a lot of time and – the authorised representatives do not work for money.

Filed in German · English published by the European Commission

As a solo entrepreneur who has only just launched a business in Portugal, I am worried that these new regulatory burdens have killed it before it has even begun. While I strongly support the idea of creating a more sustainable environment for handling packaging waste, I absolutely cannot afford the costs necessary to register in even a handful of EU countries, nevermind all of them, when my EU-wide revenue is a…

As much as we support the European idea and also the objectives of the Packaging and Waste Management Regulations – the current version of the PPWR makes it completely uneconomic for small and micro-enterprises to act within Europe. Why is there no EU-wide scheme or at least ONE declaration of quantities to a central body, which then redistributes, similar to OSS tax processing?

Filed in German · English published by the European Commission

Dear European Commission, Unfortunately we too had to stop trading in other European Member States. As a result, we lose around 30 % of all sales. We have every day enquiries from customers who ask us to resume sending them. We too cannot afford this from an economic point of view and small businesses cannot afford it.

Filed in German · English published by the European Commission

This is still a beurocratic burden which drastically affects small entrepreneurs. The main issue in my opinion is: - countries being able to add burden to companies - not abstract the different rules away from the company - the local country laws should be the abstraction layer for the entrepeneur.

Small trader stops EU transit: fixed costs per Land are the problem We are an online specialist trader for soil care products from Baden-Württemberg with fewer than 10 employees. We strongly support the objectives of the PPWR. With regard to the design of the national registers of producers, we would like to draw attention to a consequence that we have just carried out ourselves. 1.

Filed in German · English published by the European Commission

I run a one-person business selling a niche product online to customers all over the EU. In a whole year, everything we ship adds up to about 112 kg of packaging across every country combined. Our biggest market is 36 kg. To be allowed to keep doing that, I would have to register as a producer in 25 separate countries. The quotes I have seen come to around 7.5% of our turnover.

With the help of the employers’ association Druck und Medien Baden-Württemberg, we are trying to comply with the PPWR. Our 25-strong company has long exceeded the frustration threshold. Hours are spent without knowing whether what is being done is right. The question of whether it makes the same sense and could lead to success seems to us to be completely abstract.

Filed in German · English published by the European Commission

I fully share the environmental objectives of the Packaging and Packaging Waste Regulation (PPWR) and the need to reduce packaging waste, improve its recyclability and incentivise the use of more sustainable solutions.

Filed in Italian · English published by the European Commission

For us as a small business, the costs are prohibitive. As a result, we unfortunately had to stop all our foreign shipments to the Ei Länder. Our Austrian customers in particular regret this very much. Every household already pays its rubbish! And we are already packaging very sustainably. Thank you for doing small business. Yours sincerely, Ronny Seifert

Filed in German · English published by the European Commission

Hello, too often, too many monsters will be created here in a bureaucratic way. As small businesses with six sales outlets, we have to make huge efforts to cope with ever-increasing documentation requirements. In addition, it makes no sense at all. Who is helped when we buy a licence, our bags are disposed of by the end customer and not by the licensor.

Filed in German · English published by the European Commission

I just opened a small makerspace and collective in Lisbon with a few of my friends. Our primary objective is to have fun and experiment, but we also had plans to develop art pieces and helpful items and sell them online. For now, thats definitely on hold and we dont have the time or income to pay these fees to ship throughout the EU. We will limit our market to Portugal only.

We welcome the objective of harmonising producer registers and reporting formats within the EU. However, from the point of view of a German micro-enterprise in cross-border online trade, the draft is not sufficient to remove the considerable administrative burden. Our company sells food and products for Japanese cuisine to several EU Member States through its own online shop and online marketplaces.

Filed in German · English published by the European Commission

The European Commission’s dearth, the creation of another database for entrepreneurs in each EU country is an additional burden for entrepreneurs who already have to comply with a number of obligations imposed by the European Union when operating in the EU. Each country has different bases to fulfil, slightly different rules and requirements despite uniform legislation, and different obligations to fulfil.

Filed in Polish · English published by the European Commission

Dear Sir/Madam, I operate a small online shop and am very critical of the obligation to appoint an authorised representative for EPR in cross-border sales. Until now, I have always been overwhelmed by the EU and the simplified Single Market. But the new PPWR law is radically changing this attitude, as it runs counter to the very objective of the EU’s internal market!

Filed in German · English published by the European Commission

I operate a small online trade in second-hand toys. To date, I have been able to send to the EU, accounting for around 20 % of my turnover. As my business is carried out on a secondary basis and rather as a hobby, I have neither the capacity nor the financial resources to meet the requirements of the PPWR. I have therefore restricted my dispatch to Germany and non-European countries.

Filed in German · English published by the European Commission

As a small European entrepreneur, I strongly support reducing packaging waste. But PPWR should not make cross-border trade so complicated that small EU businesses are effectively discouraged from selling to customers in other Member States.

The objective of harmonising packaging rules and funding collection and recycling is sound. The current national registration model does not achieve it proportionately for micro-enterprises selling cross-border. A producer placing under a kilogram of packaging per year on the market in a given Member State faces registration fees, scheme participation and, in most cases, an authorised representative.

Ladies and gentlemen, as an operator of small online sales, the obligation to appoint an authorised representative for extended producer responsibility in cross-border sales poses a threat to my livelihood. Up to now, as a small entrepreneur, selling to other EU countries has been an obvious step forward without a legal department of my own, but with the aim of complying with the law in force.

Filed in German · English published by the European Commission

Comments from an online trader in Germany Dear Sir/Madam, in advance: The objective of the Regulation is correct. Anyone who places packaging on a market should pay for its disposal there. We do not dispute this and we are already paying. Our criticism concerns only implementation from our point of view, and it costs the Union more economic output than it generates in terms of environmental benefits. 1.

Filed in German · English published by the European Commission

I am a small independent business owner, creator, and seller. Mandatory EPR registration fees and the complex bureaucracy required for cross-border sales make it extremely difficultand often economically impossiblefor micro-businesses to sell across EU borders.

If the EU is of the opinion that small traders should continue to be burdened, then it is only at a cost and not with red tape. A small levy charged per parcel via the shipping service provider or when purchasing the shipping packaging via the manufacturer would not impose a bureaucratic burden on the small trader, fraud and checks would not be possible or necessary.

Filed in German · English published by the European Commission

Unpackt e.V. welcomes in principle the objective of harmonising registration and reporting under extended producer responsibility across Europe. Uniform digital procedures can reduce administrative burdens and make the implementation of the PPWR more transparent. At the same time, more attention needs to be paid to small and micro-enterprises and business models that avoid packaging at source.

Filed in German · English published by the European Commission

The PPWR is in itself a beautiful thing, but for micro-traders the costs involved exceed the profit. I have been running a small mail-order shop with special articles for years, which I will no longer send to the EU, and the rules should not be reduced to a simple and tolerable level. I have been contributing to the disposal of waste in Germany and Austria for years, as these are my main destination countries.

Filed in German · English published by the European Commission

As a Swiss micro-enterprise, it is unfortunately no longer financially viable to supply potential customers in neighbouring countries. The bureaucratic and financial hurdles of the new rules far outweigh the benefits. Ordering from abroad is much easier, cheaper and easier. The basic idea of reducing packaging and ensuring its cost-covering disposal makes sense.

Filed in German · English published by the European Commission

Comments on the PPWR Dear Sir/Madam, I operate the MS-KristallGlanz online shop in Germany as a small entrepreneur and sell predominantly selected precious stones, minerals and special individual items. I would like to draw your attention to the concrete impact of the PPWR on very small online traders. To date, I have also sold my products to customers in other EU Member States.

Filed in German · English published by the European Commission

I would like to ask the European Parliament to review the impact of Regulation (EU) 2025/40 on packaging and packaging waste on micro and one-person companies and to advocate for a genuine de minimis rule. I run a small publishing and crafts company in Germany that produces science-based and partly manually colored signage for zoos, animal parks, falconries and similar establishments.

Filed in German · English published by the European Commission

The rules proposed here, while good in intention, add friction and make it hard for small businesses to be compliant. That's the wrong move for multiple reasons: 1. it widens the gap between the capex necessary to compete in EU-markets. Small businesses that are just starting will find it hard to do this cheaply compared to big ones. 2. it adds complexity to something that could be made super easy.

Ladies and gentlemen, the new Packaging Regulation has simply gone too far. The idea behind this is certainly understandable, but its implementation does not correspond to my definition of debureaucratisation and burden reduction. It is precisely at this time that small businesses should be supported and not ruined! Their decision costs livelihoods. This is simply no longer sustainable!

Filed in German · English published by the European Commission

Hello together, if you want to ruin small companies with up to 40 employees and manageable turnover, please continue. We are a European Union, why we are making life difficult for each other. Please simply put the draft regulation in the trolley! Best regards, [name removed]

Filed in German · English published by the European Commission

Ladies and gentlemen, as the operator of a small online shop, I would like to take this opportunity to draw your attention to a point which, in my view, deserves particular attention in the planned implementation of the PPWR producer register: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Why will we no longer be able to supply all EU countries in the future? Is this rule particularly harsh for small traders? From our point of view, it is clear: yes. A large international trader can spread registration, advice, agency and administrative costs over millions of orders. We cannot. If there are five orders in a country, there is nothing to distribute.

Filed in German · English published by the European Commission

Ladies and gentlemen, I have been running a goldsmith for 13 years. We hand-operate to create pledging rings and marital rings. Although we work primarily for German customers, we also often have customers from abroad, e.g. Austria. The duty of plenipotentiary and the PPWR in general hit us hard. We are a small craft business and therefore do not have a legal department.

Filed in German · English published by the European Commission

I completely get what you are trying to achieve but I don't think the current solution is fair to small businesses within EU. It could cost 20k EUR even before the first package is sent, this nonsense makes it that the only sensible thing is to suspend all EU activities and only do non-EU businesses.

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

Filed in German · English published by the European Commission

leading to new product ideas and innovation. The EPR regulations threaten the existence of this innovative space in the EU. EU policymakers keep sounding the alarm about Europes lack of innovation, but seem hell-bent on making it as hard as possible for innovation to emerge at all, with regulations that create a disproportionate barrier to entry for micro-enterprises and SMEs.

By imposing this law on small traders you are in effect banging the last nail in to many of our coffins. It will prohibit us from free trade throughout Europe. Many small traders make a hand full of sales per year in different countries and this law will effectively prohibit that due to the registration fees required in each country.

Merchandise Number 1 Weight per Content Total Weight Value per Content Total Tariff No: 39269097 Description of goods: styling accessory for cars Germany Export supply under Section 6 of the Turnover Tax Act/Exempt under Section 4(1a) of the Turnover Tax Act As I am delighted to see that you have the opportunity to do so, I would like to point out that, with regard to the planned implementation of the PPWR producer…

Filed in German · English published by the European Commission

Greetings to all who read this. I am a small, in-home manufacturing business based in Ireland. Before the new packaging rules I was able to send the odd order that would come in from other EU states without worry or extra cost to me. I barely run at a profit and to even get registered with a single other EU nation for sending anything would wipe out almost all of my net profits for the year.

We are a small independent retailer based in Greece, operating since 2005 and selling directly to consumers across the European Union. We support the environmental objectives of Regulation (EU) 2025/40 and the principle that businesses should take responsibility for the packaging they place on the market.

The objectives of the PPWR and the polluter-pays principle are reasonable. Companies that place large quantities of packaging on the market should contribute to collection and recycling costs. However, the current cross-border EPR architecture is disproportionate for micro-enterprises and small online retailers and risks undermining the EU Single Market.

I own a small ceramic studio in Poland, and I am the only person working there. I send no more than 30 packages per year to different countries across Europe. It may not seem like much, but these sales are an essential part of my income. With this new regulation, it is becoming impossible for me to sell to customers in other European countries.

Ladies and gentlemen, we are a company with 10 employees which imports products and sells them under its own brand within the EU. In lengthy and burdensome tests, we have provided these products with various certificates from various laboratories and institutes in order to confirm quality, usability through compliance with European standards and much more.

Filed in German · English published by the European Commission

As small business I feel that the burden this law creates is too great compared to what I'd like to do which is occassional trading with goods that I purchase online. I see customers outside my country by I don't bother filing documents and paying fees and risking making a mistake somewhere which could lead to potential fines. I will just not sell abroad.

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

Filed in German · English published by the European Commission

As the owner of an artisan micro-enterprise based in the EU, I wish to express my deep concern regarding the disproportionate administrative and financial burden that the Packaging and Packaging Waste Regulation (PPWR) and Extended Producer Responsibility (EPR) schemes impose on small producers.

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

Filed in German · English published by the European Commission

Ladies and gentlemen, as a small organic farming and food business in Bavaria, we would like to draw your attention to one of our most critical points in the implementation of the PPWR: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Ladies and gentlemen, with whom the PPWR is interfering with the obligation to appoint an authorised representative for extended producer responsibility in the case of cross-border sales. For many SMEs, this is simply not economically feasible, so cross-border sales will be avoided. This runs counter to the idea of the EU single market.

Filed in German · English published by the European Commission

It is necessary to group the individual authorised representatives for each country and the individual licences. None of my colleagues can participate in a proper movement of goods in this way. This is where the major mail order companies, such as Amazon, etc., are given more. A united EU also requires a united movement of goods.

Filed in German · English published by the European Commission

Nexperia B.V. is a semiconductor manufacturer. Our packaging is industrial and goes into business-to-business channels. We support a single harmonised format. The points below are where the draft creates recurring work without better data. 1.

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

Filed in German · English published by the European Commission

In Germany, we operate the micro-enterprise RBcurrency Germany with two persons and sell collector banners exclusively to private end-users via our own online shop and marketplace. Our goods are small and light; as shipping packaging, we mainly use commercial paper envelopes.

Filed in German · English published by the European Commission

Ladies and gentlemen, I hereby lodge a formal complaint against the extended producer responsibility (EPR) scheme and the associated obligation to appoint national authorised representatives under the EU Packaging Regulation (PPWR).

Filed in German · English published by the European Commission

. Free model letter Dear Sir/Madam, as a small e-commerce operator, I would like to take this opportunity to draw your attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.

Filed in German · English published by the European Commission

Dear Sir or Madam, ​As the operator of a small e-commerce business, I would like to take this opportunity to highlight a point in the planned implementation of the PPWR producer registers that I consider particularly critical: the obligation to appoint an authorized representative for extended producer responsibility when selling cross-border.

Dear Sir/Madam, With the entry into force of the PPWR, I was forced to stop shipping throughout the EU and will now have a serious loss of turnover. I am solo self-employed and I can live on my income in this way. I cannot finance the funds for authorised representatives in several EU countries and the additional high fees for packaging licences. On the other hand, I depend on every euro of turnover.

Filed in German · English published by the European Commission

**Subject: PPWR Articles 44 and 45(3) per-Member-State registration and representative duties are pricing small sellers out of smaller EU markets** **Provision.** From 12 August 2026 Regulation (EU) 2025/40 applies in all 27 Member States.

Good afternoon, if that remains the case, it will be cheaper and easier for me to deliver only to Germany, the USA and Canada. I have a small business to deliver for the costs in each EU country.... For this I would work Jannuar and February Completely for free to pay the costs for the PPWR. mfg

Filed in German · English published by the European Commission

Ladies and gentlemen, as a small company with 18 employees, we would like to draw attention to a particularly problematic point in the implementation of the EU Packaging Regulation (PPWR): the obligation to appoint an authorised representative for the extended producer responsibility in case of deliveries to other EU Member States.

Filed in German · English published by the European Commission

Please can we find politicians that have at least a basic understanding of business? This will KILL innovation in Europe unless its harmonised to allow small business owners to at least ship with someone who takes care certifications across Europe, at a minimum?

Ladies and gentlemen, as the owner of a small German handmade company, I would like to address you, as I am directly concerned by the new requirements of the European Packaging Regulation and in particular the extended producer responsibility schemes for cross-border shipments. I operate a small online shop alone, through which I sell, package and ship self-sealed products.

Filed in German · English published by the European Commission

Hello, I am the manager of a French microenterprise created less than a year ago and I support the objectives of Regulation (EU) 2025/40. JAI also chose from the start of my activity to limit packaging as much as possible: my products do not have individual sales packaging and my shipping packaging is plastic free.

Filed in French · English published by the European Commission

Ladies and gentlemen, we are a small German publisher and, in addition to subscriptions to periodicals, we also send books and other publishing products directly to our customers. Until the entry into force of the new PPWR rules, this included customers and subscribers in different EU Member States. Since 12 August 2026, we have stopped shipping to the EU countries concerned.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

The objectives of the PPWR in terms of recyclability, resource conservation and more uniform regulation within the European Union are in principle understandable. However, concrete implementation poses significant problems, especially for small businesses.

Filed in German · English published by the European Commission

Subject: PPWR = Repealing the EU’s internal market Good day, we operate a small online shipment for party decorations and cladding. We only started to sell our own mail order a few years ago, but we have been aware of this business for many years, from another company. We know how important cross-border shipping is for the growth of a young business.

Filed in German · English published by the European Commission

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

Filed in German · English published by the European Commission

It is very difficult to remain civilised in the tone if I imagine that more than 30.000 bureaucrats with monthly salaries corresponding to my annual profit impose such regulations on us. I have disabled all EU Member States as sending destinations in my webshop. I am now sending only to non-EU countries. As a German company. Misrepresentation.

Filed in German · English published by the European Commission

As you know, from many other small business owners, these new rules are killing us. Some already have established costumers in other countries, others have plans to start to expand. But common for us all, we simply do not have funds to comply with the new rules. It's not that we don't want to, but we can't afford to.

I love the EU and I love the possibibilites all EU citizens have. But what you put up with PPWR is a full blown mess ️ As a small business owner (one-man show) who ships items within the EU it won't be possible for me to conform with the PPWR meaning I'd have to cancel all sales to other EU countries than my homecountry. It's a good thing to cope with too much waste and increase recycling within all EU states.

I am a micro-business in Malta selling greeting cards direct to consumers, posted in paper envelopes. Annual volumes are roughly 1000 orders in Malta and 10 cards to Ireland about 7 kg and 0.07 kg of packaging respectively. The tiering in Article 2(1)(b) and Annex II Part B is a genuine improvement. Four points where the draft could go further without any loss of data quality: 1.

Ladies and gentlemen, we would like to provide feedback on the extended producer responsibility requirements under the EU Batteries Regulation and the PPWR. As a German company, we supply, among other things, replacement batteries to commercial customers in other EU Member States, such as industrial companies, hospitals, fire brigades, police authorities and technical service providers.

Filed in German · English published by the European Commission

Europe promised a more unified market. Europe promised less bureaucracy and fewer regulations. Yet the reality increasingly appears to be the exact opposite. These EPR regulations risk becoming the death blow to free trade within Europe for many small e-commerce businesses.

Our French micro-business (4 employees) sells dust cyclone filters across Europe via an online store. While we support the EUs sustainability goals, the EPR and PPWR requirements impose unsustainable costs on small businesses like ours, threatening our ability to trade across borders.

Ladies and gentlemen, I am an optician and craftsman with a small shop and my customers are mainly nearby. However, most of my product comes from other European countries, mainly from small spectacle manufacturers and manufacturers. Their products are usually preferable to larger manufacturers in terms of sustainability and durability.

Filed in German · English published by the European Commission