As shared in previous feedback rounds for PPWR, we see huge problems for SME's and the EU single market with PPWR. The following measures should be taken to minimize these issues: 1) Any business should be able to register directly with procuder registers and be able to submit their declarations directly, without an Authorized Representative in between. 2) Excemptions for SMEs, e.g.
EG
ecosistant GmbH
Company · Germany
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
2
positions filed
in the 663 files tracked
2
legislative files
of 663 tracked
0
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 663 consultation files tracked so far (57,738 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
ecosistant GmbH filed 2 positions between 9 Dec 2022 and 10 Sept 2026, across 2 of the 663 legislative files tracked here.
2022 · 1 filed2026 · 1 filed
What they argued
At ecosistant, we welcome the approach of the European Commission for harmonization of packaging waste EPR, packaging labels for recycling, and packaging/recycling standards. However, although the Commission aims for specific treatment of SME`s and micro-enterprises to ensure that the impacts on them are proportionate, we fear that the current proposal will further increase the burden on SMEs and make it impossible…
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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