Help for Fellow Small Businesses: PPWR 12 August 2026

August 10, 2026

UPDATES:

14 August 2026

The EU Commission has taken notice and replied online. They are recommending no fines and revised rules for micro-enterprises. However, they do not have legally-binding powers. The EU will be reviewing the PPWR in October, so keep giving feedback to make sure our voices are heard.
France has delayed requirements to participate in the EPR Scheme. Source: https://www.cleolabs.co/en/blog/france-professional-packaging-epr-2026
Another important way for your voice to be heard:
ECA (European Crafts Alliance) - they need data from creators & sellers

The European Crafts Alliance (ECA) is currently gathering information from creators and small businesses to draft lobbying documents for this autumn. They need specific operational statistics and personal stories directly from small makers and sellers to present a strong case in Brussels on behalf of small businesses.

Note: This survey is intended only for small business owners, micro-creators and sellers impacted by these regulations (not for general supporters)

Please, take a moment to fill out their official survey here:

https://docs.google.com/forms/d/e/1FAIpQLSd4UEfB0FpPbw1zetViYlj6b1PbShUNl6OC5e9NV1Ki8Rwnzg/viewform

----

Disclaimer: I am but an overwhelmed micro-enterprise like yourself. One woman, many hats, and a day of reading VERY boring and confusing documentation. I have cited sources wherever possible but do not pretend to offer legal advice of any kind. Aka you are responsible for your own decisions an don’t be trying to sue me. Okay? Thanks.

Also – if you find that something is incorrect and can provide a source to back that up, PLEASE share it with me. I always want to provide the most accurate info possible.

LONG STORY SHORT

The EU revamped its requirements regarding sustainability in packaging in February 2025.

18 months later, they come into full effect – 12 August 2026.

(So no, this actually hasn’t come out of nowhere even though it very much feels like it. It is just impossible to keep on top of everything when you wear many hats)

KEY TERMS

Just a head’s up that the legislation’s use/ definitions of Supplier vs Manufacturer vs. Producer are mind-boggling. In most cases with any form of e-commerce, you are going to be the responsible party is the main takeaway.

PPWR = Packaging and Packaging Waste Regulation. Legislation that narrows the definition of packaging waste as previously outlined in the PPWD (Packaging and Packaging Waste Directive) and provides a plan and goals for excluding harmful chemicals and heavy metals in packaging, prioritising reusable/refillable options, and making it easier for customers to understand how to best dispose of or recycle packaging at its end life through a harmonised system of labelling.

EPR = Extended Producer Responsibility. This is the scheme that helps enact the EU’s philosophy that the person/company responsible for putting waste into the EU market is responsible for helping manage it (the polluter pays). Basically, based on the amount and type of waste that ends up in an EU member state that can be traced back to you, different fees apply. Those fees are then used to help collect and properly treat, dispose of, or recycle the waste. More on this later.

PRO = Producer Responsibility Organisation. Companies supplying packaging (including product packaging) must report and contribute financially to the collection and recycling of their packaging waste. Doing so generally requires that you register with a Producer Responsibility Organisation (PRO) in each EU member state where you supply products. PPWR Article 45 (2)

In practice, this means that you pay a fee to a PRO, which in turn collects, disposes of, and recycles your packaging. PROs can also help you to comply with registration, reporting, and other requirements. Source: https://www.compliancegate.com/epr-organisations-european-union/

MICRO-ENTERPRISE = Defined as an enterprise which employs fewer than 10 persons and whose annual turnover and/or annual balance sheet total does not exceed EUR 2 million. Source: https://eur-lex.europa.eu/eli/reco/2003/361/oj/eng

PRODUCER: If the manufacturer of the (empty) packaging or the packaged product is based in the same country as the packages final destination, he is deemed to be the producer - because there is no one before him in the supply chain. If the manufacturer is based abroad, but another company in the EU country where it will become waste handles/imports the packaging, it is deemed to be the producer. Only if a delivery from abroad is made directly to a private or commercial end user is the foreign company considered to be the producer (The case with most ecommerce). Source: https://www.eunr.org/fileadmin/user_upload/Publications/202606_Producer_Definition_EUNR.pdf

THE MOST URGENT STUFF TO KNOW

This does apply to Sole Traders. The EU’s definition of an enterprise is as follows:

An enterprise is considered to be any entity engaged in an economic activity, irrespective of its legal form. This includes, in particular, self-employed persons and family businesses engaged in craft or other activities, and partnerships or associations regularly engaged in an economic activity. Source: https://eur-lex.europa.eu/eli/reco/2003/361/oj/eng

In the PPWR documentation, a sole-trader would fall under the micro-enterprise clause.

This does apply to EU Member States as well as anyone outside the EU shipping into the EU Market.

Even EU member states have to register with any other EU member states into which they want to ship goods.

If you are shipping TO Northern Ireland, according to Daera and the Windsor Framework, the following parts of PPWR do and don’t apply:

Applicable to NI	Not applicable to NI
Recyclability of packaging	Re-use and refill targets
Labelling	EPR & DRS obligations
Restrictions on single-use packaging	Recycling targets

Source: https://www.daera-ni.gov.uk/articles/packaging-and-packaging-waste & https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:C_202500946

Documentation Requirements: EU Declaration of Conformity & Technical Documentation

Part of the legislation is having documents you can provide, if audited, demonstrating the composition and sustainability of your packaging. There is a requirement for the company’s making packaging to supply this information to their customers so there is traceability through the entire supply chain. Source: Manufacturers shall, upon a reasoned request from a national authority, provide all the information and documentation necessary to demonstrate the conformity of the packaging with the requirements laid down in or pursuant to Articles 5 to 12, including the technical documentation, in one or more languages which can be easily understood by that authority. That information and documentation shall be provided in electronic form and, on request, in paper form. The relevant documents shall be made available within 10 days of receipt of the request from the national authority. Manufacturers shall cooperate with the national authority on any action taken to remedy any case of non-compliance with the requirements laid down in or pursuant to Articles 5 to 12 Source: PPWR Article 15 (10)

Suppliers shall provide the manufacturer with all the information and documentation necessary for the manufacturer to demonstrate the conformity of the packaging and the packaging materials with this Regulation, including the technical documentation referred to in Annex VII and required under or pursuant to Articles 5 to 11, in one or more languages which can be easily understood by the manufacturer. That information and documentation shall be provided in either paper or electronic form. PPWR Article 16 (1)

Not Every Part of the Legislation is Enforceable Right Now

There are different goals and a timeline framework for meeting them within the PPWR. As of 12 August 2026, what is most pertinent is having to register with each EU market into which you are selling.

What’s Good About this Legislation

During a time when people and the planet are actively suffering due to overconsumption and poor material choices, the EU is actually making moves to change that. This is in conjunction with other legislation regarding textile waste, mass-imports of low-value tat, and shipping waste overseas.

What Sucks About this Legislation

- They haven’t delineated between companies of different sizes. While micro-enterprises don’t have to follow some of the requirements that come into effect in the future, they do still have to follow the EPR (Extended Producer Responsibility) guidelines which involves registering, tracking your packaging, and submitting reports.

- There are plans / requirements for a single registration system in the future. But it doesn’t exist yet. This means that right now, the EPR scheme looks like this:

1) Go to each EU Member State and register with that state’s designated authority. Producers cannot put packaging or packaged products on the territory of a Member State they are not registered with, as per Article 44 (4)

2) Some countries have a threshold/ de minimis which if you fall under, you don’t pay any waste management fees. Others don’t and it is at the discretion of each member state whether they require you to sign up with a PRO (Producer Responsibility Organisation) for tracking, reporting, and waste management fees. Source: Producers may entrust a producer responsibility organisation authorised in accordance with Article 47 with carrying out the extended producer responsibility obligations on their behalf. Member States may adopt measures to make entrusting the extended producer responsibility obligations to a producer responsibility organisation mandatory Article 46 (1) PPWR

3) You must have an authorised representative in each EU member state into which you’ll ship, even if you are in the EU / NI. Source: On the other hand, when the packaging or the packaged product is made available by means of distance contracts directly to the end user, the producer could also be established in another Member State or in a third country. In such cases, if the producer is established in another Member State, it should appoint an authorised representative for the extended producer responsibility in the Member State where the end user is located. In cases where the producer is established in a third country, it should also be possible for Member States to provide that the appointment of an authorised representative for the extended producer responsibility be mandatory in order to avoid the risk of eluding the extended producer responsibility obligations. PPWR PAGE 21 (123)

SO WHAT DO I DO????

FIRSTLY!

There is a petition and an official European Commission Consultation which you can sign/ give feedback on and hopefully we can get them to give the micro-enterprises a break.

Change.Org Petition: https://www.change.org/p/stop-destroying-eu-micro-businesses-immediate-moratorium-on-cross-border-epr-fees?sign_confirm_error=failed_token

Official EC Consultation ONLY OPEN UNTIL THE 10TH SEPTEMBER https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/15352-Packaging-and-packaging-waste-rules-on-national-registers-of-producers_en

SHARE SHARE SHARE these two actions wide and far. We need to make it abundantly clear how damaging the current infrastructure is micro and small businesses.

SECONDLY

My plan of attack would be:

Suspend all sales to the EU while you research.
Look at what EU states you get the most sales from.
- If you are on a platform like Shopify, Squarespace, Etsy, etc. you should be able to easily pull this data from your system.
Look into what each of those EU states requirements are regarding PPWR/EPR.
- Is there a cost to register with the government entity?
- Is there a de minimis threshold for paying waste management fees?
- Is it required to register with a PRO?
- Cost of an Authorised Representative for that member state.

Depending on the amount of sales you get on average from that member state and their requirements/costs, it may be worth it to register with them.

There are also third party companies who may help handle all of the registration and reporting and act as an authorised representative. Global Trade Department has been an amazing resource of information for micro and small enterprises during the many challenges we have faced in the past few years (Brexit, Windsor Framework, Customs/VAT changes, GPSR and now this) and offer some free consultations. They are developing a platform to help with the PPWR documentation, registrations, and reporting. I have enquired if it is ready yet and will update this page with more information once I receive it.

It is also worth mentioning that there are potentially millions of customers available to you in your own country. You may have to start some more targeted marketing campaigns, networking locally, and focusing on local custom. We are very used to globalised markets now...but it is really only a recent development. (Sorry – really trying to find ANY positives that I can here. Ugh).

If this has been helpful at all and you are in position to do so, feel free to buy me a coffee. I need one after 9 hours straight staring at this stuff LOL. But absolutely no pressure or shame if you can't! x Dee

https://buymeacoffee.com/quirkybutfierce

SOURCES:

(PPWR) REGULATION (EU) 2025/40 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202500040

GLOBAL TRADE DEPARTMENT

Videos:

Understanding the new EU Packaging and Packaging Waste Regulation (PPWR)

https://youtu.be/NxxI64Js-xg?si=raPbCwDy3qeJ2tNf

Update on the new EU Packaging and Packaging Waste Regulation PPWR - 10th June 2026

https://youtu.be/OXipBIVTFMg?si=nrV8USsKQ-h4kWFM

Update on EU Extended Producer Responsibility - 20th May 2026

https://youtu.be/Td_or35HV_E?si=CoAVWISQYArgHY6z

Website: https://www.globaltradedept.com/

Email: contact@globaltradedept.com

RESURGANCE – Provides some information on the EPR requirements for some of the EU Member State that have their scheme established already.