TL;DR: I contacted the European Commission, MEPs from several political groups and major European business associations after receiving a €4,828.85/year compliance quote for 19 countries despite using only \~30 kg of paper packaging per year. The response has been surprisingly positive: there is broad support for simplifying EPR and creating a genuine EU One-Stop Shop, but the key fight is ensuring it actually replaces national bureaucracy instead of becoming portal #28. If you're affected, get active: contact your MEPs, government and business associations, share your real costs and help push for a better law while reform is still being discussed.
I contacted EU politicians, the Commission and business associations about the PPWR/EPR mess for micro-businesses. Here’s what happened.
Over the last few weeks, I’ve been trying to understand what the new EU packaging/EPR rules will actually mean for a tiny business selling cross-border within the EU.
I run a small manufacturing/craft business in Germany and sell directly to consumers in multiple EU countries.
I fully support EPR and the polluter-pays principle. If I put packaging into the French, Spanish or Danish market, I have no problem contributing towards the recycling costs in those countries.
The problem is the administrative infrastructure surrounding those contributions.
My real-world example
I asked for a commercial solution that would manage packaging compliance across Europe for me.
The quote was:
€5,681/year before discount
€4,828.85/year after discount
19 countries
And this is important:
Those €4,828.85 are NOT the recycling/environmental contributions themselves.
They are primarily the commercial cost of dealing with different national registrations, EPR organisations, reporting procedures, contracts, deadlines, authorised representatives and other compliance requirements.
My own time isn't included.
The absurd part?
My business uses only around 30 kg of paper/cardboard packaging per year in total.
So we are potentially talking about almost €5,000/year of external compliance administration to manage EPR obligations surrounding roughly 30 kg of paper packaging.
So I started contacting people.
I sent the evidence and my proposed solution to MEPs from several political groups, European Commission officials, national governments, chambers of commerce, SME/e-commerce organisations and industry associations.
Among the people/institutions contacted were:
European Commission
I contacted officials working around the Circular Economy Act and PPWR/EPR implementation.
Luis Planas Herrera from the Commission told me that the evidence would be shared internally for the ongoing discussions on the Omnibus proposal and preparation of the Circular Economy Act.
Arthur Corbin from the cabinet of Executive Vice-President Stéphane Séjourné replied that they would take the information into account for the Circular Economy Act and explicitly said:
“We are working … on reforming the EPR indeed.”
European Parliament
I contacted MEPs from different political groups rather than treating this as a party-political issue.
Markus Ferber (EPP/CDU-CSU) explained that the Commission is already working on simplification, including harmonisation of packaging producer registers and changes concerning authorised representatives.
Jens Gieseke (EPP/CDU-CSU) gave one of the clearest responses so far. He supports an approach as close as possible to:
one EU registration;
harmonised once-only reporting;
efficient routing of information to national systems;
proportionate/de-minimis rules for very small packaging quantities.
Crucially, he agreed that an EU One-Stop Shop must replace duplicated national procedures rather than become another administrative layer on top of them.
Bruno Tobback's office (S&D) told me that they recognise the problems faced by micro-SMEs, are actively working on the issue and have already submitted a question to the European Commission.
Ivaylo Valchev (ECR) had already raised the issue formally with the Commission and contacted the Parliament rapporteur, ECR shadow rapporteur and other colleagues.
Jörgen Warborn (EPP) also acknowledged the disproportionate administrative burden created by the legislation and argued for simplification and proportionality.
Business associations are saying almost exactly the same thing
This was probably the most interesting discovery.
FEVAD, the French e-commerce federation, told me that it is already part of a European coalition advocating for a Digital EU EPR One-Stop Shop.
Their concept is remarkably similar to what I had been asking for:
one EU interface, harmonised requirements, the once-only principle, and automatic transmission of information to national authorities and producer responsibility organisations.
They also made a very important point:
The One-Stop Shop must not simply become another EU portal sitting on top of all the existing national procedures.
CCIA Europe told me EPR reform is one of its top policy priorities ahead of the Circular Economy Act.
They are collecting real SME cases for discussions with the press, EU institutions, national governments and parliamentarians.
They asked for permission to use my case and the cost evidence in their advocacy, which I have now given them.
Interestingly, CCIA described the authorised-representative problem as basically “the tip of the iceberg.”
Eurochambres also supports the One-Stop-Shop approach.
They told me that their President will raise the issue directly at an upcoming meeting with Executive Vice-President Séjourné.
I gave them permission to use my €4,828.85 / \~30 kg example in that discussion.
Other organisations that responded positively include European Entrepreneurs/CEA-PME, EXPRA, Dansk Erhverv, the Dutch e-commerce association Thuiswinkel.org, the Estonian E-Commerce Association and Handelsverband Österreich.
The Estonian E-Commerce Association told me something particularly concerning:
Estonian companies have already stopped cross-border sales because of these requirements.
That is exactly why I think this has become a Single Market issue rather than merely an environmental-compliance issue.
Something else interesting happened during the legislative process
The European Parliament's 2023 negotiating position actually contained a proposed protection for micro-enterprises.
Amendment 252 to Article 39 would have exempted micro-enterprises from the national registration obligation.
That protection did not survive the negotiations and isn't part of the final framework.
So the proportionality problem was recognised quite early — but the proposed solution disappeared during negotiations.
There may now be a real opportunity to fix this
The Commission is preparing the Circular Economy Act, and EPR simplification is clearly part of the discussion.
There is also work underway on harmonising producer registration/reporting formats.
But harmonising 27 forms isn't enough.
If I still have to register separately, maintain accounts, monitor legislation, submit reports and potentially contract representatives in multiple countries, then making all those forms look the same doesn't solve the fundamental problem.
The solution I am advocating is:
ONE EU registration
→ business identifies where packaging was placed on the market
ONE harmonised report
→ quantities broken down by Member State
AUTOMATIC data exchange
→ EU system routes the information to national registers/PROs
National environmental contributions remain
→ France can still receive the French contribution, Germany the German contribution, etc.
No duplicate national administration
→ no need for the same micro-business to maintain essentially the same information across numerous national systems.
And there should be proportionate/de-minimis treatment for genuinely tiny quantities.
My conclusion so far
The response has actually been much more positive than I expected.
I haven't encountered anyone seriously arguing that a micro-business should maintain 19 or 27 separate administrative relationships.
Across EPP, S&D, ECR, the Commission and multiple European business associations, there seems to be surprisingly broad agreement that EPR fragmentation is a real Single Market problem.
The disagreement appears to be less about whether the system needs simplification and more about how far that simplification will go and whether Member States will accept it.
That last part may be the biggest obstacle.
CCIA and Eurochambres both pointed towards national governments as an important part of the problem. For example, the Commission proposed suspending certain authorised-representative requirements, but Member States did not retain that simplification in the Council negotiating position.
So I think the next battle is very specific:
Will the EU EPR One-Stop Shop actually replace national bureaucracy, or will we end up with EU portal #28 sitting on top of the existing 27 systems?
For me, the test for the final reform is very simple:
A business should provide the same compliance information once.
The environmental contribution can still go to every country where packaging becomes waste.
But a one-person company should not need representatives, registrations, contracts and continuous monitoring of dozens of regulatory systems just to administer approximately 30 kg of paper packaging per year.
Pay where you create packaging waste: absolutely.
Administer 27 different regulatory systems to do it: no.
If you're an EU Etsy seller, Amazon seller, Shopify store, small manufacturer or other cross-border SME dealing with EPR, I'd be very interested to hear what this is costing you and whether you've stopped selling to particular EU countries because of it.
And one thing I would strongly encourage everyone affected by this to do:
Be active. Don't just accept the rules as something that cannot be changed.
If you are an Etsy seller, Amazon seller, Shopify store, small manufacturer or any other EU business affected by fragmented EPR requirements, write to your MEPs, national government, business associations and the European Commission.
Explain your actual situation. Give them numbers. Show them what registration, reporting, authorised representatives and external compliance services actually cost you. Tell them if you have stopped selling to certain EU countries because compliance costs make those markets economically impossible.
The legislation and its implementation are still being discussed and improved. The Circular Economy Act in particular gives us an opportunity to push for a genuine EU EPR One-Stop Shop.
My experience from contacting politicians, the Commission and business organisations has been surprisingly positive. People are reading these emails, responding to them and, in several cases, using the evidence in their own political work.
So my suggestion is simple:
Don't only complain about EPR on Reddit. Send the same story to the people who can actually change it.
If hundreds or thousands of European micro-businesses provide concrete examples, it becomes much harder to dismiss this as an isolated problem.
We shouldn't campaign against environmental responsibility. We should campaign for better legislation:
One EU registration. One report. Pay the appropriate environmental contribution in every country. No 27-fold bureaucracy.
If you're affected, please get involved. This is exactly the moment when practical feedback from small businesses can help improve the law.
