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PPWR

EPR for packaging: moving towards simpler obligations for small businesses

October 15, 2026

Ferdinand Hodler, Public domain, via Wikimedia Commons

Two months after the PPWR became applicable, the European Commission published a guidance page on the extended producer responsibility (EPR) obligations of small businesses. Like its FAQ and Guidance Document, this guidance page is not legally binding. It does, however, show how the Commission intends the Regulation to be applied to operators that place only small volumes of packaging on the market.

Key points

  • Small producers (less than 10 tonnes of packaging per year) may benefit from relief measures, set at national level.
  • Existing national EPR registration rules continue to apply until the harmonised registers are in place.
  • The obligation to appoint an authorised representative has applied since August 2026, but the Commission has proposed suspending it for small businesses.
  • Online platforms are not yet required to ask for an EPR registration number.

I. Background

EPR requires businesses that place packaged products on the market to help finance the collection and recycling of that packaging. Like the Directive before it, the PPWR already provides that Member States and producer responsibility organisations (PROs) must not place a disproportionate burden on low-volume producers.

II. Special conditions to check country by country

Member States and PROs may, in particular:

  • exempt small producers from administrative fees (such as registration fees) or set flat-rate, proportionate contributions;
  • simplify procedures: exemption from updating information, fast-track procedures, help desks;
  • reduce record-keeping requirements and limit checks and audits.

These measures are not automatic. They depend on each Member State and each EPR scheme.

The Regulation on Packaging and Packaging Waste (PPWR) provides for certain exemptions for producers who place less than 10 tonnes of packaging on the market per calendar year, particularly with regard to reporting to the producers’ register.

III. Registration is still mandatory

Businesses must continue to comply with the registration rules of the country where their packaging becomes waste. The Commission will adopt uniform EU rules on registration and reporting. Member States will then have 18 months to adapt their registers, or to create one if none exists. Data formats and reporting obligations will then be aligned across the European Union.

IV. The authorised representative obligation on hold

Since August 2026, appointing an authorised representative in order to sell in another Member State has been required throughout the EU. The Commission has proposed suspending this obligation for small businesses. Pending a decision by the Council and the European Parliament, it is asking Member States to show flexibility and not to impose penalties.

V. Online platforms

For now, marketplaces do not have to request an EPR registration number. They will, however, once the harmonised national registers are up and running.

This article does not constitute legal advice and cannot be a substitute for a legal analysis adapted to the specific situation of your company.

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