Germany Proposes Simplifying PPWR Obligations for Small Businesses
Germany has raised the need to introduce certain simplification measures under Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), particularly in relation to extended producer responsibility obligations and cross-border sales.
The PPWR has applied generally since 12 August 2026 and establishes a harmonised framework aimed at reducing packaging waste, improving recyclability and supporting the transition towards a more circular economy across the European Union.
However, some of its obligations may create a significant administrative burden for businesses placing packaged products on the market in several Member States.
The authorised representative requirement is a key concern
One of the areas creating practical difficulties concerns companies selling packaged products directly to end users located in other EU Member States.
The PPWR provides for the appointment of an authorised representative for extended producer responsibility purposes, established in the relevant Member State.
In practice, this may mean that a company selling directly into several EU markets needs to manage EPR-related obligations and local representation separately in each country.
For small operators or businesses making relatively limited cross-border sales, the associated administrative and financial burden may be disproportionate to the actual volume of packaging placed on the market.
Germany is therefore supporting the introduction of a possible exemption for certain operators placing less than 10 tonnes of packaging per year on the market.
The 10-tonne threshold is not entirely new within the PPWR framework. Article 44 already provides for simplified reporting arrangements for certain producers placing less than 10 tonnes of packaging on the market during a calendar year.
Particular relevance for cross-border e-commerce
The issue is especially relevant for cross-border e-commerce.
A company established in one Member State may sell relatively small quantities of packaged products directly to consumers or other end users across multiple EU countries.
Where registration, EPR participation and local representation requirements apply separately in each jurisdiction, a relatively modest level of commercial activity can result in a complex and costly compliance structure.
Germany’s proposal is therefore aimed at introducing greater proportionality between the volume of packaging placed on the market and the administrative requirements imposed on businesses.
Germany is also calling for changes to the registration framework
Another area currently under discussion concerns the future registration system for producers.
Article 44 of the PPWR establishes specific registration and reporting obligations. The Regulation also requires these systems to operate electronically and seeks to improve interoperability and data exchange between national systems.
Germany is calling for additional time before certain new registration obligations become fully operational, with the aim of allowing progress towards a more centralised European solution and avoiding unnecessary duplication of national procedures.
This debate also forms part of a broader EU discussion on the simplification of extended producer responsibility obligations, an area in which further legislative developments are expected.
Does this mean that the current obligations no longer apply?
No.
This is one of the most important points for businesses to understand.
The measures proposed by Germany do not amend the PPWR by themselves. Any change to the Regulation would need to be adopted through the appropriate EU legislative procedure.
Companies should therefore continue assessing their obligations under the current PPWR framework and under the applicable national extended producer responsibility rules in each market where their products are placed on the market.
What should companies do now?
The current debate confirms that the practical implementation of the PPWR is still evolving.
Companies placing packaged products on the market in several Member States should continue collecting detailed packaging information, identifying their producer responsibilities and preparing the documentation required to demonstrate compliance.
At the same time, businesses should closely monitor future simplification initiatives that may affect registration, authorised representative and extended producer responsibility obligations.
At Belab Services, we will continue monitoring regulatory developments under the PPWR and any future amendments that may affect companies placing packaged products on the EU market.
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