Just weeks into the application of the EU Packaging and Packaging Waste Regulation, a growing campaign by European micro-businesses is exposing one of the PPWR’s most sensitive implementation issues: how to strengthen producer responsibility without making cross-border trade disproportionately complex and expensive for the smallest companies.
The Packaging and Packaging Waste Regulation was designed in part to reduce fragmentation across the European packaging market, yet one of its first major implementation controversies is emerging around fragmentation itself. A Change.org petition launched on 6 August 2026 and linked to the newly created European Micro Enterprises Movement has already attracted more than 78,000 verified signatures, calling for a moratorium on certain cross-border Extended Producer Responsibility requirements for micro-businesses.
The campaign does not primarily challenge the environmental objectives of the PPWR or the polluter-pays principle. Instead, it targets the administrative and financial burden created when very small businesses sell packaged products across several EU markets, potentially facing different registrations, producer responsibility organisations, reporting procedures and compliance costs in each country.
Why Cross-Border EPR Is Becoming a PPWR Flashpoint
Under the PPWR, producers must register in every Member State where they make packaging or packaged products available for the first time. Businesses selling directly to end users in another Member State are also required, under the current rules, to appoint an authorised representative for Extended Producer Responsibility in that market.
For large companies distributing millions of products, these fixed administrative costs can be absorbed across substantial sales volumes. For an independent brand, artisan or small online retailer sending only a limited number of parcels to several European countries, however, the same compliance structure can become disproportionately expensive.
The PPWR already provides some simplification for smaller producers, including reduced reporting requirements below certain packaging volumes, but it does not establish a general EU-wide exemption from producer registration for micro-enterprises. This is precisely where the current debate is concentrating: not on whether small businesses should contribute to packaging waste management, but on whether the compliance model is proportionate to the amount of packaging they actually place on each market.
Thousands of Businesses Are Asking Brussels for Change
The petition is only one sign of growing concern. Euractiv reported that the European Commission’s consultation on PPWR producer registration and EPR reporting received more than 5,000 responses within its first two weeks, many of them linked to the challenges faced by smaller cross-border sellers.
Campaigners are asking for an EU-wide de minimis threshold, temporary relief from certain registration and enforcement obligations and, in the longer term, a genuine European one-stop-shop that would allow businesses to manage EPR through a central system instead of navigating multiple national structures.
This distinction is important. Despite the strong language surrounding the campaign, the issue is not simply whether the PPWR should be stopped. The more fundamental question is whether Europe can maintain ambitious packaging-waste rules while preventing compliance costs from becoming a practical barrier to the Single Market.
The Commission Has Already Recognised Part of the Problem
The controversy also comes at a time when the European Commission has already acknowledged that some cross-border EPR obligations may be unnecessarily burdensome. In December 2025, the Commission proposed suspending until 2035 the requirement for EU-based producers selling into other Member States to appoint separate authorised representatives for EPR.
The proposal has not yet completed the legislative process, but it shows that concerns over administrative proportionality are not limited to the businesses behind the petition. Even if the authorised representative obligation is eventually suspended, however, companies operating across several countries would still have to deal with national registrations, reporting systems and producer responsibility structures.
This is why the debate is increasingly moving beyond a single PPWR provision towards a broader question about the architecture of European EPR.
One PPWR, but Still Many National Systems
The underlying tension is straightforward. The PPWR aims to create a more harmonised European packaging framework, but Extended Producer Responsibility continues to be implemented largely through national systems.
A business selling across the EU can therefore comply with one European regulation while still interacting with multiple authorities and schemes. Harmonised legislation does not automatically create a harmonised compliance experience, particularly for companies without dedicated legal or regulatory teams.
Other industry voices are therefore calling for simplification rather than deregulation. Germany’s Circular Valley Foundation, for example, has highlighted the burden that different registrations and administrative requirements can create for SMEs while continuing to support the environmental ambitions of the PPWR.
That may be the most constructive way to frame the current controversy: the choice is not necessarily between environmental protection and small businesses. The challenge is to ensure that environmental obligations remain ambitious while the processes used to administer them become simpler, more consistent and more proportionate.
A First Major Test for PPWR Implementation
The backlash from micro-businesses may be an early indication of the challenges Europe will face as the PPWR moves from legislation into practical implementation. The Regulation covers everything from recyclability and recycled content to reuse, labelling, packaging minimisation and producer responsibility, while many technical details will continue to be defined through secondary legislation.
For cross-border EPR, the risk is particularly sensitive. If administrative costs become high enough that small businesses decide to stop selling into certain Member States, stronger packaging accountability could unintentionally create new barriers within the European Single Market.
The coming months will therefore be important. The Commission will need to assess the unusually high level of stakeholder feedback, while Parliament and Council continue examining proposed changes to the authorised representative requirement. Discussions around de minimis thresholds, simplified regimes and a possible European EPR one-stop-shop are also likely to gain momentum.
The controversy does not necessarily suggest that the PPWR’s environmental ambitions are too high. Instead, it highlights a different challenge: if Extended Producer Responsibility is to work across Europe, responsibility must not only be effective, but proportionate and workable for companies of every size.
