Key provisions of the new Packaging and Packaging Waste Regulation (PPWR) have been in effect across the European Union since August 12. While the regulation aims to reduce packaging waste and harmonize the internal market, small retailers in particular are facing difficulties due to additional obligations associated with shipping within the EU. Depending on the specific circumstances, they must comply with national registration and disposal requirements and appoint an authorized representative in the destination country. This creates fixed costs that are rarely justifiable for low shipment volumes, prompting some smaller companies to scale back their international shipping operations. Notably, however, the EU Commission itself intends to suspend a key provision and is advising authorities to adopt a lenient approach to enforcement for the time being.
Packaging regulation aims to simplify matters – but creates new hurdles
The regulation’s objective seems reasonable at first glance. In the EU, packaging waste amounts to around 178 kilograms per person annually, while Germany’s figure is as high as approximately 215 kilograms. Consequently, the aim is to reduce packaging, improve recycling rates, and increase reuse. At the same time, however, Brussels promised greater consistency for businesses—a promise that is already faltering right from the start.
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After all, there is still no single European packaging register. Consequently, retailers must comply with different national systems depending on the destination country. In addition, Article 45(3) requires the appointment of an authorized representative for extended producer responsibility under certain conditions. The Händlerbund estimates the associated costs at several hundred euros per country, per year. While large platforms can manage this, small retailers feel the impact of such fixed costs much more acutely.
Small retailers are already withdrawing from EU markets
The consequences are now becoming apparent in practice. Small booksellers, beekeepers, breweries, and specialized online shops are evaluating whether individual EU markets remain profitable. As a result, some businesses are halting shipments to specific countries or limiting their operations entirely to Germany. Honigmanufaktur Eggers, based in Lower Saxony, is among the companies that have suspended shipping to the EU for the time being. For consumers, this means a shrinking range of products available from small foreign vendors.
Particularly striking, however, is the fact that the packaging regulation had not yet fully come into effect when the Commission already sought to roll back a key requirement. As early as December 10, 2025, Brussels proposed suspending Article 45(3) until the beginning of 2035. The Commission cited, among other reasons, the unnecessary administrative burden placed on cross-border trade. In doing so, it acknowledged—months before the rules were set to take effect—that a portion of its own regulation risked hindering rather than facilitating the Single Market.
Brussels acknowledges the error—yet the rule remains in force
The correction was not finalized in time. Since both the European Parliament and member states must approve any amendment, the rule in question remains in effect for the time being. Even just before the regulation was set to take effect, the Commission publicly reaffirmed its desire to suspend it. Companies are thus expected to comply with a rule that its own architects already deem in need of reform. This is hardly what a well-prepared regulation looks like.
The situation becomes even more contradictory regarding enforcement. According to the Händlerbund (a major German online retailers’ association), the Commission has recommended that national authorities refrain from imposing sanctions for violations initially, focusing instead on issuing warnings. This creates a remarkable scenario: the law is in force, yet Brussels wants to defuse key parts of it as quickly as possible. For businesses, this generates not legal certainty, but rather additional uncertainty.
Packaging regulation launches with a built-in need for fixes
The German Retail Federation (HDE) has also criticized the implementation with unusual severity. HDE Chief Executive Stefan Genth stated: “Companies must not be made to suffer the consequences of a regulation botched by the EU Commission.” The association also complains of unclear areas of responsibility and unresolved obligations. When even guidelines and repeatedly revised FAQs fail to provide clarity on application, the problem does not lie solely with the companies.
The packaging regulation was intended to harmonize bureaucracy and facilitate European trade. Instead, it is launching with added costs, divergent national approaches, and a central requirement that Brussels already intends to suspend. Consequently, small retailers are withdrawing from certain markets, while consumers may face a more limited range of choices. Above all, this episode demonstrates one thing: a regulation requiring repair immediately after its launch was clearly not fully thought through.
Author: Blackout News
Sources: Welt (13.08.26) – Händlerbund (12.08.26) – Europäische Kommission (11.08.26) – Handelsverband Deutschland (11.08.26)