Make PPWR Work for European SMEs

Make PPWR Work for European SMEs and the EU Single Market

We, the undersigned European businesses, entrepreneurs and stakeholders, respectfully ask the European Parliament to examine the practical impact of Regulation (EU) 2025/40 (PPWR) on SMEs engaged in cross-border trade.

We fully support the environmental objectives of PPWR: reducing packaging waste, improving recyclability, increasing resource efficiency and applying the polluter-pays principle.

Our concern is not the environmental objective, but the administrative and financial burden created by fragmented national EPR systems.

A business selling the same compliant packaged product in several EU Member States may face different national registration systems, reporting requirements, fees, compliance organisations and representative requirements.

This creates a practical contradiction:

One EU product + one EU packaging framework = multiple national administrative systems. For large multinational companies this may be manageable. For SMEs and micro-enterprises, the cumulative cost and complexity can become disproportionate and may discourage cross-border expansion.

We therefore ask the EU to ensure that PPWR strengthens rather than undermines the Single Market and the free movement of goods.

We call for:
1. ONE FREE EU PACKAGING EPR PLATFORM
Create one official EU digital platform through which businesses can complete all mandatory packaging EPR registrations, declarations and reporting.
2. ONE DATA SUBMISSION
Businesses should enter their packaging information once, rather than repeatedly into different national systems. The platform should electronically transmit the relevant information to national authorities or EPR systems.
3. NO MANDATORY PRIVATE INTERMEDIARY
Businesses should always have the option to comply directly through the free official EU platform. Private compliance providers may offer additional services voluntarily, but SMEs should not have to pay substantial private fees simply to fulfil mandatory regulatory declarations.
4. CLEAR CROSS-BORDER RESPONSIBILITY
Where an independent distributor imports and first places packaged products on a national market, that distributor should normally bear the corresponding national EPR registration, reporting and financial obligations.
5. PROPORTIONALITY FOR SMEs
Introduce simplified registration, reporting, thresholds and fees for SMEs and micro-enterprises, proportionate to the amount of packaging placed on the market.
6. ONE OFFICIAL EU DATABASE
Until full harmonisation is achieved, provide one official database showing the EPR requirements, registration obligations, deadlines, fees and responsible parties in every Member State.
7. PROTECT THE SINGLE MARKET
Assess whether fragmented national EPR requirements create disproportionate barriers to cross-border trade and take corrective action where necessary.

This petition is not anti-environmental. We support strong environmental standards, responsible packaging and the polluter-pays principle. We simply believe that European SMEs should not have to navigate multiple fragmented administrative systems or pay disproportionate compliance costs to sell compliant products within the EU.

Keep the environmental objectives.
Keep producer responsibility.
Keep strong packaging standards.
But create ONE simple, FREE and genuinely European compliance system.
Make PPWR work for European SMEs and the Single Market.