This new directive fully prevents me from selling to the EU due to the cost of registering with an appropriate representative.
PPWR / public feedback / 18 August 2026
source: European Commission
One small sale. Many national registers.
Between 7 and 18 August 2026, 4,946 public submissions to the European Commission described the same friction: a few parcels can mean national steps, fees and reporting work that a small business cannot spread across its margin.
The rule is about packaging waste. The feedback is about the cost of staying in the market.
A snapshot of public feedback on the draft implementing regulation for national registers of producers.
FIG. 01snapshot / collected 18 August 2026
national registers
4,946
unique submissions in snapshot
61
reported country labels
21
original languages
95.6%
of completed size fields marked micro
01 / THE RULE
The rule, in plain language
Regulation (EU) 2025/40 puts national producer registers at the centre of packaging responsibility. Article 44 says producers must register in each Member State where they first make packaging or packaged products available. It allows cost-based, proportionate registration fees and lets Member States provide for authorised representatives.
In the feedback, people describe the practical consequence: separate contracts, portals, languages, deadlines and fixed charges for cross-border sales. Those are respondents' descriptions. They are not a legal conclusion that every seller has the same obligation in all 27 countries.
02 / THE SIGNAL
The signal that keeps returning
I read the full text of every submission and searched for word families about costs, small businesses, procedures and sales. The families overlap. A mention is not a vote and does not measure how severe a problem felt to its author.
4,053
81.9%
submissions mention a cost, fee or affordability term
Contains a cost, fee, price, revenue, margin or affordability term.
Contains a small-business, sole-trader, creator or independent-seller term.
Contains an administration, reporting, paperwork, deadline, procedure, system or language term.
Contains a register, registration, EPR or compliance term.
Contains a cross-border, destination-country, EU-market or single-market term.
Contains a threshold, de minimis, exemption or low-quantity term.
Contains a stop/withdrawal term near a sales, shipping, market or trade term.
Contains a central, one-stop, harmonised, EU-wide or one-registration proposal.
Contains an authorised-representative, agent or mandate term.
lexical indicator / not a sentiment score
03 / THE VOICES
The voices, when you turn the register
Choose a thread and read short fragments from the original source. For submissions written in a language other than English, the text is the Commission's displayed translation and may contain automatic-translation errors.
4,946
of the collection
We also had to stop shipping to most EU countries currently, but we hope for a better solution in the near future.
Having to register and pay fees in 27 EU countries even before I sell/ship a single painting or art print there is absolutely unstainable
expansion to several EU countries already generates annual fixed costs of over EUR 15.000
What kind of small business has that kind of money to shell out for maybe 2 orders worth 50 in Austria?
It's easier to send a handmade creation across the ocean than to a neighbour in EU!
First, my choice is shrinking.
For us, even a low level of sales in several EU countries can lead to a multitude of additional contracts, fees and administrative channels.
The core problem is that the PPWR harmonised the design rules for packaging but left Extended Producer Responsibility completely fragmented.
the regulatory burden should reflect both the scale of the business and its actual environmental impact
There are no excerpts for this thread.
04 / THE ASK
What people ask for, in different words
The same three practical solutions appear across the objections. They belong to respondents, not the Commission, and they are not legal advice.
A European point of entry
One register or portal for reporting and payments, with distribution to national systems afterwards.
A threshold for small volumes
A de minimis rule that treats businesses with a few parcels and small packaging volumes proportionately.
Costs tied to actual packaging
Fees tied to the quantity placed on the market, without fixed charges arriving before a sale.
05 / THE SHAPE
Where the submissions came from
n = 4,946The country field is the one supplied to the Commission. Germany is the largest source in this snapshot. These values are not population-adjusted rates and do not measure economic impact by country.
When they arrived
18 AUGVolume rose sharply on 9 and 10 August. That describes the page's rhythm. It does not prove a coordinated campaign.
7 Aug9
8 Aug103
9 Aug986
10 Aug1,225
11 Aug714
12 Aug524
13 Aug496
14 Aug389
15 Aug140
16 Aug128
17 Aug173
18 Aug59
06 / THE RECORD
How to read the collection
The unit is a submission published in the initiative's "Unique feedback" tab. The snapshot contains 4,946 distinct IDs, 61 country labels and 21 original languages.
The live data changes. In a freshness check after collection, the page already had two new entries. They are outside this snapshot.
The theme percentages are reproducible lexical counts. They are not a representative survey, they do not estimate how many people are affected in the economy, and they do not settle the legal meaning of an obligation.
Names and quotes appear to the extent that the Commission page publishes them. The downloadable collection keeps public text and a source link for each record.
Sources and files
- Commission public feedback
- Regulation (EU) 2025/40, full text
- Commission packaging-waste page
- download JSON snapshot
- download CSV snapshot
The feedback and counts can change as the official page receives new submissions. Keep the snapshot date when citing a number.