58.5% of respondents to ECA’s Packaging and Packaging Waste Regulation (PPWR) Impact Survey are stopping, pausing or restricting EU cross-border sales. The findings point to a growing mismatch between very small sales volumes and national Extended Producer Responsibility (EPR) requirements. The ECA is calling for five targeted changes to keep craft micro-enterprises participating in the Single Market, including relief from mandatory Authorised Representatives and a simplified, interoperable route for very low-volume cross-border sales.
“Environmental impact is measured in kilograms of packaging, while administrative burden is multiplied by borders. “ ⁃The ECA Advocacy Group
The ECA has published the findings of its PPWR Impact Survey together with a position paper calling for more proportionate implementation of Extended Producer Responsibility (EPR) requirements for very small cross-border businesses.
The Packaging and Packaging Waste Regulation is intended to reduce packaging waste, improve recyclability and reuse, and create a more harmonised approach across the European Union. These objectives are closely aligned with the way many craft businesses already work. At small scale, with close knowledge of materials, durable products and relatively limited quantities of packaging.
The difficulty arises when very small quantities of packaging meet separate national EPR systems. A craftsperson may send only one or two parcels to a Member State during an entire year. The amount of packaging placed on that market may be measured in grams not in kilograms, while the craftspeople can still face registration, fees disproportionate to the volume of packaging placed on the market, reporting, representation and other national requirements.
Evidence from the sector
The ECA PPWR Impact Survey received 768 responses from respondents from every EU Member State. The sample is strongly rooted in micro-enterprise practice. 79.4% of respondents are sole traders, while 89.2% are sole traders or businesses with two to four employees. Among respondents making cross-border sales, 68.6% send no more than 50 parcels a year. Yet 58.5% reported stopping, pausing or restricting EU cross-border sales.
Open-text responses repeatedly describe the same pattern: annual sales into an individual country may amount to 50€, 100€ or 200€, while reported registration, representation or compliance costs can run into hundreds of euros.
The survey is self-selecting and should not be read as statistically representative of the entire European craft sector. Its value lies in the scale, geographic spread and consistency of the practical issues reported.
ECA’s position
The ECA welcomes the PPWR’s environmental ambition and its recognition that micro-enterprises require proportionate treatment. The concern is that this principle has not yet been sufficiently reflected in the way cross-border EPR works for occasional, low-volume sales.
The position paper sets out five recommendations.
Businesses making cross-border sales within the Single Market should be able to comply directly with their EPR responsibilities without being required to appoint paid representatives in each destination country.
Possible approaches could include thresholds based on packaging weight, destination-market sales or a combination of both, together with simplified declarations for occasional sales.
National systems should work towards common data formats, simplified reporting templates and interoperable digital tools, with greater EU-level integration explored over time.
Micro-enterprises placing very small quantities of packaging on a market should not face minimum fees or procedures that bear little relationship to those quantities.
Information on packaging weight, occasional sales and cross-border EPR obligations should be easy to locate and navigate across Member States.
Removing the Authorised Representative requirement would be an important step, but it would not resolve the wider issue on its own. Separate national registration, reporting, fees and procedures would remain. The ECA is therefore asking for the discussion to go beyond representation and address the proportionality of the cross-border EPR system itself.
The environmental objective is not in dispute. A craftsperson sending a handful of parcels to another Member State should not face fixed administrative costs that exceed the value of those transactions.
Read the full ECA PPWR Impact Survey report>>
Read the full ECA Position Paper>>
Visit ECA PPWR Hub>>