PPWR and Small Craft Businesses

Last updated: 30 September 2026

The EU’s Packaging and Packaging Waste Regulation, known as the PPWR, applies from 12 August 2026. It creates a common framework for packaging across the European Union, covering packaging design, recyclability, reuse, waste prevention and Extended Producer Responsibility, or EPR. For craft businesses, some of the most immediate questions concern not the packaging itself, but what happens when products are sold across borders. The PPWR establishes a European framework, while many aspects of EPR continue to be administered through national systems. Registration, reporting, fees and other requirements can therefore vary between Member States.

“Environmental responsibility should be proportionate to environmental impact.”
ECA Position Paper

September 2026

Table of Content

One European Framework, Different National Systems
Selling Across Borders
What About an Authorised Representative?
If You Receive an Order from Another EU Country
What Is Changing at EU Level?
What ECA Is Working On
Ceramics, Textiles and Other Low-Volume Packaging Materials
Official Packaging and EPR Contacts by Country
Resources and Further Reading
Latest Developments

One European Framework, Different National Systems

Extended Producer Responsibility, or EPR, is the system through which producers contribute to the costs of managing the packaging they place on a market once it becomes waste. Depending on the national system and the business situation, this can involve producer registration, participation in an EPR scheme, reporting, financial contributions and, in certain cross-border situations, an Authorised Representative.

These are separate parts of the system. There is no single “PPWR fee”. Registration may be free in one country while participation in an EPR scheme carries a cost. Commercial compliance services and Authorised Representatives can add further costs. The EU framework does not create a single EPR registration covering the whole Union. National systems continue to play a central role.

Selling Across Borders

Where a business established in one Member State sells and delivers a packaged product directly to an end user in another Member State, the foreign business can be considered the producer for EPR purposes in the destination country.

The position can be different where another business enters the supply chain in the destination country. If the Danish studio supplies its necklaces to a Spanish importer or distributor rather than directly to the end user, that domestic business may instead be considered the producer. National systems differ, so an occasional sale does not automatically create the same costs or administrative requirements in every country. The destination country and the way the product reaches the end user are therefore the places to start.

What About an Authorised Representative?

An Authorised Representative acts on behalf of a producer in relation to specified EPR obligations in another Member State. Under the current framework, this requirement can arise in certain cross-border situations where a business sells packaged products directly to end users in another Member State where it is not established. The European Commission has proposed suspending certain mandatory Authorised Representative requirements for EU-based producers selling across borders. The proposal has not been adopted and remains under legislative consideration. Businesses should therefore continue to check the current requirements in the countries where they sell rather than assuming that the proposed change already applies. Even if the Authorised Representative requirement changes, other EPR obligations may still remain. Registration, reporting and financial contributions are separate parts of the system.

If You Receive an Order from Another EU Country

There is no single answer for every business or every country, but these are sensible first steps.

1.Check the destination country.
If you sell and deliver directly to an end customer in another EU Member State, start by checking the packaging producer-responsibility rules in that country.

2.Keep a simple record.
Note the destination country, the number of parcels sent, the packaging materials used, the approximate quantity or weight, and whether you sell directly to consumers or through another business.

3.Start with the official source.
Before buying a commercial compliance service, check the competent national authority or official producer register. Registration, reporting, EPR participation, financial contributions and Authorised Representation are separate requirements and may not all apply in the same way.

4.If it is unclear, ask.
A short description of your actual situation is usually more useful than legal terminology.

5.Do not assume very small quantities are automatically exempt.
The PPWR provides simplified reporting for producers placing less than 10 tonnes of packaging on a Member State market during a calendar year, subject to the Regulation and national implementation. This is a reporting simplification, not a general exemption from registration or EPR.

The rules concerning Authorised Representatives are currently under legislative review. Other EPR obligations may still apply even if those rules change.

What Is Changing at EU Level?

The PPWR now applies, but parts of the wider EPR framework are still under legislative and policy review.

Authorised Representatives

The European Commission has proposed suspending certain mandatory Authorised Representative requirements for EU-based producers selling across borders. The proposal has not been adopted. Businesses should therefore continue to check the requirements that apply in the countries where they sell.

Fragmentation Between National EPR Systems

The discussion is also moving beyond Authorised Representatives alone. A September 2026 briefing from the European Parliamentary Research Service identifies fragmentation between national EPR systems as a barrier to the Single Market. Cross-border producers may face different definitions, registration portals, reporting formats, fee structures and deadlines between Member States.

The Circular Economy Act

The forthcoming Circular Economy Act is expected to address wider reform of Extended Producer Responsibility, including simplification, harmonisation and digitalisation. Among the ideas under discussion is a digital one-stop shop for EPR registration and reporting. Such a system could reduce duplication across national systems, but it would not by itself harmonise the underlying legal definitions, reporting obligations, fees or enforcement arrangements.

Read the European Parliamentary Research Service briefing: Extended producer responsibility: 2026 turning point

What ECA Is Working On

ECA supports the environmental objectives of the PPWR. The issue for the craft sector is proportionality. A small studio sending only a handful of parcels to another Member State can still encounter registration, reporting, EPR and representation structures designed to operate across national markets. ECA’s PPWR Impact Survey gathered 768 responses, including respondents from all over Europe. Among respondents making cross-border sales, 68.6% reported sending no more than 50 parcels a year to other EU countries, while 58.5% said they were stopping, pausing or restricting EU cross-border sales.

The survey was self-selecting and should be read as evidence about the respondents, rather than as a statistically representative estimate of the entire European craft sector.

ECA’s Position Paper sets out five areas for action

• relief from disproportionate mandatory Authorised Representative requirements for EU micro and small enterprises
• a simplified route for very low-volume cross-border sales
• more interoperable EPR administration across national systems
• proportionate national procedures and fees
• clearer practical guidance for micro-enterprises

Read the ECA PPWR Impact Survey
Read the ECA Position Paper

Ceramics, Textiles and Other Low-Volume Packaging Materials

The PPWR contains specific provisions for certain sales packaging made from lightweight wood, cork, textile, rubber, ceramic, porcelain and wax. Each of these categories represents less than 1% by weight of packaging placed on the EU market. Sales packaging made from these materials is exempt from particular recyclability requirements under Article 6. This does not mean that the materials are generally exempt from the PPWR or from Extended Producer Responsibility. A textile pouch used to contain or present a piece of jewellery may still be packaging. A ceramic container may still be packaging. Producers may therefore still have registration, reporting and EPR obligations.

For these material categories, the PPWR requires Member States to take account of the technical feasibility and economic viability of recycling when determining EPR financial contributions. How these provisions are reflected in national EPR systems and fee structures is one of the implementation issues ECA is following.

The Commission must review these material-specific exemptions by 1 January 2035. This is a review date, not a general exemption from EPR obligations until 2035.

Official Packaging and EPR Contacts by Country

Packaging producer responsibility continues to be administered through national systems. The directory below points to the relevant public authority, statutory producer register or official packaging system in each EU Member State. It is a starting point, not a compliance checklist. The inclusion of a country does not mean that every business selling there automatically needs to register, appoint an Authorised Representative or pay a particular fee. If you sell directly to an end customer in another Member State, start with the official source for that country.

Malta

Environment and Resources Authority, Packaging Producer Responsibility

Netherlands

Verpact, Packaging Producer Responsibility

Poland

BDO, Database on Products, Packaging and Waste Management

Portugal

Agência Portuguesa do Ambiente, Packaging and Packaging Waste

Romania

Environmental Fund Administration, AFM

Slovakia

ISOH, Waste Management Information System

Slovenia

Packaging Producer Register, GOV.SI

Spain

MITECO, Registro de Productores de Producto, Sección Envases

Sweden

Swedish Environmental Protection Agency, PPWR Packaging Producer Guidance

A European Reference Point

European National Registers for Packaging, EUNR: EUNR brings together national organisations responsible for packaging producer registers and packaging data in participating EU Member States. Its work includes PPWR implementation, Extended Producer Responsibility and cross-border supply chains. EUNR also provides guidance on determining the responsible producer for EPR in cross-border situations. EUNR does not replace national authorities or producer registers. Businesses should still check the requirements of the individual Member State concerned.

Resources and Further Reading

Regulation (EU) 2025/40: Read the Regulation on EUR-Lex
European Commission: Packaging and Packaging Waste Regulation: European Commission PPWR overview
European Commission PPWR FAQ: Read the PPWR FAQ
European Commission Guidance: Read the Commission guidance
European National Registers for Packaging, EUNR: Visit EUNR
Extended Producer Responsibility: Read the EPRS briefing
A September 2026 briefing from the European Parliamentary Research Service examining EPR fragmentation, Authorised Representatives and possible future reforms.
ECA PPWR Impact Survey: Read the ECA PPWR Impact Survey
Evidence from 768 respondents on cross-border EPR, administrative burden and access to the European Single Market.
ECA Position Paper: Read the ECA Position Paper
ECA recommendations for making the PPWR and EPR framework workable for craft micro-enterprises.

ECA Members on PPWR

Oficio y Arte, Spain: RAP y envases en artesanía
Crafts Council UK: Unpacking the EU’s Packaging and Packaging Waste Regulation (PPWR)
Bundesverband Kunsthandwerk, Germany (Membership Access): PPWR information for the German craft sector

Latest PPWR Updates

This information is provided by the European Crafts Alliance as an accessible guide and summary. It is not legal, regulatory, tax or professional compliance advice. For legally binding requirements, please consult Regulation (EU) 2025/40, the competent national authorities and producer registers. Simplified examples cannot cover every supply-chain arrangement, particularly where sales involve importers, distributors, retailers, fulfilment services or other intermediaries.

Last updated: 30 September 2026

This page is updated as the regulatory framework develops. To report an error, outdated link or correction to the information on this page, please contact us at communication(at)europeancraftsalliance.org.