Under the previous EU packaging framework, based on the Packaging and Packaging Waste Directive, packaging EPR was already implemented through national systems. Whereas, the new Packaging and Packaging Waste Regulation (PPWR) is intended to harmonize packaging rules across the Single Market.

Under Article 44 of Regulation (EU) 2025/40, producers must register in each Member State where they first make packaging or packaged products available. In addition, it requires national registers to be interoperable, machine-readable and linked to one another. Article 45 then directly ties producers to EPR for packaging placed on each national market. Each Member State maintains its own producer register. That is where the problem starts.

For large companies, this is a compliance task. For small businesses, it can become a disproportionate administrative burden. Social media is already exploding with the small businesses expressing their confusion and frustration over this new requirement.

In this article, we have a look at where the complication arises and how it could potentially be fixed.

A small artisan can quickly become a “producer” in several countries under the new EPR regulation

Imagine a small accessories business based in Luxembourg which makes handmade products and sells them online. Products are placed in a small plastic pouch, then into a cardboard box or mailing envelope and sent to the customer who may be anywhere in the EU.

If the customer is in France, that packaging is being placed on the French market. If the next customer is in Germany, the business may also have packaging-EPR obligations there. Some orders may go to Belgium, Austria and the Netherlands, and suddenly the very small business may now have to deal with several national registration and reporting systems.

As a result, the business may have to register separately in each Member State where it places packaged products on the market, repeatedly entering much of the same company information, maintaining multiple registrations, submitting separate packaging declarations and complying with country-specific administrative procedures.

For a small business selling into many EU countries, this can translate into tens of hours of repetitive administrative work, even when the actual quantity of packaging placed on each market is very small.

The environmental objective is reasonable: businesses placing packaging on a market should contribute to the cost of managing that packaging when it becomes waste. However, the environmental obligation should not require the same company information to be entered repeatedly into different national systems.

Is there a better way of doing this?

An alternative would be a central European registration platform. A producer would create one account, enter its company details once and select the Member States where it sells packaged products. The producer would then report the relevant packaging quantities. The system could automatically route the information to the competent national authorities and request additional country-specific information only where necessary.

Member States could still retain control over national EPR fees, producer-responsibility organizations, collection and recycling systems, enforcement, country-specific reporting requirements.

The central platform would simply provide a common interface. One company. One account. One core dataset. Behind it, 27 national systems could continue to operate.

Improved enforcement

A central system would not only reduce the burden on businesses, it could also improve regulatory oversight. A single EU producer identifier would make it easier to see where a company is registered and where it places packaging on the market.

Authorities could more easily detect:

producers selling across borders without registration;
inconsistent company information;
unexplained differences in reported packaging quantities;
businesses operating through multiple national identities.

Data quality could also improve because basic information would be entered once rather than repeatedly. Simplification and stronger enforcement are therefore not competing objectives. Good digital architecture can achieve both.

Compliance should not mean endless paperwork

The PPWR is intended to create a more harmonized European packaging system. Yet for small businesses selling across borders, this new EPR regulation can mean navigating multiple national systems for relatively small quantities of packaging.

The EU has already recognized the need for interoperable registers and has admitted the burden of registering separately in up to 27 national register. Therefore, the next logical step is a single “European EPR gateway” through which businesses can register once and distribute their information to the relevant Member States.

The environmental obligation should remain. The unnecessary duplication should not.

One Market, Many Registers: EU Packaging EPR — Is There a Fix?

A small artisan can quickly become a “producer” in several countries under the new EPR regulation

Is there a better way of doing this?

Improved enforcement

Compliance should not mean endless paperwork