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I've seen some conflicting claims on this law and to me it sounded like it affects mostly producers of packaging, but everyone else seems to be complaining abou

by IsTom 1mo ago

I've seen some conflicting claims on this law and to me it sounded like it affects mostly producers of packaging, but everyone else seems to be complaining about it too. Did everyone actually read the law or is this a game of telephone?

alephnerd 1mo ago
> Did everyone actually read the law or is this a game of telephone It's HN - everyone did the latter.
l-one-lone 1mo ago
The terminology is confusing. Under the PPWR, a “producer” is not necessarily someone who manufactures packaging. The regulation also covers businesses selling packaging or packaged products directly to end users in another Member State. So a maker shipping a board in an envelope can indeed be the packaging producer for EPR purposes.
- IsTom 1mo ago
  Having looked into FAQ[1] it seems that it's mostly the case if you sell in branded packaging and are >10 people or >2M eur revenue. [1]https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1 https://op.europa.eu/en/publication-detail/-/publication/ad1...
  - kakoni 1mo ago
    According to the PPWR rules, if you (as a webshop) package your shipment in non-branded box and send it from another EU country to another, then you are considered to be manufacturer(=you were the first to bring this into market) and EPR/PPWR rules apply. There is no exemption for this.
    - anigbrowl 1mo ago
      I'm more inclined to believe the person who backed up their argument with a citation, especially after looking at the document they linked which expressly contradicts you.
      - kakoni 1mo ago
        Sorry, messed up the terms here. You became producer. From the earlier faq that parent posted; > The following provide some typical examples of who the producer of transport packaging is: - If Company A fills the cardboard boxes and sells them to an end user in another Member State, then Company A would typically be the producer in that other Member State.
        IsTom 1mo ago
        In the following > If Company A manufactures cardboard boxes under the name or trademark of Company B, then Company B will typically become the manufacturer and producer of the boxes in that Member State. However, if Company B is a micro-enterprise, then Company A is manufacturer and the producer in the Member State. That has the same "typically", so I'd assume it has the same micro-enterprise exemption. Otherwise only branded boxes would be exempt and that'd be pretty weird.

by IsTom 1mo ago

alephnerd 1mo ago

> Did everyone actually read the law or is this a game of telephone It's HN - everyone did the latter.

l-one-lone 1mo ago

The terminology is confusing. Under the PPWR, a “producer” is not necessarily someone who manufactures packaging. The regulation also covers businesses selling packaging or packaged products directly to end users in another Member State. So a maker shipping a board in an envelope can indeed be the packaging producer for EPR purposes.

IsTom 1mo ago
Having looked into FAQ[1] it seems that it's mostly the case if you sell in branded packaging and are >10 people or >2M eur revenue. [1]https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1 https://op.europa.eu/en/publication-detail/-/publication/ad1...
- kakoni 1mo ago
  According to the PPWR rules, if you (as a webshop) package your shipment in non-branded box and send it from another EU country to another, then you are considered to be manufacturer(=you were the first to bring this into market) and EPR/PPWR rules apply. There is no exemption for this.
  - anigbrowl 1mo ago
    I'm more inclined to believe the person who backed up their argument with a citation, especially after looking at the document they linked which expressly contradicts you.
    - kakoni 1mo ago
      Sorry, messed up the terms here. You became producer. From the earlier faq that parent posted; > The following provide some typical examples of who the producer of transport packaging is: - If Company A fills the cardboard boxes and sells them to an end user in another Member State, then Company A would typically be the producer in that other Member State.
      - IsTom 1mo ago
        In the following > If Company A manufactures cardboard boxes under the name or trademark of Company B, then Company B will typically become the manufacturer and producer of the boxes in that Member State. However, if Company B is a micro-enterprise, then Company A is manufacturer and the producer in the Member State. That has the same "typically", so I'd assume it has the same micro-enterprise exemption. Otherwise only branded boxes would be exempt and that'd be pretty weird.