4 ms·

Thanks to tomis who posted the EU FAQ on the topic below: https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1 https://

Thanks to tomis who posted the EU FAQ on the topic below: https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1 https://op.europa.eu/en/publication-detail/-/publication/ad1... None of this applies to companies that are micro-enterprises or use generic rather than branded packaging. There's a helpful diagram on page 13. The author of this article seems to have imagined a worst-case scenario based on either a misunderstanding or misrepresentation of the EU rules; the discussion here seems to have a lot of people who are in a big rush to demonize their perceived political opponents on ideological grounds.

veeti 2mo ago
Simply not true. The helpful diagram you refer to does not consider the case where company A manufactures the packaging, company B buys the packaging, and then does a B2C delivery to another member state. In that case company B is the producer, even if B is a "micro-enterprise". > the discussion here seems to have a lot of people who are in a big rush to demonize their perceived political opponents on ideological grounds. No, it is the opposite. There are a whole lot of people trying to rationalize something crazy. Nevertheless, countless online shops in the EU run by small business have already closed thanks to these regulations. Even if your assertion that this is a giant misunderstanding were true, the damage is already done.
- vanviegen 2mo ago
  > Nevertheless, countless online shops in the EU run by small business have already closed thanks to these regulations. Do you happen to have a source for that?
  - veeti 2mo ago
    You can start with the TFA or many given in this comment section.
    - gusgus01 2mo ago
      The article is actually saying they've had record sign ups this year and as far as I can see doesn't make any comment about a decrease in sales in the last 2 weeks since the implementation of this regulation. There is a first hand report of someone stopping their shipping really far down on this post, and then someone on that chain links to a reddit comment from someone as well. I'm sure there's probably a few comments I missed, but idk if I'd say there's proof of countless here or in the article. It does seem like it'd have a chilling effect if the article's interpretation is correct, and other comments here also stated that the EU commission wanted to have a central registry to minimize the overhead.
- deleted 2mo ago
  [deleted]
- Huppie 2mo ago
  Under definitions (page 9) there's a big section > 6) Who is the ‘manufacturer’ of branded packaging? NEW! And it starts off this blurb: > According to the PPWR (Article 3(1), point (12)), if a packaging does not bear a name or trademark, the manufacturer will be the natural or legal person who manufactures packaging or packaged products. Seems pretty obvious to me the generic bubble envelope example from the blogpost doesn't make sense because that is generic packaging where the manufacturer has to handle this.
  - jansan 2mo ago
    Do you realize who Kafkaesque the discussion already has become?
  - DiggyJohnson 2mo ago
    Good god lol
  - imtringued 2mo ago
    >the manufacturer will be the natural or legal person who manufactures packaging or packaged products. Manufactures packaged products means you buy flat pre-cut card board, fold it, insert the product and then close the box and tape it shut. Even if you bought fully assembled packaging and somehow teleport the product into the packaging, that would still be considered manufacturing a packaged product. >Seems pretty obvious to me the generic bubble envelope example from the blogpost doesn't make sense because that is generic packaging where the manufacturer has to handle this. I'm not sure about the part "doesn't make sense" because it could go either way (you disagree with the regulation or you disagree with the example), but what's obvious is that manufacturer is the Greek engineer and he is responsible for the packaging of the product.
- anigbrowl 2mo ago
  the case where company A manufactures the packaging, company B buys the packaging, and then does a B2C delivery to another member state In that case company A is the producer. Also, even if the packaging is branded, company A is the producer if company B is a micro-enterprise. Looking through the document further, I notice that producers aren't even liable for detailed reporting until they put 10 tons of packaging material onto the market. There are a whole lot of people trying to rationalize something crazy. Nevertheless, countless online shops in the EU run by small business have already closed I'm sure you can find less emotive ways to make your point, like offering some approximate estimates of how many of these small businesses have closed.
  - imtringued 2mo ago
    The entity that introduces the packaging is responsible for upholding the packaging laws. The manufacturing entity of the packaging is not and cannot be responsible, because it does not decide to which countries the packaging is ultimately sent to. And even if it worked that way, if you add a CE certified module to your product, the product as a whole still has to be CE certified.
- floro 2mo ago
  This whole discussion is the reason innovation it's dead in Europe. The regulations are so complex that you need a team dedicated to navigating the bureaucracy nonsense. Small companies and startups can't do that.
  - pfa87 2mo ago
    Same tax on software, just less visible. A solo browser extension or a tiny site still has store review, OAuth consent, privacy pages, and a different "are we a company" answer in FR vs UK. No parcel, still a lawyer-shaped afternoon before you can take a euro. The FAQ-as-PDF problem is the product.
    - meatpile 2mo ago
      Go away, Claude
  - badestrand 2mo ago
    My mom sometimes buys wool from online wool sellers which often are other 60 year old ladies who really don't know much about the internet or business. These are affected, too, and will probably all stop selling to other EU countries because how could they ever fully grasp that regulation in all its details. It's a shame, life and doing business is difficult enough already, and then millions of people get those regulations thrown at them. They already had a big wave of newsletter closures when the EU's GDPR came around and everyone was scared to handle customer data. Now here's the next round.
  - inigyou 2mo ago
    I think you're supposed to ask forgiveness not permission
tgsovlerkhgsel 2mo ago
EU web sites are such an epitome for the EU as a whole: Inscrutably bureaucratic. Instead of a FAQ page that starts with, you know, the FAQ, the actual information is hidden in a PDF download. Once you click it, there is another popup to confirm. That then leads to a PDF with 9 pages of misc front matter before you can see the first question. And the answers themselves are completely unreadable. Take for example "3) Are envelopes containing letters, invoices, statements and other correspondence which serve a communication function considered to be packaging under the PPWR? NEW!": Three paragraphs of legalese just to say "no" in the most complicated and hard to understand way. The whole document is 27847 words. If we ignore the complexity and assume the reading-speed number of 238 wpm that I often see cited, that's two hours of extra compliance overhead just to read the FAQ. And for extra hilarity, the page is also covered in so many popups and warts that fight each other that on mobile you have to accept all cookies because the decline button is covered. Edit: Also, I've been unable to find any diagram on either the page numbered 13 on the bottom of it or the page numbered 13 by the PDF reader (not the same thing, in 2026...). There are two diagrams nearby but none of them seem helpful. If you mean the one in "9) Who is the ‘producer’ of transport packaging?", it only covers a subset of cases (company A sells the packaging in the same member state). The text states "If company A sells the cardboard boxes to Company C in another Member State, and Company C fills the boxes to transport packaged products, then Company C would typically be the producer in that Member State." so we're back to square one.
- deepsun 2mo ago
  > the decline button is covered Well, covering the decline button is very illegal according to EU cookies laws.
  - tgsovlerkhgsel 2mo ago
    Exactly, that's why I think it's hilarious that the EU itself is doing it. Clearly it's just incompetence not malice, but...
    - veeti 2mo ago
aero_code 2mo ago
I don't see a diagram on page 13, but I read a few pages around there. I don't see anything about it not applying to micro-enterprises. I see one diagram (PDF page 14/page num 11) that says a farmer selling "under own name or trademark to end user in another Member State" (without saying there's an exception for a micro-enterprise) means that the "Farmer is producer," which sounds like the opposite of what you said.
- LelouBil 2mo ago
  There is a diagram on page 12 that says companies that use unbranded packages OR that use branded packages but are micro entreprise are not considered as "producer" of the package
  - LelouBil 2mo ago
    After re-reading, it only specifies the packaging manufacturer is the producer when they are in the same member state as the seller. If the seller sells to other member states I don't know
- Huppie 2mo ago
  Not a diagram but the section on page 9 regarding who's considered the manufacturer is relevant here. For generic packaging that's the manufacturer of the packaging.
- anigbrowl 2mo ago
  Sorry, it's on page 12.
ajnin 2mo ago
The exact scenario from TFA is listed just before the diagram you're referencing : "If a farmer packs a few apples in a container (sales packaging) and sells it under its own name or trademark to a retailer or consumer in the same Member State, the farmer is a producer [for the purpose of EPR obligations]" And : "If the farmer sells the packed apples under its own name or trademark in another Member State, the farmer is only the producer if the recipient is the end user of the apples." And : "If the farmer is a micro-enterprise, which is often the case, and the supplier of the apple container is established in the same Member State, such supplier becomes the producer" That last exemption is quite restrictive, it can be a problem. I can attest that a French manufacturer of antistatic packaging refused to sell to me as a micro enterprise when I was selling electronics kits a long time ago and I had to buy them from China. Some states might not even have packaging manufacturers. So the concerns from the article are founded.
- Huppie 2mo ago
  Under definitions (page 9) there's a big section > 6) Who is the ‘manufacturer’ of branded packaging? NEW! And it starts off this blurb: > According to the PPWR (Article 3(1), point (12)), if a packaging does not bear a name or trademark, the manufacturer will be the natural or legal person who manufactures packaging or packaged products. Seems pretty obvious to me the generic bubble envelope example from the blogpost doesn't make sense because that is generic packaging where the manufacturer has to handle this. Edit: The farmer example is a bit bad imho because produce is not like the products in the blogpost and 'under its own trademark' applies to the product packaging (e.g. custom Apple carton frames etc.), best to focus on the more applicable sections imho.
  - kccqzy 2mo ago
    How does that jibe with the following paragraph then? > If company A sells the cardboard boxes to Company C in another Member State, and Company C fills the boxes to transport packaged products, then Company C would typically be the producer in that Member State. This example makes no mention of whether Company C is a micro-enterprise. This is under transport packaging, not branded packaging.
sva_ 2mo ago
Even if true, I wonder if it really helps if I basically need to hire a lawyer ($$$) to find out which regulations may or may not apply, and if I'll get myself into trouble. It is not a coincidence that here in Germany there are whole law firms specialized in suing small business owners (Abmahnkanzleien.) I think for a lot of people the tradeoff might not be worth it.
- PennRobotics 2mo ago
  To the person in the comments suggesting asking for forgiveness rather than permission, it's hard to know which of the many laws won't have warnings during their enforcement e.g. "no website imprint, pay us," versus, "your last sale was B2C, you need GARAN labels from now on, fix it or pay us."
cm2012 2mo ago
There are a dozen small business owners in this thread alone, giving specific details of how this legislation is irrationally hurting their business and the economy.
baxtr 2mo ago
I don’t know who is right or who is wrong. The mere fact that people seem to be highly confused (I saw many posts about that the last week) speaks volumes. Why introduce legislation that is so complex and hard to understand that people seem to be confused wether or not they’re affected. It’s highly irresponsible and arrogant thing to do.
- Longhanks 2mo ago
  > Why introduce legislation that is so complex and hard to understand that people seem to be confused wether or not they’re affected. It’s highly irresponsible and arrogant thing to do. You must be new to Europe :)
l-one-lone 2mo ago
Yes, but the quoted section actually confirms the article’s interpretation. The micro-enterprise exception in the final bullet on page 11 concerns branded packaging when it is initially supplied within a Member State. "Within a Member State" is an important point here. The relevant example is the preceding bullet on page 11: when a company fills a box and sends it directly to an end user in another Member State, that company becomes the producer in the destination country. In the article, the Greek maker is that company. Micro-enterprises receive simplified reporting below 10 tonnes in the regulation, but they are not exempt from registration or destination-country EPR.
harha 2mo ago
Better not grow then!
- anigbrowl 2mo ago
  Why not? If you grow and you're producing more packaging that ends up as waste, your reporting responsibilities/liability scale with your output. As I mentioned in another comment, you're not liable to do detailed reports (identifying what sort of packaging material you produce across 22 categories) until you're producing 10 tons a year.
dana-s 2mo ago
Is a package branded if it has a sticker on it? Is it branded if it's got a print on the outside? If it has a tape that has the brand on it? Because all these cases have happened to smaller shops I buy from. One has a tape on regular boxes that is branded Other has stickers on the packages to identify it And one has a small branded plastic packaging. I doubt any of them is bringing home more than 500k EUR in revenues per year(giving a very safe margin there)
- anigbrowl 2mo ago
  Sounds like those small companies would be micro-enterprises, no?

veeti 2mo ago

Simply not true. The helpful diagram you refer to does not consider the case where company A manufactures the packaging, company B buys the packaging, and then does a B2C delivery to another member state. In that case company B is the producer, even if B is a "micro-enterprise". > the discussion here seems to have a lot of people who are in a big rush to demonize their perceived political opponents on ideological grounds. No, it is the opposite. There are a whole lot of people trying to rationalize something crazy. Nevertheless, countless online shops in the EU run by small business have already closed thanks to these regulations. Even if your assertion that this is a giant misunderstanding were true, the damage is already done.

vanviegen 2mo ago
> Nevertheless, countless online shops in the EU run by small business have already closed thanks to these regulations. Do you happen to have a source for that?
- veeti 2mo ago
  You can start with the TFA or many given in this comment section.
  - gusgus01 2mo ago
    The article is actually saying they've had record sign ups this year and as far as I can see doesn't make any comment about a decrease in sales in the last 2 weeks since the implementation of this regulation. There is a first hand report of someone stopping their shipping really far down on this post, and then someone on that chain links to a reddit comment from someone as well. I'm sure there's probably a few comments I missed, but idk if I'd say there's proof of countless here or in the article. It does seem like it'd have a chilling effect if the article's interpretation is correct, and other comments here also stated that the EU commission wanted to have a central registry to minimize the overhead.
deleted 2mo ago
[deleted]
Huppie 2mo ago
Under definitions (page 9) there's a big section > 6) Who is the ‘manufacturer’ of branded packaging? NEW! And it starts off this blurb: > According to the PPWR (Article 3(1), point (12)), if a packaging does not bear a name or trademark, the manufacturer will be the natural or legal person who manufactures packaging or packaged products. Seems pretty obvious to me the generic bubble envelope example from the blogpost doesn't make sense because that is generic packaging where the manufacturer has to handle this.
- jansan 2mo ago
  Do you realize who Kafkaesque the discussion already has become?
- DiggyJohnson 2mo ago
  Good god lol
- imtringued 2mo ago
  >the manufacturer will be the natural or legal person who manufactures packaging or packaged products. Manufactures packaged products means you buy flat pre-cut card board, fold it, insert the product and then close the box and tape it shut. Even if you bought fully assembled packaging and somehow teleport the product into the packaging, that would still be considered manufacturing a packaged product. >Seems pretty obvious to me the generic bubble envelope example from the blogpost doesn't make sense because that is generic packaging where the manufacturer has to handle this. I'm not sure about the part "doesn't make sense" because it could go either way (you disagree with the regulation or you disagree with the example), but what's obvious is that manufacturer is the Greek engineer and he is responsible for the packaging of the product.
anigbrowl 2mo ago
the case where company A manufactures the packaging, company B buys the packaging, and then does a B2C delivery to another member state In that case company A is the producer. Also, even if the packaging is branded, company A is the producer if company B is a micro-enterprise. Looking through the document further, I notice that producers aren't even liable for detailed reporting until they put 10 tons of packaging material onto the market. There are a whole lot of people trying to rationalize something crazy. Nevertheless, countless online shops in the EU run by small business have already closed I'm sure you can find less emotive ways to make your point, like offering some approximate estimates of how many of these small businesses have closed.
- imtringued 2mo ago
  The entity that introduces the packaging is responsible for upholding the packaging laws. The manufacturing entity of the packaging is not and cannot be responsible, because it does not decide to which countries the packaging is ultimately sent to. And even if it worked that way, if you add a CE certified module to your product, the product as a whole still has to be CE certified.
floro 2mo ago
This whole discussion is the reason innovation it's dead in Europe. The regulations are so complex that you need a team dedicated to navigating the bureaucracy nonsense. Small companies and startups can't do that.
- pfa87 2mo ago
  Same tax on software, just less visible. A solo browser extension or a tiny site still has store review, OAuth consent, privacy pages, and a different "are we a company" answer in FR vs UK. No parcel, still a lawyer-shaped afternoon before you can take a euro. The FAQ-as-PDF problem is the product.
  - meatpile 2mo ago
    Go away, Claude
- badestrand 2mo ago
  My mom sometimes buys wool from online wool sellers which often are other 60 year old ladies who really don't know much about the internet or business. These are affected, too, and will probably all stop selling to other EU countries because how could they ever fully grasp that regulation in all its details. It's a shame, life and doing business is difficult enough already, and then millions of people get those regulations thrown at them. They already had a big wave of newsletter closures when the EU's GDPR came around and everyone was scared to handle customer data. Now here's the next round.
- inigyou 2mo ago
  I think you're supposed to ask forgiveness not permission

tgsovlerkhgsel 2mo ago

EU web sites are such an epitome for the EU as a whole: Inscrutably bureaucratic. Instead of a FAQ page that starts with, you know, the FAQ, the actual information is hidden in a PDF download. Once you click it, there is another popup to confirm. That then leads to a PDF with 9 pages of misc front matter before you can see the first question. And the answers themselves are completely unreadable. Take for example "3) Are envelopes containing letters, invoices, statements and other correspondence which serve a communication function considered to be packaging under the PPWR? NEW!": Three paragraphs of legalese just to say "no" in the most complicated and hard to understand way. The whole document is 27847 words. If we ignore the complexity and assume the reading-speed number of 238 wpm that I often see cited, that's two hours of extra compliance overhead just to read the FAQ. And for extra hilarity, the page is also covered in so many popups and warts that fight each other that on mobile you have to accept all cookies because the decline button is covered. Edit: Also, I've been unable to find any diagram on either the page numbered 13 on the bottom of it or the page numbered 13 by the PDF reader (not the same thing, in 2026...). There are two diagrams nearby but none of them seem helpful. If you mean the one in "9) Who is the ‘producer’ of transport packaging?", it only covers a subset of cases (company A sells the packaging in the same member state). The text states "If company A sells the cardboard boxes to Company C in another Member State, and Company C fills the boxes to transport packaged products, then Company C would typically be the producer in that Member State." so we're back to square one.

deepsun 2mo ago
> the decline button is covered Well, covering the decline button is very illegal according to EU cookies laws.
- tgsovlerkhgsel 2mo ago
  Exactly, that's why I think it's hilarious that the EU itself is doing it. Clearly it's just incompetence not malice, but...
  - veeti 2mo ago

aero_code 2mo ago

I don't see a diagram on page 13, but I read a few pages around there. I don't see anything about it not applying to micro-enterprises. I see one diagram (PDF page 14/page num 11) that says a farmer selling "under own name or trademark to end user in another Member State" (without saying there's an exception for a micro-enterprise) means that the "Farmer is producer," which sounds like the opposite of what you said.

LelouBil 2mo ago
There is a diagram on page 12 that says companies that use unbranded packages OR that use branded packages but are micro entreprise are not considered as "producer" of the package
- LelouBil 2mo ago
  After re-reading, it only specifies the packaging manufacturer is the producer when they are in the same member state as the seller. If the seller sells to other member states I don't know
Huppie 2mo ago
Not a diagram but the section on page 9 regarding who's considered the manufacturer is relevant here. For generic packaging that's the manufacturer of the packaging.
anigbrowl 2mo ago
Sorry, it's on page 12.

ajnin 2mo ago

The exact scenario from TFA is listed just before the diagram you're referencing : "If a farmer packs a few apples in a container (sales packaging) and sells it under its own name or trademark to a retailer or consumer in the same Member State, the farmer is a producer [for the purpose of EPR obligations]" And : "If the farmer sells the packed apples under its own name or trademark in another Member State, the farmer is only the producer if the recipient is the end user of the apples." And : "If the farmer is a micro-enterprise, which is often the case, and the supplier of the apple container is established in the same Member State, such supplier becomes the producer" That last exemption is quite restrictive, it can be a problem. I can attest that a French manufacturer of antistatic packaging refused to sell to me as a micro enterprise when I was selling electronics kits a long time ago and I had to buy them from China. Some states might not even have packaging manufacturers. So the concerns from the article are founded.

Huppie 2mo ago
Under definitions (page 9) there's a big section > 6) Who is the ‘manufacturer’ of branded packaging? NEW! And it starts off this blurb: > According to the PPWR (Article 3(1), point (12)), if a packaging does not bear a name or trademark, the manufacturer will be the natural or legal person who manufactures packaging or packaged products. Seems pretty obvious to me the generic bubble envelope example from the blogpost doesn't make sense because that is generic packaging where the manufacturer has to handle this. Edit: The farmer example is a bit bad imho because produce is not like the products in the blogpost and 'under its own trademark' applies to the product packaging (e.g. custom Apple carton frames etc.), best to focus on the more applicable sections imho.
- kccqzy 2mo ago
  How does that jibe with the following paragraph then? > If company A sells the cardboard boxes to Company C in another Member State, and Company C fills the boxes to transport packaged products, then Company C would typically be the producer in that Member State. This example makes no mention of whether Company C is a micro-enterprise. This is under transport packaging, not branded packaging.

sva_ 2mo ago

Even if true, I wonder if it really helps if I basically need to hire a lawyer ($$$) to find out which regulations may or may not apply, and if I'll get myself into trouble. It is not a coincidence that here in Germany there are whole law firms specialized in suing small business owners (Abmahnkanzleien.) I think for a lot of people the tradeoff might not be worth it.

PennRobotics 2mo ago
To the person in the comments suggesting asking for forgiveness rather than permission, it's hard to know which of the many laws won't have warnings during their enforcement e.g. "no website imprint, pay us," versus, "your last sale was B2C, you need GARAN labels from now on, fix it or pay us."

cm2012 2mo ago

There are a dozen small business owners in this thread alone, giving specific details of how this legislation is irrationally hurting their business and the economy.

baxtr 2mo ago

I don’t know who is right or who is wrong. The mere fact that people seem to be highly confused (I saw many posts about that the last week) speaks volumes. Why introduce legislation that is so complex and hard to understand that people seem to be confused wether or not they’re affected. It’s highly irresponsible and arrogant thing to do.

Longhanks 2mo ago
> Why introduce legislation that is so complex and hard to understand that people seem to be confused wether or not they’re affected. It’s highly irresponsible and arrogant thing to do. You must be new to Europe :)

l-one-lone 2mo ago

Yes, but the quoted section actually confirms the article’s interpretation. The micro-enterprise exception in the final bullet on page 11 concerns branded packaging when it is initially supplied within a Member State. "Within a Member State" is an important point here. The relevant example is the preceding bullet on page 11: when a company fills a box and sends it directly to an end user in another Member State, that company becomes the producer in the destination country. In the article, the Greek maker is that company. Micro-enterprises receive simplified reporting below 10 tonnes in the regulation, but they are not exempt from registration or destination-country EPR.

harha 2mo ago

Better not grow then!

anigbrowl 2mo ago
Why not? If you grow and you're producing more packaging that ends up as waste, your reporting responsibilities/liability scale with your output. As I mentioned in another comment, you're not liable to do detailed reports (identifying what sort of packaging material you produce across 22 categories) until you're producing 10 tons a year.

dana-s 2mo ago

Is a package branded if it has a sticker on it? Is it branded if it's got a print on the outside? If it has a tape that has the brand on it? Because all these cases have happened to smaller shops I buy from. One has a tape on regular boxes that is branded Other has stickers on the packages to identify it And one has a small branded plastic packaging. I doubt any of them is bringing home more than 500k EUR in revenues per year(giving a very safe margin there)

anigbrowl 2mo ago
Sounds like those small companies would be micro-enterprises, no?