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Uh, guys, the EU left a huge loophole. The law applies to all companies that "makes transport packaging available for the first time on the territory of anothe
by A_D_E_P_T 2mo ago
Uh, guys, the EU left a huge loophole.
The law applies to all companies that "makes transport packaging available for the first time on the territory of another Member State, directly to end users." (I've checked and there's definitely no exemption for micro entities.)
The loophole is in the words "for the first time" and "another Member State."
So. You are in Italy. You want to ship a parcel to Germany. If you buy generic packaging off-the-shelf from a German supplier, and then you ship the parcel in that packaging, the regulation does not apply to you, as that specific packaging material was already "made available" in the territory of the destination Member State before you used it. Therefore you cannot be the party making that packaging unit available there "for the first time."
It was already available in that member state via a different company. You bought it. You used it.
You'd need to buy boxes and bubble-wrap from 27 member states and keep them inventoried, but that's pennies compared to actual regulatory compliance -- I mean, the paperwork and fees.