EU Packaging Regulation: For Small Firms, Where You Sell Now Counts
The new EU packaging regulation has applied since August. It creates obligations for packaging on the EU market, yet provides relief for small producers.
The European packaging regulation goes by the technical abbreviation PPWR. It governs which packaging may be placed on the market of the European Union, how packaging waste is to be avoided and treated, and what responsibility companies bear for its later disposal.
One regulation, many practical consequences
Since 12 August 2026 the regulation has applied directly in all EU member states. It thereby replaces the previous packaging directive as the central legal basis. That does not mean, however, that every requirement takes effect for every company in the same way on the same day. Various transition periods, technical specifications and questions of national enforcement continue to play a role.
For small companies in particular, the situation is therefore more complex than the catchphrase 'new packaging rules' suggests. Company size alone is not decisive. The volume of packaging, a company's role in the supply chain and the market where the packaged goods are sold matter just as much.
No automatic exemption for small companies
A central part of the regulation is extended producer responsibility. Companies that place packaged goods on the market are to contribute to the costs of collecting, sorting and recycling the resulting waste. In many countries national systems for this already existed. The new regulation is intended to harmonise these rules more strongly over the long term.
The European Commission explicitly points out that small producers handling fewer than ten tonnes of packaging per calendar year can benefit from reliefs. Member states and the competent systems are to avoid disproportionate administrative burdens. Simplified reporting, flat-rate fees, reduced documentation duties or fewer inspections are possible.
That is not, however, a general exemption from responsibility. Anyone placing only small quantities of packaging on the market must still clarify which national registration rules apply. Particularly in cross-border online trade, obligations can differ from one country to another. The Commission therefore advises companies to find out from the competent national authorities and systems how the rules are implemented in practice.
Another point of contention concerns the obligation to appoint an authorised representative for sales into other member states. The Commission has proposed suspending this requirement for small companies. As long as that proposal is under political discussion, it calls on member states to apply the obligation pragmatically and not to impose sanctions on the small companies concerned. That, too, is not a definitive legal change but a transitional arrangement.
What Swiss suppliers need to check
The EU packaging regulation does not automatically change Swiss packaging law. Switzerland is not an EU member state, and the regulation applies directly only within the European Union. For Swiss companies it can nevertheless be decisive.
Anyone selling packaged products from Switzerland to customers in the EU, or bringing goods onto the EU market through European distribution partners, must check which role they take on in legal terms. Depending on the constellation, registration in a national producer register, participation in a disposal system or the appointment of a representative may be required.
It would be wrong, though, to describe every Swiss company as affected across the board. A company that sells exclusively in Switzerland does not fall under the EU regulation merely because of where it is based. Conversely, a small online retailer with a few exports to several EU countries can already be confronted with differing national requirements.
For Swiss businesses, therefore, it is not only the quantity of packaging used that is decisive but also the distribution structure. Who is the producer, who imports and who first makes goods available in a particular EU country can determine which obligations arise in concrete terms.
Harmonisation promises relief – later
The PPWR pursues a dual goal: less packaging waste and a more strongly harmonised internal market. More uniform rules for registration, labelling and recycling are intended to help companies that operate across borders in particular over the long term.
In the short term, however, implementation remains demanding. The regulation requires numerous supplementary rules and national adjustments. For small businesses, the most important step is therefore not a hasty conversion but a precise stocktaking: which EU countries are sold to, who legally places the packaging on the market there, and which national systems apply?
The new EU regulation is thus neither a free pass nor automatically an existential burden. Above all, it is a mandate for every company supplying the EU market to review its position.
Sources
- EUR-Lex: Regulation on packaging and packaging waste, EU 2025/40
- European Commission: Implementation of the packaging regulation
- European Commission: Extended producer responsibility for small businesses
- European Commission: FAQ on the packaging regulation
- European Commission: Guidance on Regulation EU 2025/40
