New EU Packaging Rules: A Stranglehold for Small Merchants (cross-border guide)

Many micro-enterprises are considering suspending shipments due to the administrative burdens introduced by the new regulation.
Context
In a nutshell
- New EU packaging rules for small traders
- Many micro-enterprises are considering suspending shipments
- Administrative charges introduced by the new regulation
Key facts
- PPWR Regulation
- Entered into force between the end of 2024 and the beginning of 2025
- New binding operating rules from mid-2026
- Objective: reduce packaging waste and improve recycling
The PPWR officially came into force between the end of 2024 and the beginning of 2025. Its new operating rules have become binding and applicable from mid-2026.
New rules for small merchants
The PPWR regulation introduces new rules for small traders regarding packaging. The goal is to reduce packaging waste and improve recycling. The new rules require small traders to use packaging made of recyclable material and to be able to demonstrate proper packaging management.
What are the new operating rules?
The new operating rules of the PPWR regulation are as follows:
- Use packaging made of recyclable material
- Demonstrate proper packaging management
- Reduce packaging waste by at least 50%
- Improve packaging recycling by at least 70%
How will the new rules be applied?
The new operating rules will apply from mid-2026. Small merchants will need to demonstrate the
Operational details
The new EU rules on packaging require those who sell products in different European countries to register in the individual national extended producer responsibility systems. This means that for those who want to ship to all 27 Member States, registrations can reach 27. An onerous and complex obligation for small Ticino traders operating in the sector. According to the EU Directive 2019/904 of 5 June 2019, which regulates extended producer responsibility for packaging, packaging producers must register in the national extended producer responsibility systems of the individual member countries. This obligation has been in force since 4 July 2021. For example, a company selling products in Switzerland, Austria and Germany will have to register in the national extended producer responsibility systems of these three countries. This means that for a company operating in these three countries, registrations can reach 3. But if the company wants to ship to all 27 Member States, registrations can reach 27. The registration requirement is very burdensome for small Ticino traders operating in the sector. According to an estimate by the Swiss Council for International Cooperation, small traders in Ticino may have to spend up to 10,000 Swiss francs a year on registrations. This is a burden that may be difficult for small businesses to bear. In addition, the obligation to In conclusion, the new EU rules on packaging are an onerous and complex obligation for small Ticinese traders operating in the sector. Small traders should know how to register in individual national extended producer responsibility schemes and keep track of their packaging and registrations made.
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Key points
The problem concerns in particular small businesses, for which the new procedures risk making cross-border sales uneconomical. Sandra, founder of the Berlin-based design brand s.wert design, has decided to suspend shipments to the EU due to the administrative burdens introduced by the new regulation.
According to Article 8 of EU Regulation 2019/994, dated 3 April 2019, packaging must be reusable or compostable by 2025. However, small traders such as s.wert design face costs and complexity that may not be sustainable due to their size.
According to a calculation made by s.wert design, the cost of reusable packaging for a 5 kg product is about CHF 10.50, while the cost of compostable packaging is about CHF 5.20. However, to enforce these rules, companies need to invest in new equipment and technologies, which could lead to increased overhead costs.
For example, a company in Lugano that sells 5kg products might have to invest around CHF 50,000 to buy 10,000 high-quality reusable packaging. In addition, it will also have to face the costs of shipping and packaging maintenance.
⚠️ To avoid facing these costs, companies may choose to suspend shipments to the EU or increase product prices to cover the new costs. However, this could lead to a
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Source: tio.ch
Frequently Asked Questions
- What is PPWR?
- The PPWR is a European regulation that comes into force between the end of 2024 and the beginning of 2025 and introduces new binding operating rules from mid-2026.
- Why do many micro-enterprises consider suspending shipments?
- Because the new EU rules on packaging require that those who sell products in different European countries must register in the individual national extended producer responsibility systems.
- What happens if the new provisions are not respected?
- Sanctions shall be established by the individual Member States and shall be effective, proportionate and dissuasive.