On Saturday 5th September 2026, my friend Guy Wilkinson, informed me that he'd sussed out that non-EU members could leave feedback on the EU portal. Here's what I wrote:
I have a small one-man business based in the UK. My sales to the EU contribute perhaps 60% towards my total global sales. The new EPR legislation means that like many artists, creators and small businesses, I have had to withdraw from the EU market.
I commend any government that makes moves towards reducing waste. I feel however, that the implementation of the new EPR legislation is very problematic and will not significantly reduce packaging waste. Indeed, it will adversely impact business with and within the EU and Norway.
I welcome the opportunity to provide feedback although I am sceptical that anything will change.
Please note the following:
- Several attempts to acquire details of the new legislation did not answer many of my questions. There was no central portal to provide the answers I needed. I therefore had no option other than to approach (privately owned) compliance companies, none of which had comprehensive information. Neither did I have any confidence that the information I was presented with, was correct as there seems to be no certification for compliance companies by their respective governments.
- When it comes to EPR implementation, like many, I am confused about the word ‘Union’ in the term ‘European Union’. Producers are asked to register separately with each EU (and Norway) member state. This does not seem very union-like to me.
- Compliance companies are offering packages, all of which start by requesting the applicant to select the countries that the applicant would like to register with. To the best of my knowledge, the new EPR legislation applies to EU and Norway but Norway is not on the list of countries that can be selected.
- The amount of waste generated by artists, creators and small businesses is exceedingly small in comparison to lager businesses and I feel that the legislation is targeting the wrong people. It might have been an idea for example, to set thresholds for packaging. My business probably sends less than 50kg of packaging per year into the EU (and Norway). This is negligible when compared to large companies, yet I am forced to comply with the same requirements (logistically and financially) as large companies. I have read that the EU is treating all businesses equally. Instead, it should be treating all businesses proportionally.
- Packaging void has not been carefully considered. Customs requires the CN22 or CN23 Customs documentation to be attached to a single flat face of a package. The Customs declaration has a minimum size of about A5. If a small item is to be shipped, then to abide by the Customs requirement, packaging must have at least one A5 sized face. For many small items, this will be in contradiction to the EPR requirement which demands that void must not exceed 40% of the item size.
- Packaging protects the item when in transit. I feel that the EPR legislation in its current form, will result in many shipments being damaged in transit. If this will be the case, then ironically, the waste generated by damaged products will be considerable. Why would the producer be liable for disposal of packaging waste under these circumstances or is it assumed that shipping insurance will cover that? If the latter is the case, then that needs to be confirmed by all courier companies. I do not think that the EU (and Norway) have liaised with courier companies over this.
- It is my intent that by the end of 2026, all my packaging will be fully PPWR compliant, biodegradable and recyclable. It will also be appropriately marked with information pertaining to disposal, etc. With regards the EU (and Norway) however, my efforts will be meaningless as I simply cannot afford the cost of being registered in the EU countries that I trade with.
- It seems apparent that this legislation has been rushed through with very little if no thought, given to the suitability of the legislation to fulfil its objectives and the enormous cost to business with and within the EU (and Norway).
- Perhaps the EU (and Norway) might consider involving micro and small business owners when planning similar legislation in the future. It’s quite apparent that the EU did not do this during the planning of the EPR legislation.
I have taken some time to read some of the many comments left by others. It seems that many small and micro businesses are seeing the legislation as very much in favour of large companies and corporates. I hope the EU listens and make things easier.