PPWR: what obligations apply to a micro-enterprise or independent maker?

1The regulation includes specific rules for micro-enterprises

The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, which has applied since 12 August 2026, provides no general size exemption from its qualitative obligations. Taken alone, this general rule suggests that independent businesses, craftspeople, freelancers and e-commerce businesses have the same conformity obligations as manufacturers. Our PPWR overview and PPWR scope test explain the micro-enterprise clause alongside it. These businesses do not have the same obligations: two clauses of the regulation transfer them to the packaging supplier.

If you are a micro-enterprise under Recommendation 2003/361/EC, with fewer than 10 employees and annual turnover or an annual balance sheet total below €2 million, two articles apply in parallel:

• Article 15(12) transfers the obligations under Article 15 (conformity assessment procedure, technical documentation, labelling and management of non-conformity) to your packaging supplier, provided it is established in the European Union.
• Article 3, point (b) goes further when the supplier is in the same Member State as you: the supplier is recognised as the packaging manufacturer under the regulation's general definition.

For a French micro-enterprise, a French supplier therefore provides the most complete legal position. The infographic below summarises the three typical situations.

2The three obligations that remain your responsibility

Once this transfer of responsibility is established, three obligations remain yours, listed here in order of importance.

1. Choose packaging suppliers established in the EU

• This covers envelopes, cardboard mailing sleeves, boxes, void fill and strapping: everything you use for shipping.
• Prioritise suppliers in the same Member State as you (French suppliers if you are in France), to benefit from Article 3 as well as Article 15(12).
• Keep your purchase invoices, which serve as evidence of EU origin during an inspection.
• Take care when buying on marketplaces from non-EU sellers shipping directly (dropshipping): the micro-enterprise then becomes the packaging importer, with the associated obligations (technical documentation, declaration of conformity and labelling). If this is your current situation, switching to an EU supplier resolves the issue; otherwise, dedicated support is needed to prepare the technical documentation for your imported packaging.

2. Join the French EPR scheme

• France introduced extended producer responsibility (EPR) for household packaging in 1992. Every company placing a packaged product intended for a final consumer on the French market must finance the sorting and recycling of this packaging through an EPR fee. This is an obligation independent of the PPWR, which existed before it and will continue after it.
• You join one of the 2 State-approved producer responsibility organisations (PROs, éco-organismes in French), Citeo (the longstanding market leader) or Léko (the alternative), which pass your EPR fee on to the local authorities managing the yellow recycling bins.
• For small volumes, an annual flat fee and around fifteen minutes spent filling in a form are enough. At Citeo, the flat-fee declaration costs €110 excl. VAT for fewer than 10,000 consumer sales units (UVC in French) per year, covering both packaging and graphic paper, including the unique identifier (identifiant unique, or IDU). At Léko, the minimum charge is €95 excl. VAT, capped at €150 excl. VAT for fewer than 20,000 UVC, excluding paper, which is billed separately with an exemption below 5 tonnes (2026 schedules).
• The obligation begins when a packaged product intended for a French consumer is first placed on the market.
• As for penalties, the inspection risk is low for a micro-enterprise and membership costs around €100 to €150 excl. VAT per year. Its main benefit is the unique identifier it enables you to obtain from ADEME (the French Agency for Ecological Transition).
• The declaration covers every parcel shipped to a private individual, whether the box is new or reused. Placing a packaged product on the French market is what matters, rather than purchasing the packaging.
• By joining, you obtain a unique identifier (IDU), an ADEME number with 15 characters (the AGEC law, France's Anti-Waste and Circular Economy Act, Article 62, codified in Article L. 541-10-13 of the French Environmental Code). Since 2022, marketplaces must check their sellers' IDUs and increasingly request them when a shop opens. A missing IDU may lead to suspension of a seller account: this makes the declaration essential for online sellers, often before any administrative inspection.

3. Sales in other EU countries

• Since 12 August 2026, the PPWR has required registration on the national producer register in each EU country where you place packaged products on the market (Article 44, with existing registers applying until PPWR registers are available) and, if you are not established there, appointment of a local EPR authorised representative (Article 45). There is one representative per country, with no European one-stop shop.
• This also applies between Member States: a French maker shipping to Belgium is a producer in Belgium. The obligation does not cover only sellers established outside the EU.
• France acted earlier: since 10 July 2026, every producer not established in France placing products covered by an EPR scheme on its market must appoint an authorised representative established in France (Article L. 541-10-9-1 of the French Environmental Code, introduced by Law No 2026-602 of 8 July 2026). If you are established in France, this does not affect you. If you are established elsewhere and sell in France, the obligation already applies, even when EPR fees are paid, and covers all EPR schemes, beyond packaging. We have devoted a full article to this subject.
• The text provides an exception: the obligation to appoint an authorised representative is deemed fulfilled for products whose EPR obligations are already met by an online platform established in France. Selling through a French marketplace may therefore cover this requirement, which you should confirm with the platform.
• The strictest register remains Germany's LUCID, with fines from the first undeclared sale.
• Decide country by country: start with the country where you sell most (by volume or frequency), check its thresholds and arrangements, then expand. Restricting shipping destinations to countries that justify this cost is a perfectly legitimate choice.
• In December 2025, the Commission proposed suspending the European authorised representative obligation for producers established in the EU until 2035 through the environmental omnibus. The Council rejected this suspension on 24 June 2026; in Parliament, the rapporteur proposes limiting it to companies with fewer than 50 employees and €10 million in turnover. Nothing has been adopted: the obligation applies. Details of the mechanism and how it interacts with the French rule.

Check your situation with 3 questions. Unsure whether you need to register (Article 44) and appoint an EPR authorised representative (Article 45)? Our tool gives an immediate verdict, whether you sell only in France, through a marketplace or in several countries, and the steps to follow country by country.

3What you can stop worrying about

• Address labels are not packaging under the regulation.
• Cardboard boxes that you print and assemble yourself from sheets bought in the EU pose no design problem: paper and cardboard are the best-positioned materials under the regulation, well above the recyclability requirements planned for 2030.
• Harmonised sorting labels (2028) and mandatory recyclability (2030) concern packaging design: your supplier bears these requirements.
• Banned formats (miniature hotel toiletries, plastic packaging for fruit and vegetables below 1.5 kg and very lightweight plastic bags) are formats most micro-enterprises do not use.
• The PPWR concerns packaging only: your products themselves may fall under other EPR schemes depending on their nature. For fashion makers, textile products sold under your own brand fall under textile EPR (Refashion), a scheme distinct from packaging, which also offers a simplified declaration for small volumes.

To resolve the remaining questions, see the full PPWR timeline and banned formats.

4You can keep reusing your suppliers' boxes

This situation often arises for small e-commerce businesses: you receive goods from French suppliers in cardboard boxes, process the goods and then ship the finished product in the same boxes, without ever buying packaging. Reusing a box you have received does not constitute placing the packaging on the market again. Conformity obligations, technical documentation and the declaration have been handled upstream when the box was first placed on the market. This does not make you a packaging manufacturer and you have no documentation to produce. This is similar to, but distinct from, making packaging from cardboard sheets (covered in the FAQ): in that case you start with a raw material; here you reuse packaging that already exists.

Reusable packaging under the regulation means systems designed for organised rotations, with specific technical criteria (deposit and return systems and returnable crates). Your shipping box does not fall into this category. The PPWR directs it towards recycling, and its transport packaging reuse targets explicitly exclude cardboard boxes. Reusing your boxes is good environmental practice encouraged by the regulation, and you have nothing to document on that account.

5The timeline from a micro-enterprise's perspective

• 10 July 2026, in France: every producer not established in France must appoint an EPR authorised representative there (Article L. 541-10-9-1). A national requirement ahead of the PPWR, applying to all EPR schemes. It has no effect if you are established in France.
• 12 August 2026: the PPWR begins to apply, harmonising the rule across Europe. For your sales in France, there is nothing to do directly: your EU packaging supplier must now maintain technical documentation and a declaration of conformity for every package it sells you, which you should check with your next order. For shipments to other EU countries, however, appointment of an EPR authorised representative (Article 45) becomes required from this date, country by country, and registration on the national producer register (Article 44) uses existing registers until PPWR registers are available.
• 12 August 2028: harmonised sorting labels on all packaging intended for final consumers. A standardised pictogram shows how to sort each component. Your supplier prints it during manufacture. You have nothing to add, provided you buy packaging produced or sold in the EU.
• 1 January 2030, at the earliest: all packaging placed on the market must be recyclable under the regulation's A/B/C classification. Packaging failing to reach at least recyclability grade C can no longer be placed on the market; material-specific criteria are expected in 2028, and multilayer or metallised packaging is most exposed. For a micro-enterprise, the impact is almost nil if you use cardboard, paper or common single-material plastics (polyethylene (PE), polypropylene (PP) or polyethylene terephthalate (PET)). Check with your suppliers if you use sophisticated packaging (complex transparent windows, metallised pouches, etc.).

The action plan for a micro-enterprise is therefore to choose packaging suppliers in the EU (ideally in your own country), join the French EPR scheme and check national registers in the countries where you sell.

6Key takeaways

• PPWR Articles 3 and 15(12) transfer conformity obligations to the packaging supplier if it is established in the EU. The transfer is complete (the supplier is recognised as the manufacturer) when it is in the same Member State as you.
• Two issues remain the responsibility of the micro-enterprise in France: the French EPR declaration (Citeo or Léko, with a flat fee for small volumes) and, as soon as you ship to another EU country, registration on the national register and a local EPR authorised representative (Articles 44 and 45).
• The transfer does not apply in one case: packaging bought outside the EU through a marketplace or dropshipping, where you become the importer.
• In practice, PPWR conformity obligations fall on manufacturers and companies placing large volumes of packaging on the market, much less on micro-enterprises selling directly.
• For a maker shipping in the EU, the cost to budget is an EPR authorised representative appointed country by country (Article 45). Make informed decisions about your shipping destinations.

Further resources

Frequently asked questions

1Do I need to draw up a declaration of conformity for my envelopes and mailing sleeves?

No, if 2 conditions are met: you are a micro-enterprise under Recommendation 2003/361/EC (fewer than 10 employees and turnover or a balance sheet total below €2 million) and your packaging supplier is established in the European Union. In that case, Article 15(12) transfers the Article 15 conformity obligations to that supplier. When the supplier is also in the same Member State as you, Article 3 recognises it as the manufacturer under the regulation's general definition. For a French micro-enterprise, a French supplier therefore provides the most complete legal position. This clause covers packaging conformity, however, rather than your EPR obligations: registration, EPR fees and the authorised representative remain your responsibility (see the dedicated section). If you print and assemble your packaging yourself from sheets bought in the Union, the approach is unchanged: the material is inherently compliant and your forming process raises a question only if you add a varnish or component compromising recyclability. Simply keep records of your raw materials' origin.

2Is buying my packaging on Amazon or a marketplace a problem?

It depends on the seller rather than the platform. A seller established in the EU (with an address in an EU country and an intra-Community VAT number) covers you under Article 15(12). A non-EU seller shipping directly to you from Asia or the United States makes you the packaging importer: you must then prepare technical documentation demonstrating conformity and keep it available for each package (material composition, recyclability tests and marking) and manage any non-conformity with market surveillance authorities. In the event of an inspection and non-conformity, each Member State sets penalties (Article 68, by 12 February 2027 at the latest). In France, the regime has not yet been set, but market surveillance authorities can already require conformity or withdrawal of the packaging. The inspection risk remains statistically low for a micro-enterprise, but the real question is the actual cost of technical documentation for each packaging type: in practice, switching to a French or EU supplier costs less than staying with a non-EU supplier and bearing the documentation obligations yourself.

3What must I do if I sell at markets or online in other European countries?

This is the regulation's most onerous obligation for a maker shipping within the EU. Since 12 August 2026, the PPWR has required two things in each country where you place packaged products on the market: registration on the national producer register (Article 44, through existing registers until PPWR registers are available) and, if you are not established in that country, appointment of a local extended producer responsibility authorised representative (Article 45). There is one representative per country, with no European one-stop shop. France has applied this rule since 10 July 2026 (Article L. 541-10-9-1 of the French Environmental Code): a seller established outside France shipping there must appoint an authorised representative, even if it already pays its EPR fees. If you are established in France, this national requirement does not affect you. You have 3 options: limit shipments to countries that justify this cost (a perfectly legitimate strategy), use specialist providers pooling representation and declarations country by country or sell through channels that handle these obligations. In December 2025, the Commission proposed suspending this authorised representative obligation until 2035 for sellers established in the EU. The Council rejected the suspension in June 2026, and Parliament is discussing a suspension limited to companies with fewer than 50 employees. Nothing has been adopted: the obligation applies, and we will update this page as soon as the situation changes. To identify your specific situation, check it with 3 questions. Our dedicated article on the EPR authorised representative sets out the steps.

4Is EPR a new tax introduced by the PPWR?

No, and this is the most widespread confusion. The packaging EPR fee has existed in France since the 1990s. It is not a tax: it finances collection, sorting and recycling of what you place on the market and is paid to a producer responsibility organisation, rather than the Treasury. The PPWR neither introduces nor increases it. What changes in 2026 is better enforcement: platforms now request the unique identifier (IDU) issued by ADEME and passed on by the producer responsibility organisation, and its absence blocks seller accounts. Many makers therefore discover an obligation that already applied to them.

5What is the total cost for a micro-enterprise?

For a micro-enterprise shipping a few parcels a week in France, allow an annual flat fee of around €100 to €150 excl. VAT (2026 schedules) and around a quarter of an hour to fill in a form when joining. At Citeo, the flat-fee declaration costs €110 excl. VAT for fewer than 10,000 UVC per year: this is the contract's minimum charge, covering the two declarations for packaging and graphic paper and allocation of the unique identifier. At Léko, the minimum charge is €95 excl. VAT and the amount is capped at €150 excl. VAT for fewer than 20,000 UVC, with paper billed separately and an exemption below 5 tonnes. Registration on Germany's LUCID register, for those selling in Germany, adds an amount of the same order. The remaining cost is time: a few hours each year for declarations. No viable shop project becomes loss-making because of this expense, which is the point to remember if worry has made you consider stopping.

6Are the 10,000 or 20,000 UVC thresholds a minimum number of sales I must reach?

No. These thresholds are ceilings for flat-fee coverage, rather than a required volume of activity. You pay the same amount whether you sell 50 items or 8,000 during the year: below 10,000 UVC, the Citeo flat-fee declaration costs €110 excl. VAT. The word minimum in the documents refers to the producer responsibility organisation's minimum charge, meaning its lowest charge, whatever your activity. Citeo's 2026 guide states this explicitly: a company placing zero packaging and less than 5 tonnes of paper on the market still pays the €110 excl. VAT under the contract. Above 10,000 UVC at Citeo, you move to the simplified declaration and the amount begins to depend on your actual volumes.

7Must I do anything if I reuse my suppliers' boxes to ship my products?

For packaging conformity, there is nothing to produce: reusing a box you have received does not constitute placing it on the market again, and the obligations (technical documentation and declaration) have already been handled upstream when it was first placed on the market. This does not make you a packaging manufacturer. There are two qualifications, however. First, you almost always add less visible packaging (adhesive tape, void fill, tissue paper and mailing sleeves): buy these from suppliers established in France or the Union and keep your invoices. Second, the French EPR declaration remains required for every parcel shipped to a private individual, whether the packaging is new or reused, and it gives you the unique identifier now requested by marketplaces.

8What should I do before my online shop's first sale?

Only one action is mandatory at launch if you sell in France: join a packaging producer responsibility organisation, Citeo or Léko, which passes on your unique identifier issued by ADEME. This is the number marketplaces request, and its absence is the most frequent reason for an account being blocked. The rest is good purchasing practice rather than a prerequisite formality: choose a packaging supplier established in the Union, triggering the micro-enterprise clause, and keep your invoices as evidence. As long as you sell only in France, you have no authorised representative to appoint.

9Can I use up packaging stock bought before 12 August 2026?

Yes, in principle. The regulation applies to packaging placed on the market from 12 August 2026, and the documentary obligations fall on the party placing it there from that date. Existing stock is normally used up, and throwing away new packaging to comply would contradict the text's objective. The useful action comes when restocking: switching to a supplier established in France or the Union transfers packaging conformity to it under Articles 3 and 15(12). There is a qualification if your stock comes directly from a country outside the Union: the purchase made you the importer at the time, and this remains true for that stock. Restocking within the Union resolves the issue for the future.

10I have been selling for years and only just discovered the PPWR: where should I start?

Proceed calmly in this order. First, check whether you already have a unique identifier: many makers have joined a producer responsibility organisation without knowing it, through their accountant or a marketplace. Next, if you have not, join Citeo or Léko; membership is completed online and the declaration can cover the current year. Also check whether you ship outside France: this is the only case that adds procedures, with a register and authorised representative per destination country. Finally, when next restocking packaging, choose a supplier established in the Union. A small business acting in good faith need not fear retrospective catch-up obligations: the administration is looking for producers missing from registers rather than makers regularising their position.

Ask Sébastien your questionA personal reply within 24 working hours

Send my questionor: [email protected]