Yes, in principle: the PPWR provides no general size exemption from qualitative obligations (recyclability, recycled content and labelling). However, if you are a micro-enterprise (fewer than 10 employees and turnover below €2 million under Recommendation 2003/361/EC) and buy packaging from a supplier established in the EU, Article 15(12) transfers conformity obligations to that supplier; Article 3 even reclassifies it as the manufacturer if the parties are in the same Member State. Your real issue then becomes joining the French EPR scheme (Citeo or Léko, with a flat fee for small volumes) and registering on the national packaging registers in the EU countries where you sell. See our dedicated article: PPWR: what obligations apply to a micro-enterprise or independent maker?.
Read the source article: Who is affected by PPWR? Company roles and obligations
