European Parliament discusses PPWR and EPR requirements for small businesses
What happened in the European Parliament’s 16 September debate on PPWR and SMEs? We look at the concerns around EPR, authorised representatives and cross border requirements, what the Commission said, and what businesses should watch next.
European Parliament discusses PPWR and EPR requirements for small businesses
On 16 September 2026, Members of the European Parliament met in Strasbourg to discuss how the Packaging and Packaging Waste Regulation (PPWR) is affecting small and medium sized businesses, with much of the practical discussion focusing on extended producer responsibility, or EPR, requirements for smaller companies selling packaged products across EU borders.
The discussion focused particularly on the administrative processes companies may face when operating in several Member States, including national EPR registrations, reporting requirements, fees and the requirement to appoint authorised representatives.
This was a debate in the European Parliament. No changes to the PPWR were adopted as a result of this meeting, and businesses should not interpret the discussion as a suspension or change of their current obligations.
What makes the debate important is that it shows which implementation problems policymakers are hearing from businesses and some of the approaches being discussed to address them.
Why is EPR creating concerns for small businesses?
A small company selling packaged products into several EU countries can encounter different EPR requirements in each market.
Depending on the circumstances and the Member State, this can involve separate registrations, reporting processes, fees and representation requirements.
For a large company placing significant volumes of packaging on multiple markets, these processes may be absorbed into established compliance functions.
For a microenterprise or small business shipping relatively small volumes across several EU countries, the administrative cost can become significant compared with the value or volume of the products being sold.
This was at the centre of many of the concerns raised by MEPs on 16 September.
Several speakers argued that requiring small businesses to navigate multiple national systems creates barriers to cross border trade within the Single Market.
Questions were also raised about legal certainty, particularly around who qualifies as a producer for EPR purposes and which entity becomes responsible when manufacturing, selling and placing packaging on the market involve different companies.
Authorised representatives received particular attention
One of the most frequently discussed issues was the requirement for companies operating across borders to appoint authorised representatives in certain circumstances.
Several MEPs argued that requiring a small business selling limited quantities into several countries to appoint representatives in individual Member States can create disproportionate costs.
European Commissioner for Environment, Water Resilience and a Competitive Circular Economy Jessika Roswall acknowledged this concern during the debate.
She stated:
“We cannot ask small companies selling small quantities across several Member States to set up authorized representatives in each national market.”
This is an important indication of the Commission's position on the problem. It is not, however, itself a change to the law.
Businesses should continue to determine their current obligations based on the PPWR, applicable EPR legislation and the requirements of the Member States in which they place packaging on the market.
What alternatives were discussed?
Although MEPs expressed very different positions on the PPWR as a whole, several recurring ideas emerged around the administration of EPR for smaller companies.
These included:
a single digital point of contact instead of multiple national administrative processes
an EU wide registration approach
thresholds for companies placing very small quantities of packaging on the market
specific exceptions or adapted requirements for microenterprises and SMEs
changes to authorised representative requirements
greater consistency between national EPR systems
clearer guidance for businesses
increased digitalisation of EPR administration
These were proposals and political positions raised during the debate. They have not become new PPWR requirements simply because they were discussed in Parliament.
What did the European Commission say?
Commissioner Roswall acknowledged that smaller businesses can face practical difficulties when applying the new framework across several Member States.
She said that hundreds of businesses had contacted her about the authorised representative issue and that the Commission is working with stakeholders and Member States on implementation.
The Commissioner also connected the longer term development of EPR to the forthcoming Circular Economy Act, where the Commission intends to address how extended producer responsibility functions across Europe.
This is an area businesses selling into multiple EU markets should follow closely.
Does this change what businesses need to do under PPWR?
No changes to PPWR resulted from the 16 September European Parliament debate.
The PPWR generally became applicable on 12 August 2026, although individual requirements within the Regulation have different application dates and transitional provisions.
Many important packaging requirements apply in later years. Others are already relevant.
Businesses should therefore distinguish between the requirements applying to packaging itself and the administrative processes used to manage EPR obligations in different Member States.
These are related, but they are not the same thing.
A future change to an EPR registration or authorised representative process, for example, would not automatically remove requirements concerning packaging composition, restricted substances, conformity, technical documentation, supplier information or economic operator responsibilities.
The distinction between PPWR and EPR matters
The debate also illustrates why businesses should avoid treating PPWR and EPR as interchangeable concepts.
PPWR establishes a much broader framework covering packaging sustainability, conformity, information requirements, economic operator responsibilities and future requirements concerning recyclability, recycled content, reuse and packaging minimisation.
EPR concerns responsibility for packaging waste and the systems used to finance and organise its management.
For companies operating across borders, EPR can nevertheless be one of the most visible administrative aspects of packaging compliance because these systems operate at Member State level.
A debate about the difficulties associated with cross border EPR administration should therefore not be interpreted as a discussion about removing PPWR compliance requirements generally.
What should companies do now?
Businesses should continue preparing for the requirements that apply to them while monitoring developments concerning EPR administration.
A practical starting point remains:
Know your packaging. Know your role. Know your markets. Know what evidence you have and what is still missing.
Companies should understand the packaging associated with their products, identify where that packaging is placed on the market, determine their economic operator and EPR roles, and establish processes for collecting information from suppliers.
Companies selling into several Member States should also map their current EPR registrations and representation requirements rather than assuming that a future EU approach will replace them.
What should businesses watch next?
The 16 September 2026 debate did not change the PPWR, but it identified several areas that could develop further.
The authorised representative requirement is one of the most important.
The future relationship between national EPR systems is another.
Businesses should also follow the forthcoming Circular Economy Act, developments concerning the Environmental Omnibus and further European Commission guidance addressing PPWR implementation for SMEs.
For now, the key point is straightforward:
Nothing was changed by this European Parliament debate. Current obligations remain relevant.
What the discussion does show is that EU policymakers are actively examining the practical difficulties small businesses face when managing EPR requirements across several EU countries.
Whether this ultimately results in changes to authorised representatives, registration processes, thresholds or other aspects of EPR administration will depend on what is formally proposed and adopted next.
Have questions about what PPWR means for your organization?
PPWR is now applicable, but understanding what your organization actually needs to do requires looking at your role, your packaging, your suppliers and the requirements that apply now versus those that come later.
Join us for our next live PPWR Academy webinar:
PPWR in Practice: From Regulatory Requirements to Compliance Processes
We will look at how to turn PPWR requirements into practical action, including responsibilities across the supply chain, packaging data, supplier evidence, documentation and implementation priorities.
There will also be time for live Q&A, so bring your PPWR questions and real world scenarios.
Register for the PPWR Academy webinar:
https://events.ppwracademy.com/webinar/
PPWR Academy provides practical education about the EU Packaging and Packaging Waste Regulation. This article is for general informational purposes and does not constitute legal advice.
