Musterschreiben - PPWR mittelstandsfreundlich und einheitlich umsetzen (Englisch)

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E-Mail: Jessika.Roswall@ec.europa.eu
Postadresse:
Ms. Jessika Roswall
Commissioner for Environment, Water Resilience and a Competitive Circular Economy European Commission
Rue de la Loi 200
1049 Brussels
Belgium
Dear Ms. Roswall,
As a medium-sized company based in Germany, I am writing to express our serious concerns and to request urgent action. Since 12 August 2026, the European Packaging and Packaging Waste Regulation (PPWR) has generally applied. Its practical implementation is creating significant organisational and financial burdens and is putting cross-border trade within the European Single Market at risk.
We fully support the objectives of the PPWR: reducing packaging waste, conserving resources and strengthening the circular economy. However, achieving these objectives requires procedures that are clear, proportionate and practicable across the European Union. At present, this is not sufficiently the case.
The PPWR introduces new obligations for producers, importers, suppliers, distributors and manufacturers. In practice, however, responsibilities along complex supply chains often remain unclear. This is particularly challenging for transport packaging, where it is frequently difficult to determine when packaging has reached its final form. Article 21 creates further scope for interpretation, as producer obligations may already be triggered where there is merely a possibility that the conformity of packaging could be affected. At present, this is leading, among other issues, to inconsistencies between the position of Germany’s Central Agency Packaging Register and the EU Commission’s FAQs of August 2026.
Compliance with the documentation and verification requirements involves extensive information exchange throughout the supply chain. We are already being confronted with substantial data requests. In many cases, information is being requested even though the corresponding legal basis has not yet been established, for example regarding recyclability and minimum recycled content. For small and medium-sized enterprises in particular, this ties up resources that are then no longer available for core business operations.
Although the PPWR applies directly in all Member States, extended producer responsibility continues to be organised at national level. Companies must therefore deal with separate registers and systems in each Member State concerned. For companies operating across borders, this results in a highly fragmented and difficult-to-manage framework. Further burdens arise from the planned mandatory appointment of authorised representatives.
We therefore call for the following measures:
  1. An EU-wide One-Stop Shop that centrally consolidates registration, quantity reporting and EPR processing and replaces national authorised representative requirements.
  2. Effective EU-wide de minimis thresholds that exempt small packaging quantities and individual deliveries from disproportionate obligations.
  3. A clear, legally binding and EU-wide uniform clarification of roles, particularly with regard to shipping packaging and the combination of finished packaging components.
  4. Proportionate, predictable and EU-wide uniform costs that do not place an excessive burden on small packaging quantities.
The European Single Market must not become accessible only to large companies with dedicated legal and compliance departments. We therefore urge you to take immediate steps towards a uniform, legally certain and economically viable solution. Otherwise, companies may withdraw from markets, jobs may be lost and, in individual cases, economically sound businesses may be forced to cease operations.

Yours sincerely

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