Ljubljana: New packaging EPR guidance from the European Commission aims to ease the load on small businesses that sell across borders under the Packaging and Packaging Waste Regulation. Published in mid-October 2026, the guidance explains how extended producer responsibility should work in practice for firms that put packaging on several national markets at once.
The central message of the packaging EPR guidance is proportionality. Producers that generate less than 10 tonnes of packaging a year already receive exemptions and flexibilities under the regulation. The Commission now tells member states and producer responsibility organisations to make sure small producers do not face disproportionate burdens.
The packaging EPR guidance spells out what that could look like. Member states could waive administrative costs such as registration fees and set proportionate flat fees. Both governments and producer responsibility organisations may limit administrative procedures, for example by sparing small producers from frequent information updates, or by offering fast-track arrangements, guidance and help desks. Documentation duties can be reduced and inspections or audits kept to a minimum.
The packaging EPR guidance does not remove the basic duty to comply. Businesses must still follow national registration rules in every country where their packaging is likely to become waste. To help them check which rules apply, the Commission points to its Green Forum.
The sharper dispute concerns authorised representatives. The Commission has proposed suspending the requirement for small businesses to appoint a representative in each member state where they sell. The Council and Parliament are still examining that proposal and have reached no decision. Until they do, the Commission asks member states to enforce the rules in a constructive and pragmatic way and to avoid sanctioning operators.
Longer term, the Commission plans uniform EU-wide rules on registration and reporting. Member states would then have 18 months to set up new national registers or adapt existing ones. Once harmonised registers exist, online platforms will have to ask for an EPR registration number before a business can use their services, although that requirement is not yet enforced.
Industry reaction split along familiar lines. SMEunited urged policymakers to suspend the representative requirement and offer a grace period. Flexible Packaging Europe, CEFLEX, EUROPEN and other associations used the moment to call for a strong, harmonised and enforceable EPR framework in the upcoming Circular Economy Act, arguing that today’s national approaches are fragmented and uneven. The aim appears to be to stop small sellers from abandoning foreign markets simply because registration looks too complicated. Together, the reactions show that the packaging EPR guidance is a stopgap while the larger circular economy rulebook takes shape.
