Today, the EU’s new packaging rules enter into force. A Swedish small-business owner who sells goods to customers in several EU countries may need to register, report and pay fees in each country – and in some cases appoint local representatives. The European Commission itself has warned that the rules could become an unreasonable burden.

On Wednesday, August 12, large parts of the EU’s new regulation 2025/40 PPWR Packaging and Packaging Waste Regulation enter into force.

The regulation states that every producer selling goods within the EU is responsible for registering and reporting which packaging materials they use, as well as the quantity of packaging material. In addition, producers must finance the management of the packaging waste generated.

The purpose of the new regulation is to reduce the amount of packaging waste, increase recycling and harmonise the rules within the EU’s internal market.

But for companies that sell goods directly to consumers in other Member States, the rules also introduce new administrative requirements. It is above all the rules on extended producer responsibility that risk becoming costly for smaller online retailers.

Under the PPWR, everyone engaged in cross-border mail-order or e-commerce sales to end consumers must comply with the regulation’s requirements. This means, among other things, that every such business owner must register in each individual recipient country’s producer register and join each individual recipient country’s recycling or producer responsibility system, report the quantities and types of packaging materials in each individual recipient country, pay environmental or recycling fees in each individual recipient country and appoint a local authorised representative in each individual recipient country.

A register in every country

One of the requirements that risks hitting smaller retailers particularly hard is that the PPWR states that all producers must register in each individual Member State in whose market they make packaging or packaged products available.

For a business owner who, for example, operates a Swedish online shop and sells directly to private individuals in several other EU countries, this means that there will be no common EU register – instead, there are 27 separate national systems that the business owner must adapt to.

Companies must also report which types of packaging they use and how large the quantities of each type are – broken down by country. The company is also required to comply with each country’s producer responsibility requirements.

Local representatives become an expensive affair

One of the most debated parts concerns authorised representatives for producer responsibility.

The PPWR contains rules meaning that a business owner who sells packaged products directly to end customers in another Member State must appoint an authorised representative for producer responsibility in that country – a requirement that hits small businesses particularly hard.

A large international online retailer such as Amazon can spread the cost of legal services, registration, reporting and regulatory compliance across millions of sales.

For a small business owner who sells individual products to private individuals in another EU country through, for example, the Etsy marketplace, the same administrative requirements can instead become disproportionately expensive – so expensive that it is no longer profitable to sell the products.

The consequence is that small producers risk being driven out, with trade then becoming concentrated among the already large players.

The European Commission has seen the problem

The PPWR is entering into force even though the threat to small businesses has been identified. In December 2025, the European Commission presented a proposal under which the requirement for local representatives in each Member State would be postponed until January 1, 2035. The Commission’s justification was that the requirements of the new regulation impose an unreasonable administrative and financial burden on small businesses engaged in cross-border trade.

But the proposal never became more than a proposal.

This means that the PPWR regulation and its requirements apply from August 12, 2026, while negotiations on possible relief for small businesses continue.

One internal market – 27 administrative systems

The EU’s internal market was created, among other things, to make it possible for businesses to sell goods across national borders without encountering 27 different national trade barriers.

The PPWR does provide a common EU legal framework, but producer responsibility will now be organised through 27 national registers and systems.

For a Swedish small-business owner, this may therefore in practice mean that a sale to, for example, France, Germany, Spain and Italy requires handling in four different national systems – with different authorities, producer responsibility organisations, reporting requirements and fee structures.

EU – a market for the big players?

The regulation creates a paradoxical effect when the same EU that was created to remove trade barriers introduces regulations that create new administrative barriers for the businesses the European internal market was intended to help.

In practice, only companies that can afford to handle the regulation benefit. Large e-commerce platforms have access to lawyers, specialist staff and automated systems.

Small-business owners do not have the same resources and may therefore have to decide simply not to sell their goods to other EU countries. There are already extensive discussions among small online retailers on social media about this very problem, although the actual impact of the PPWR cannot yet be measured.

Stricter rules are coming

August 12 is only the beginning.

The PPWR contains a number of additional requirements that will enter into force gradually. Among other things, a requirement for harmonised packaging labelling will be introduced from 2028. From 2030, requirements for recycled material in certain plastic packaging will apply, and from 2035 the requirements for packaging to be recyclable at scale will be tightened. From 2038, packaging that does not meet certain recyclability classes will be prohibited.

Sweden voted yes

The EU regulation that entered into force on Wednesday is binding and therefore replaces many of the current Swedish provisions, while Swedish legislation is being adapted to complement the EU rules.

Eleven of Sweden’s 21 Members of the European Parliament (S+V+MP+L) voted in favour of the final packaging regulation. Five voted against (C+SD), and five abstained (M+KD). When the issue of the PPWR was subsequently finally decided in the Council of the European Union, the Swedish government voted in favour.