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PPWR exemptions for micro-enterprises: what changes and what does not

The Packaging Regulation (EU) 2025/40 has a few exemptions for micro-enterprises: businesses with fewer than 10 persons and an annual turnover or balance sheet total of at most EUR 2 million (Recommendation 2003/361/EC as applicable on 11 February 2025). Most of its rules apply whatever the size of the business.

Checked against the sources on 19 October 2026

Who is the manufacturer

Normally the manufacturer is the business that has the packaging or packaged product designed or made under its own name or trademark. It must make sure the packaging meets Articles 5 to 12, carry out the conformity assessment and draw up the EU declaration of conformity (Article 15).

If that business is a micro-enterprise and its packaging supplier is located in the same Member State, the supplier is the manufacturer instead (Article 3(1), point 13(b)). For the duties of Article 15 a supplier anywhere in the EU is enough (Article 15(12)), and the same applies to micro-enterprises that are importers or distributors (Article 21). The Commission's guidance of 10 June 2026 adds that the supplier's own size does not matter, while a brand owner that is not a micro-enterprise gets no relief even if its supplier is one.

So a micro-enterprise buying its packaging from an EU supplier can leave the declaration of conformity to that supplier. A brand owner outside the EU whose packaging supplier is also outside the EU stays the manufacturer.

Other exemptions

  • Re-use targets from 1 January 2030 (Article 29): not for a calendar year in which the business is a micro-enterprise and made at most 1,000 kg of packaging available in a Member State (Article 29(13)).
  • Re-use offer for take-away food and drink by 12 February 2028 (Article 33): not for final distributors that are micro-enterprises (Article 33(4)).
  • Banned packaging formats of Annex V from 1 January 2030 (Article 25): Member States may allow micro-enterprises to keep using them where there is no technically feasible alternative or no access to a re-use system (Article 25(4)).

What still applies

There is no micro-enterprise exemption from producer registration, extended producer responsibility or the authorised representative a seller outside a country must appoint there (Articles 44 and 45). National laws can set reporting thresholds, as Germany does for its declaration of completeness: see packaging EPR in Germany.

Business size under Recommendation 2003/361/EC counts partner and linked enterprises; a franchisee whose franchisor holds 25% or more, or controls it, adds the franchisor's figures. More on the PPWR and the free declaration of conformity.

Check which other EU rules apply

Sources