Are micro-enterprises completely exempt from the PPWR?

No. A micro-enterprise brand owner can pass the technical documentation and conformity assessment to its packaging supplier where that supplier is located in the Union, but it must still comply with the material restrictions and with national EPR registration, reporting and fee obligations.

What is the PPWR micro-enterprise threshold?

A micro-enterprise is defined as a business with fewer than 10 employees and an annual turnover or balance sheet total of less than €2 million.

Do I lose the manufacturer shift if I buy packaging from another EU country?

No. Articles 15(12) and 21 require the packaging supplier to be located in the Union, not in your own Member State, so buying from another EU country keeps the shift. Buying from a supplier outside the EU loses it, and you become the legal manufacturer.

Are there PPWR exemptions for pallet wrapping?

Yes. A Commission decision of 25 February 2026 exempts pallet wrappings and straps from the 100% intra-company reuse requirement, on load-stability and cost grounds. The 40% transport-packaging reuse target from 1 January 2030 still applies to the operation as a whole.

PPWR Exemptions

PPWR Exemptions: Are Micro-Enterprises Exempt from Packaging Rules?

Who qualifies as a micro-enterprise, what the carve-outs cover, and how easily they are lost

By Anton Kröger3 June 20267 min read

The PPWR micro-enterprise exemption covers businesses with fewer than 10 employees and under €2 million turnover, and it shifts the manufacturer's documentation duties to your packaging supplier – provided that supplier is located in the Union. Buying from another EU country keeps the shift; buying from outside the EU loses it. No PPWR exemption removes your EPR fees.

Updated 19 August 2026: revised now that the PPWR (Regulation (EU) 2025/40) applies, since 12 August 2026, and to correct the supplier-location condition to "located in the Union".

The PPWR carve-outs are real, but narrow, and the one that matters most turns on where in the world your packaging supplier sits.

Key takeaways

Micro-enterprises (under 10 employees, <€2 million turnover) can shift the manufacturer's compliance duties to their packaging supplier.
The condition is that the supplier is located in the Union – not in your own Member State. Sourcing from another EU country keeps the shift; sourcing from outside the EU loses it.
Micro-enterprises are exempt from all the Article 29 reuse targets, and pallet wrapping, straps and cardboard boxes have their own carve-outs.
Being exempt from PPWR paperwork does not exempt you from Extended Producer Responsibility (EPR) registration, reporting or fees.

What is the micro-enterprise exemption for manufacturers?

Micro-enterprises can be relieved of the technical documentation and conformity assessment that packaging manufacturers otherwise carry. To qualify, your business must have fewer than 10 employees and an annual turnover or balance sheet total of less than €2 million, following the definition in Recommendation 2003/361/EC.

If you meet that threshold, Article 15(12) of the regulation shifts the legal responsibility for the packaging's compliance upstream: the packaging supplier is deemed to be the manufacturer. Instead of your brand acting as the manufacturer, the supplier legally assumes the role and responsibilities of the manufacturer, which means the supplier draws up the Annex VII technical documentation and issues the EU Declaration of Conformity.

Article 21 applies the same shift to a micro-enterprise importer or distributor selling packaging under its own name or trademark. That is real relief for a small Shopify or Amazon seller with no compliance department, and it has applied since 12 August 2026.

There is one condition, and it is about geography – just not the geography most summaries of this rule describe.

Does the supplier have to be in your own Member State?

No. The condition in Articles 15(12) and 21 is that the packaging supplier is located in the Union. Nothing in the text requires the supplier to be established in the same Member State as your business, so a German micro-enterprise buying custom mailer boxes from a supplier in Poland keeps the shift in full.

You lose it when the supplier sits outside the EU. If that same German micro-enterprise imports polybags directly from China, no Union-based operator is available to be deemed the manufacturer, so the legal obligations of importing packaging into the EU fall on the brand. It becomes the legal manufacturer and the importer, responsible for the conformity assessment, the technical file and the Declaration of Conformity.

The micro-enterprise shift survives cross-border sourcing inside the EU. It does not survive sourcing from a supplier established outside the Union.

If you rely on cheap non-EU packaging to protect your margins, weigh those savings against the cost of assessing that packaging yourself. Understanding exactly who the manufacturer is under the new rules is the only way to know which side of that line you are on.

Are micro-enterprises exempt from the 2030 reuse targets?

Mostly, but the exemption has two conditions. Article 29(13) exempts an economic operator from every one of the Article 29 reuse targets, which apply from 1 January 2030, only if in that calendar year it both made no more than 1,000 kg of packaging available in the Member State and meets the micro-enterprise definition. Clear either bar – the tonnage or the company size – and the exemption is gone. Where it holds, it covers the 40 percent transport-packaging target, the 10 percent grouped-packaging target and the 10 percent beverage target alike.

The regulation accepts that forcing a tiny business to build reverse logistics to collect and wash empty containers is not economically viable. So while larger operators have to move a growing share of their transport and grouped packaging into reuse systems, micro-enterprises are out of scope for those quotas. Note the limit of that relief: the Article 26 and 27 duties around reuse systems apply to anyone who makes reusable packaging available, and any single-use packaging a micro-enterprise uses still has to meet the recyclability and material-safety requirements on the PPWR deadline timeline.

Sorting through supplier rules and exemption clauses is exhausting when you are trying to scale a small brand. Let Gramta track it for you and keep your packaging record straight.

What packaging formats have specific PPWR exemptions?

Beyond company size, the regulation also grants exemptions based on the function and format of the packaging itself. Not every piece of material can logically be reduced, reused, or swapped for recycled content without compromising safety.

For example, the Article 10 packaging-minimisation rules and the Article 24 empty-space ratio, both of which arrive at the end of the decade, carve out packaging that protects products covered by a geographical indication protected under Union law or a quality scheme. That protects the traditional presentation of specific regional goods, such as certain wines or craft products.

In transport and logistics, pallet wrapping and straps are exempt from the 100% reuse requirement under a Commission decision of 25 February 2026. The Commission's own assessment was that requiring exclusively reusable stretch film and strapping would mean disproportionate adaptation costs. Cardboard boxes have a separate carve-out in Article 29(4)(d), which keeps them out of the transport-packaging reuse target. Neither carve-out touches the 40 percent transport-packaging target that applies to the operation as a whole from 1 January 2030.

Exemption Type	Who / What Qualifies	Key Limitation
Manufacturer Paperwork	Businesses with <10 staff and <€2M turnover.	Packaging supplier must be located in the Union.
Reuse Targets (2030)	Micro-enterprises that also stay under 1,000 kg of packaging a year in the Member State (Article 29(13), both conditions).	Single-use packaging must still meet the design rules.
Transport Reuse	Pallet wrapping, strapping, and cardboard boxes.	The 40% transport reuse target still applies overall.
Empty Space Limits	Products with protected EU geographical indications.	Cannot be used as a loophole for standard retail goods.

Do PPWR exemptions also apply to EPR fees?

No. This is the most dangerous misconception among small e-commerce sellers. Being relieved of the technical design paperwork under the PPWR does absolutely nothing to relieve you of national Extended Producer Responsibility duties.

The PPWR and EPR are two different sets of duties, sitting on two different roles. The PPWR's Article 15 conformity duties sit on the manufacturer; the EPR duties in Articles 44 and 45 sit on the producer. Even if your supplier handles your Declaration of Conformity, if you ship that packaged product to a consumer in France or Germany you are the producer in that destination country. You must register with the local authorities for Extended Producer Responsibility and pay fees on the weight of the cardboard and plastic you sent there.

Since 12 August 2026 there is a second reason to be careful with the word "exempt". Article 45(1) puts the EPR obligation on producers with no turnover or volume de-minimis in the Regulation itself, so a national "below X you are exempt" rule can no longer be relied on to remove it. What the Regulation does give small producers is Article 44(8): if you first made available under 10 tonnes of packaging in a Member State in a calendar year, you report a reduced data set rather than the full one.

Article 44(8)'s reduced data set is simplified reporting, not an exemption, and the annual filing deadline of 1 June still applies. In practice you still register and report through the existing national register or scheme, because the harmonised registers in Article 44(1) wait on an implementing act that has not been adopted.

Do not let a PPWR micro-enterprise exemption lull you into a false sense of security about your cross-border waste fees. If you ship internationally, you owe data. Get started with Gramta to automate your EPR reporting across Europe.

Sources:

Frequently asked questions

Are micro-enterprises completely exempt from the PPWR?: No. A micro-enterprise brand owner can pass the technical documentation and conformity assessment to its packaging supplier where that supplier is located in the Union, but it must still comply with the material restrictions and with national EPR registration, reporting and fee obligations.
What is the PPWR micro-enterprise threshold?: A micro-enterprise is defined as a business with fewer than 10 employees and an annual turnover or balance sheet total of less than €2 million.
Do I lose the manufacturer shift if I buy packaging from another EU country?: No. Articles 15(12) and 21 require the packaging supplier to be located in the Union, not in your own Member State, so buying from another EU country keeps the shift. Buying from a supplier outside the EU loses it, and you become the legal manufacturer.
Are there PPWR exemptions for pallet wrapping?: Yes. A Commission decision of 25 February 2026 exempts pallet wrappings and straps from the 100% intra-company reuse requirement, on load-stability and cost grounds. The 40% transport-packaging reuse target from 1 January 2030 still applies to the operation as a whole.

Reviewed 19 August 2026 by Daniel Vaknine