Germany Proposes Exemption for Small Traders Under New E.U. Packaging Rules

Germany is seeking changes to the European Union’s new packaging rules to reduce the burden on small businesses that ship goods to other member states, arguing that the current system could create costly barriers for low-volume traders.

The Federal Environment Ministry said the German government presented a concrete amendment proposal in Brussels on Monday at a preparatory meeting on the EU’s planned environmental simplification package, often referred to as the Environment Omnibus. The ministry said the goal is to ease implementation of the EU Packaging and Packaging Waste Regulation, or PPWR, especially for small merchants that fear they may no longer be able to send goods to customers in other EU countries under the current requirements.

At the center of the dispute is a rule that would require traders to appoint an authorized representative in every EU country to which they send packages. According to the ministry, each appointment carries a fee. Berlin said many small sellers, particularly those that make only limited cross-border shipments each year, see that obligation as a serious administrative and financial burden.

Germany’s proposal would exempt traders that place less than 10 tons of packaging on the market each year from having to appoint an authorized representative. It also calls for suspending registration in the new system until mid-2028, pending the launch of a central European registration system for producers.

The ministry said those changes would have to be made in the PPWR itself and could not be resolved adequately through national legislation. It said the government is now trying to build support among other member states so that the regulation can be adjusted as quickly as possible.

The ministry’s statement reflects growing pressure from smaller businesses that sell across borders inside the EU, many of them through online channels, and say the new rules risk adding bureaucracy that is disproportionate to the scale of their operations. German officials said they want relief focused on companies that send only a small number of parcels abroad each year, rather than a broader rollback of the regulation.

The PPWR is a major EU law intended to create a single framework for the full life cycle of packaging. It replaces a patchwork of national rules with common standards and targets across the bloc. The broader aim is to increase reuse and recycling and keep more packaging materials in circulation as secondary raw materials, while reducing dependence on imported resources.

Germany did not challenge those environmental goals in its statement. Instead, it said the implementation of the law should not create new bureaucratic obstacles for businesses. That position suggests Berlin is trying to balance support for the regulation’s circular economy objectives with pressure from domestic companies that say compliance costs could interfere with routine trade inside the single market.

The ministry’s statement comes less than a month after it announced that the European packaging regulation had entered into force on Aug. 12. The latest move shows that even after the law took effect, member states are still pushing for changes to how some of its obligations will work in practice.

If Germany’s proposal gains support, it could matter for small beverage companies as well as other consumer goods sellers. Smaller wine, beer, and spirits producers that ship directly to customers or retailers in other EU countries often rely on bottles, cans, transport cartons, and other packaging covered by the regulation. For low-volume operators, the cost of appointing representatives in multiple countries and handling separate registration duties could become a meaningful compliance expense. A temporary delay and a narrow exemption could therefore reduce administrative pressure for some businesses in the drinks trade, particularly those using cross-border e-commerce or specialized export channels.

It is not yet clear how much backing Germany can win from other governments or how quickly any amendment could move through the EU process. The ministry said it is working to secure a majority of member states behind the proposal, an indication that negotiations are now shifting from national criticism to a coordinated attempt to revise the regulation at the European level.

For now, Germany’s position is that the PPWR should remain in place as a common European framework, but that its rollout needs adjustment so small companies are not priced out of cross-border trade by compliance steps tied to packaging.