Question
Am I exempt from EU packaging EPR as a micro business?
Reviewed 2026-08-15
Commonly said
Micro-enterprises are exempt from the new EU packaging rules.
No. There is no general micro exemption from EPR registration.
The test
- Fewer than 10 staff, and
- Turnover or balance sheet of €2m or less.
What you do get
- Your EU supplier can hold the technical paperwork about the packaging design instead of you.
- Some easing of the single-use and reuse requirements.
What you do not get
- You still have to register with each country's scheme.
- You still have to report how much packaging you send, and pay the fees.
- Germany has no minimum at all. One parcel and you have to register.
Status of proposed relief
- A suspension proposal covered EU-established producers only.
- Council negotiations on it were discontinued on 24 June 2026.
- An ENVI committee vote on narrowing relief to micro and small enterprises was expected 1 October 2026 — after the deadline.
- Plan on the rules as they stand.
Sources
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