Four Grams of Bubble Wrap and the European Single Market
How the EU’s new PPWR, EPR rules and Authorised Representative (AR) requirement are making cross-border trade unaffordable for micro-businesses
This morning, I woke up and remembered that I had something important to do. There were new European Union rules to follow.
I sell vintage objects from France.
Occasionally, someone in Germany buys one.
I put the object into a cardboard box that has already travelled through Europe at least once. I add a piece of bubble wrap that arrived with something I bought on Vinted.
This is where European environmental regulation becomes interested in me.
The box is packaging.
The bubble wrap is packaging.
The tape is packaging.
And when I send all of this to Germany, somebody needs to know how much packaging I have sent.
By weight.
Fair enough.
So let us weigh the bubble wrap.
There is, however, a small problem.
The bubble wrap is used.
It came wrapped around something I bought on Vinted. There is still some old adhesive tape stuck to it.
Should I weigh the tape too?
Presumably.
It is packaging.
But the tape is attached to the bubble wrap.
Should I remove it first?
Damn. Some of it comes off.
Some of it does not.
If I remove the tape, should I weigh it separately?
And what about the piece that tears in half and remains attached to the bubble wrap?
Then I reuse the bubble wrap myself and add a fresh piece of tape.
The whole thing weighs four grams.
At which point, exactly, should I weigh my four grams?
Perhaps I should leave the old tape where it is, add the new tape and weigh the whole thing as plastic.
That seems sensible.
Unless the bubble wrap and the adhesive tape belong to different reporting categories.
In that case, I may need to establish the material composition of a piece of tape that somebody else stuck to my bubble wrap before sending me something I later bought second-hand on Vinted.
Damn. I am a vintage dealer…
Unfortunately, weighing the bubble wrap is the easy part.
How to pay a very small bill
The principle behind Extended Producer Responsibility, or EPR, is not particularly difficult.
Packaging becomes waste.
Waste has to be collected and treated.
The businesses putting packaging on the market contribute towards that cost.
Fine.
For a micro-business sending very small quantities of packaging to another country, the recycling contribution itself can be very small.
The interesting part is what may be required in order to pay it.
Since 12 August 2026, the EU's new Packaging and Packaging Waste Regulation, or PPWR, has applied across the European Union.
It includes national producer registration requirements.
It also includes Article 45(3).
This is where things become more ambitious.
Under this provision, certain businesses selling directly to consumers in another EU Member State can be required to appoint an authorised representative for extended producer responsibility in the country where they are selling.
Let us return to my parcel.
I am in France.
My customer is in Germany.
My business is registered in France.
The German system needs information about the packaging I send to Germany and the relevant EPR obligations must be fulfilled.
And for this, I may need an authorised representative in Germany.
The vintage plate inside the box may be worth €30.
The bubble wrap may weigh four grams.
The authorised representative, unfortunately, is not priced by the gram.
This raises a rather simple question.
I understand why I should contribute towards the cost of dealing with packaging waste.
What I do not understand is why I may need to pay another company in Germany in order to do so.
What exactly happens between my kitchen scales in France and the German reporting system that requires an intermediary?
And what does this intermediary do for the environment?
Perhaps the answer is enforcement.
But that creates another small problem.
I am not in China.
I am not in the United States.
I am in France.
My business is registered in France. It can be identified in France. It operates under French and European law.
France and Germany are both members of the European Union.
This arrangement even has a name.
The Single Market.
So why does Germany need a separate representative to deal with a business already established inside the same legal and economic union?
We have asked the European Commission.
There is another small problem.
The European Commission has already asked itself something remarkably similar.
On 10 December 2025, eight months before the PPWR became applicable, the Commission proposed suspending the mandatory authorised-representative requirement for businesses established within the EU.
Its explanation was interesting.
The Commission said the requirement could create "unnecessary administrative burden."
For SMEs, having to appoint authorised representatives in multiple Member States represented "a significant challenge in terms of costs."
The Commission noted that a business could face this requirement in up to 26 Member States.
It said this was "hampering the competitiveness" of European producers.
And it referred to "unintended barriers for the internal market."
These are not the words of an angry Etsy seller.
They are the words of the European Commission.
The Commission therefore proposed suspending the requirement for EU-established producers. It said doing so would immediately reduce costs and administrative burden.
There was, however, a timing issue.
The proposal to suspend the requirement did not become law before 12 August 2026.
The requirement became applicable.
So the sequence is now rather unusual.
The European Commission identified an unnecessary administrative burden.
It identified significant costs for SMEs.
It identified a problem for European competitiveness.
It identified possible barriers to the internal market.
It proposed suspending the requirement.
Then 12 August arrived.
The proposal has not become law.
The requirement has become applicable.
First find a customer. Or perhaps not
There is another question we have asked the Commission.
It concerns the first customer.
A micro-business normally discovers a foreign market in a rather simple way.
You put something on the internet.
You wait.
One day, a German buys it.
Congratulations.
You have discovered the German market.
This model has worked reasonably well for the internet.
But national registration and authorised-representative requirements create an interesting question.
What happens before the first sale?
Imagine a French micro-business whose products can be ordered by customers throughout the EU.
It has never sold anything to Germany.
It does not know whether anybody in Germany wants its products.
Does it have to register there and arrange an authorised representative before the first German customer can buy?
If the answer is no, then we need to know exactly when the obligation begins.
If the answer is yes, we have invented a rather unusual method of market research.
Register.
Arrange compliance.
Pay for a representative.
Then wait to see whether anyone wants to buy anything.
First pay for access to the market.
Then discover whether you have a market.
We have asked the European Commission which interpretation is correct.
Building a border without building a border
Germany is only one country.
A French micro-business selling online can have customers in many EU countries.
A few in Germany.
One in Spain.
Three in Belgium.
Perhaps somebody in Austria next Thursday.
This is one of the useful features of the Single Market.
A very small business does not need millions of customers in another country. It may need five.
The problem with fixed national compliance costs is that five customers can become economically indistinguishable from no customers at all.
For a multinational company, multiple national compliance systems are work for a compliance department.
A micro-business often has a compliance department too.
It is the same person who takes the photographs.
And answers the messages.
And finds the box.
And packs the plate.
And goes to the post office.
And is currently standing in the kitchen trying (Damn!) to remove old adhesive tape from four grams of bubble wrap.
If selling a €30 object into another Member State requires fixed administrative costs that exceed the profit from selling there, the solution is obvious.
The business stops selling there.
No customs post is required.
No barrier needs to be built.
Nobody needs to check a passport.
The seller simply clicks:
Shipping to Germany: unavailable.
The national border has returned.
It just has better software.
Back to the bubble wrap
We have asked the European Commission why an EU-established micro-business needs an authorised representative in another EU country.
We have asked what environmental benefit that representative produces.
We have asked how fixed compliance costs can be proportionate when a business sends only a few kilograms of packaging to a country in an entire year.
We have asked what happens before the first customer.
And we have asked a particularly simple question.
If the Commission had already concluded in December 2025 that the requirement created unnecessary administrative burden, significant costs for SMEs and problems for the Single Market, why was it still allowed to become applicable eight months later?
We will publish the Commission’s response if we receive it.
For the moment, I still have a parcel to send.
The box has been used before.
So has the bubble wrap.
The old tape is still attached.
I have not yet decided whether to remove it.
The bubble wrap still weighs four grams.
The border, apparently, weighs considerably more.
The European Commission is currently collecting public feedback on the implementation of the PPWR and national producer registers. The consultation closes on 10 September 2026.
EU businesses and citizens affected by these rules can submit their feedback directly to the European Commission until that date.
journalist, vintage & antique dealer, founder of Morante Boutique