PPWR and the People Behind the Parcels
Voices of European Business on the PPWR: From a Jewellery Maker Shipping 19 Parcels a Year to DHL, Antique Dealers and the Semiconductor Industry
My previous article, Four Grams of Bubble Wrap and the European Single Market, ended with a few questions.
I had sent them to the European Commission.
I did eventually receive a reply. Just not to the questions.
The Commission’s press service explained that reporters are expected to prove their professional status with a valid national press card or a press card issued by the International Federation of Journalists. I have neither. Instead, I was sent links to a recent European Parliament debate on the PPWR.
So the questions about the practical consequences of the Regulation remained unanswered.
The people dealing with those consequences, however, proved rather more forthcoming.
By then, the PPWR had already escaped the relatively quiet world of regulations, recitals and implementing acts. Across professional forums, social media and business communities, people were comparing national requirements, calculating costs, looking for authorised representatives and trying to work out what exactly they were supposed to do with a cardboard box.
Some were also beginning to decide where they would simply stop selling.
For one month, there was an official place to say all this. The European Commission had opened a public consultation on the rules for national registers of producers.
The response was difficult to mistake for indifference.
More than 7,000 submissions arrived from Europe and beyond. They came from people working alone, family businesses, manufacturers, retailers, collectors, artists, restorers, trade associations, chambers of commerce and major industries.
DHL responded. So did representatives of the semiconductor industry and antique dealers.
And so did a woman in Denmark who sent 19 parcels to other EU countries in an entire year.
The consultation received 7,133 unique feedback submissions.
But the number is not the most interesting part of this story.
The submissions are.
They do not divide neatly into small business versus big business. Nor do they all demand the same solution. Some want exemptions. Some want thresholds based on packaging volumes. Some want one EU registration system instead of a collection of national ones. Industry organisations raise questions about reporting, data granularity and technical documentation that look very different from the problems of a person packing orders at home.
Yet one problem appears in remarkably different places.
A business can have millions in turnover and put only a few kilograms of packaging onto the market of a particular Member State. A sole trader can use barely a kilogram of packaging in a year and still depend on customers scattered across twenty countries.
The environmental quantity can be tiny.
The administrative geography is not.
Nineteen parcels
Let us start in Denmark.
A self-employed jewellery maker counted how much cross-border trade she actually did in one year.
The answer was 19 parcels.
Seven went to Germany. Eight to Sweden. Two to France. One to Belgium. One to the Netherlands.
A typical shipment used around 55 grams of packaging.
In other words, her cross-border business produced roughly one kilogram of packaging in a year.
She is also the designer, maker, photographer, marketer, customer service department, accountant and administrator of the business.
Those 19 parcels represented around a quarter of all her shipments.
Now look at them again.
Five Member States. Nineteen parcels. About one kilogram of packaging.One kilogram is not very impressive as an environmental problem.
Spread it across five national systems, however, and it develops considerable administrative potential.
The jeweller asked for harmonised registration, genuinely simplified rules for very low volumes and a system that does not require a one-person business to navigate separate national procedures for a handful of sales.
Otherwise, there is an easier solution.
She can stop accepting those orders.
The packaging problem then disappears completely.
So do the customers.
The €20 part that stayed in Germany
In Spain, vintage-audio restorer Wim Romeijn described another cross-border transaction.
Or, more precisely, a transaction that never happened.
He needed a few clamp nuts for a piece of vintage audio equipment and found them on eBay, offered by a small German business.
The parts cost around €20 and weighed less than 100 grams.
The German seller refused to ship them to Spain, citing the cost of complying with packaging rules, according to Romeijn.
The part stayed in Germany.
This is an interesting achievement for a circular economy.
One European business was repairing old equipment instead of replacing it. Another European business had the part required to keep that equipment working.
Both were inside the European Single Market.
The part stayed in Germany.
No parcel was sent. No delivery vehicle carried it. No new packaging became waste.
An impeccable environmental result.
Unfortunately, the old equipment still needed its parts.
And this is where the PPWR story becomes larger than packaging.
A transaction worth €20 is irrelevant to European trade statistics. Nobody announces a crisis because a few clamp nuts failed to cross the German-Spanish border.
The German seller lost €20. The Spanish restorer lost the parts he needed to keep an old machine working.
Now imagine the consequences if the same thing happens across millions of transactions in the European Single Market.
Australia may be easier
Paula is 75 and lives in Spain.
She makes fabric accessories and sells them online. Her annual shop sales are around €3,000–€4,000.
She had been selling to customers elsewhere in Europe.
Germany's packaging compliance had previously cost her around €15 a year, according to her submission. What she could not justify was multiplying registrations and costs across countries before knowing whether she would make even one sale there.
So she disabled EU sales outside Spain.
Her description of the result needs very little editorial assistance:
“EU membership makes it easier for us to sell to Australia than to the community we belong to.”
There is not much to improve in that sentence.
A 75-year-old European craftswoman has found Australia easier to reach than Europe.
Antiques refuse to become standard
Then came the antique trade.
The Czech association representing antique dealers, private galleries, antiquarian businesses, auction houses, collectors, experts and restorers explained that many of its members send only a few parcels a year to individual Member States.
Their destinations change. Their volumes change.
And, inconveniently, so do their objects.
Antiques are rather bad at standardisation.
A porcelain figure does not become rectangular because a packaging regulation would find that helpful. A chandelier cannot be compressed into a convenient shipping format. A nineteenth-century vase may require what looks like a ridiculous amount of empty space around it for one very practical reason:
the buyer would prefer to receive a vase.
Not a box of archaeological fragments.
The association specifically warned that antiques and works of art may require larger or atypical packaging because of their artistic, cultural and financial value.
It made another point.
Its members already reuse packaging extensively.
“We hardly use new packaging materials.”
This should be the easy part of an environmental story.
An old object is sold instead of discarded. An old cardboard box is used again. Old cushioning gets another journey.
An admirable environmental practice. Until someone asks for the paperwork.
The cardboard box with a documentation problem
One company described receiving goods in a perfectly usable carton.
It wanted to use the carton again.
This would normally be called reuse.
The company says that when it sought guidance about conformity requirements, it was advised not to send goods again in the supplied carton because compliance could no longer be assured.
To be clear, this does not establish that the PPWR simply prohibits the reuse of cardboard boxes.
It establishes something more interesting.
A company trying to comply with environmental packaging rules asked whether it could reuse existing packaging and came away believing that the safer compliance option was not to reuse it.
The company pointed out the obvious consequence: replacing usable packaging in order to obtain clearer conformity documentation can create more packaging waste, not less.
A cardboard box, it seems, can have a second life.
Its paperwork may be less fortunate.
And suddenly my four grams of reused bubble wrap from the previous article do not look quite so eccentric.
There was the old tape attached to it. The unknown material. The question of who is supposed to identify, weigh and document what.
I am a vintage dealer.
I still do not, as a rule, perform polymer analysis on somebody else’s adhesive tape.
Apparently, I am not the only person who has wondered about it.
A German promotional-products wholesaler employing 18 people raised questions about the technical documentation required for cartons, tapes and pouches. The company suggested that navigating these requirements would take something approaching twenty years of education in chemistry and physics.
Another respondent asked a considerably simpler question:
Is somebody eventually going to chemically analyse the boxes and tape?
At some point, satire becomes difficult.
The consultation has already written it for you.
A market for the biggest players?
The Professional Chamber of Thessaloniki was the only Greek chamber — and one of only four chambers in Europe — to respond to the consultation.
It warned that for businesses sending only small amounts of packaging abroad, the fixed costs of registration, reporting and authorised representatives can make cross-border sales simply not worth making.
And there is an obvious beneficiary when smaller businesses retreat from the European market: the international giants that can afford the bureaucracy.
The Chamber proposed a one-tonne annual threshold per Member State, simplified reporting, proportionate fees and a single European system instead of multiple national ones.
And then there is DHL
DHL also responded to the consultation.
In a separate position published in September, the logistics group called for EPR requirements under the PPWR to be harmonised and simplified, specifically to reduce bureaucracy for companies operating across borders and strengthen the European Single Market.
A jewellery maker sending 19 parcels a year and DHL operate on rather different scales.
The problem they identified is remarkably similar.
But not everything in those submissions lends itself to satire.
These are only a few of the thousands of submissions received by the European Commission. It is impossible to include every account of a business facing closure, a family worried about losing its income, or a craftsperson wondering whether years of work can survive another layer of administrative costs.
Some respondents wrote in the measured language of business associations. Others wrote with the anger and desperation of people who could see their livelihoods slipping away.
Their circumstances differed enormously. But one demand kept returning: make it possible to trade across European borders without being overwhelmed by the cost of complying with multiple national systems.
The Commission asked for feedback on national producer registers. What it received was also a warning about the future of the European Single Market.
journalist, vintage & antique dealer, founder of Morante Boutique