EU Council approves one-tonne EPR exemption to cut cross-border costs for small packaging producers

The European Union Council has officially adopted its negotiating stance to suspend a highly contested administrative requirement under the Packaging and Packaging Waste Regulation (PPWR). As of October 21, 2026, member states have agreed to exempt businesses that place less than one tonne of packaging per calendar year on a foreign EU market from the obligation to appoint an authorized Extended Producer Responsibility (EPR) representative in that specific country.

Relief for cross-border trade and micro-brands

Since the PPWR became applicable across the European Union on August 12, 2026, the requirement to appoint a local representative in every member state where a company sells packaged goods has created a severe bottleneck. For small converters, micro-brands, and e-commerce players, the administrative overhead and registration fees often threatened to exceed the commercial value of their cross-border sales. Industry groups, including SMEunited, had been actively lobbying for a suspension, warning that the rule effectively fragmented the single market for smaller players.

The Council's mandate directly addresses this friction. By setting a one-tonne threshold per calendar year, the amendment allows small-scale producers to maintain their export activities without facing disproportionate compliance costs. This threshold is particularly relevant for specialty packaging converters and independent brands whose international footprint relies on low-volume, high-value shipments.

Safeguards and future reviews

While the exemption provides immediate structural cost relief, the Council has integrated specific control mechanisms to prevent abuse. The mandate includes a safeguard clause that allows authorities to revoke the exemption if a producer is found to be in breach of fundamental EPR obligations, ensuring that the financial responsibility for end-of-life packaging collection and recycling is not entirely bypassed.

• Threshold: Less than 1 tonne of packaging per calendar year in a specific member state.
• Exemption: No need to appoint an authorized EPR representative in that state.
• Review timeline: The European Commission must review the duration of this suspension by December 31, 2030, ahead of its scheduled expiry in 2032.

For the packaging supply chain, this legislative adjustment represents a pragmatic compromise between the ambitious circular economy targets of the PPWR and the operational realities of small businesses. Converters and brands operating below the one-tonne limit can now redirect resources from administrative compliance back into sustainable packaging design and core business operations, while the broader EPR framework continues to regulate the macro-volumes of the European packaging market.