The impact of EU PPWR and EPR to my creative business
First a few facts...
There are 1.1 million micro creative businesses in the UK, offering over 2.4 million jobs in the creative sector (outperforming the overall economy in terms of growth and value added).
In 2024, this sector generated over £145 billion gross added value to the UK economy and exported over £10.2 million in creative goods to the EU.
What is PPWR?
The EU Commission brought into effect the Packaging and Packaging Waste Regulation on 12 August 2026, which effects all businesses putting product packaging into the EU marketplace, so UK, ROW and even other EU countries must adhere to this new regulation.
The European Commission introduced this regulation to replace a directive, to address the environmental challenges associated with packaging waste. Its aim is to promote sustainable packaging practises and harmonise rules across member states to reduce unnecessary packaging, especially single use plastic packaging. It also aims to increase recycling and standardise labelling and reuse requirements.
For businesses’ product packaging and shipping packaging, the EU Commission insist packaging must be recyclable, minimally wasteful and clearly labelled for easy recycling. Packaging is assessed on weight too, so unnecessary extra packaging and harmful substances are to be avoided
Microenterprises (a business with fewer than 10 employees and an annual turnover below £1.7 million) are exempt from certain rules but must meet the packaging requirements. The exemption for micro-enterprises is still light on detail and what’s written could very well change as further requirements are revealed.
What is EPR?
The Extended Producer Responsibility is the EU Commission policy that is causing so many SME / Micro Enterprises to stop shipping to the EU member states. This is also happening in the EU as EU member states must do this if they ship to another EU member state.
Small businesses must complete a form – it’s a declaration of conformity for each packaging type being sent to each EU member state and have the necessary documents to meet requirements. To do this they have to employ and pay an EPR agent in each EU member state. Quotes are between £500 to £1000 per agent in each country.
The policy is to make producers (businesses) responsible for their products throughout the entire product lifecycle, including post-consumer waste management. The thinking behind all this is a good philosophy, as we need to reduce environmental impact and shift the cost burden from each country’s taxpayers for waste management back to the producer (the importer), to pay for this waste management.
This is a solution to reduce the mass production manufacturers who use single use plastic product packaging or send products in single use packaging.
The assumption from this is that businesses will absorb these costs….but as we know with US tariffs, they are generally passed on to the customer…
On the one hand this packaging policy is an excellent initiative for circular economy and environment by stopping single use plastic packaging (this will be enforced from 2030).
· It encourages the reuse of products to extend their lifecycle.
· Businesses (producers) can buy back used products for reuse or recycling
· Businesses (producers) can lower costs by being responsible for collection and recycling of their products.
The downside is that businesses (producers) face financial upfront challenges
· The first is that there is not one EU regulator and payment system, but instead, multiple EU member states to pay for each country you export to.
· To make it more complicated, each EU member state has different packaging rules and regulations internally to navigate, meaning some state members waive the compliance agent fee until you’ve sent 20 parcels, others it’s at zero.
· The impact of the compliance costs and additional admin burden really hits micro businesses. Even with exemptions, (if you can find and understand them), if you’re a micro enterprise, you are still expected to sign up to an EPR agent to oversee your compliance.
What other costs can a producer (artist-maker) expect?
In addition to the annual EPR agent fee, each parcel sent will have tarrifs and import duties plus a compliance packaging fee, based on weight, dimensions and type of packaging.
Why is this a problem for small business/micro enterprises?
The increased cost and lack of harmonisation and difficulties caused to meet the EU Commission targets across the EU member states, leads to barriers for UK micro/small business to sell and export to the EU market without cash flow constraint. The prediction is there will be a large reduction in the creative industry contribution to the UK economy from 2026 period onwards. There will also be other industry sectors whose small businesses cannot afford the EPR compliance agent fees.
Personal impact
As a small creative maker shipping my artwork, jewellery, paper goods, lampshades and leather goods in sustainable paper packaging worldwide, to adhere to these additional regulations and EPR compliance agent fees is another barrier to being able to sell my work in a large region of the world.
The packaging form needs careful completion, tick the wrong box and your package will be returned at your expense. Plus, the expensive up-front EPR compliance agent fee to be paid, without even knowing future sales.
This EPR compliance agent fee assumes, as an artist, I will regularly sell work valued at more than the agent fee costs to that EU member state in that year. Cash flow is tricky enough but being able to predict future sales, given the current economy and external players going to war, it means I have had to stop shipments to the EU.
Another issue is price competitivity
Dead space in packages incurs a higher cost as it’s classed as unnecessary waste. As someone who makes lampshade, I can’t send these as I can’t absorb the cost and so higher prices, mean I am no longer competitive compared to a maker in that EU member state.
But… there are some simpler (sensible) solution for micro enterprise/small business!
· One is to pay the EPR compliance agent fee per parcel, rather than an up-front large amount.
· Another idea is the EU Commission exempt or waive agent fees based on actual turnover generated on sales for the EU member state from prior financial year, and if this is less than £500, microenterprises should then not pay an EPR fee to an agent. Producers only pay the PPWR packaging tariff/duties fee per package based on completing one form.
So why does all this matter?
Nearly all creatives I know in the UK and some in the EU have stalled or completely stopped selling and shipping to the EU. This is because the rules for micro enterprises is still vague and may well change.
But the main issue is paying the up-front EPR agent compliance costs.
Creatives are frugal and often sustainably minded. We understand the need to be charged for waste management and to stop plastic through additional packaging tariffs, but these agents are charging too much for a form, which an AI programme will likely read anyway.
It is not just the creative industry, but also other small UK businesses who are stopping shipments and sales to the EU. Collectively this will impact the UK economy. We need the UK government to work on our behalf as these small businesses contribute so much to both our national and local economies.
We now don’t have a Minister dedicated to the EU, just Stuart Wood who is part of Foreign, Commonwealth and Development Office. He oversees European Affairs, amidst all his other duties. I have heard nothing on his thoughts on this regulation, or from PM Andy Burnham.
The impact this will have on so many small businesses, and the creative industry is going to affect the economy over the coming year.
YOU CAN HAVE YOUR SAY!
1 Contribute to the EU feedback form
The European Commission is seeking public feedback until 10 September 2026 – please add your voice to push for a unified and proportional system.
Please take 5 minutes to submit your comments directly through the link below. I’m happy for you to copy and paste my solutions above!
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/15352-Packaging-and-packaging-waste-rules-on-national-registers-of-producers_en
2 Email Stuart Wood and Andy Burnham
Copy and paste below wording and send today to both MPs and send separately to each MP:
Dear Andy and Stuart
There are 1.1 million micro creative businesses in the UK, offering over 2.4 million jobs in the creative sector (outperforming the overall economy in terms of growth and value added).
In 2024, this sector generated over £145 billion gross added value to the UK economy and exported over £10.2 million in creative goods to the EU.
I am writing regarding the new EU Commission PPWR and EPR policy which came into effect on 12 August 2026. The cost of paying up front an annual fee to the EPR compliance agent in each EU member state is cost prohibitive, as each agent may charge between £500 to a £1000 to check forms for compliance, which will likely be read by an AI programme.
As a maker, I understand the need for a circular economy and that we need to reduce packaging and single use packaging. Most creatives are already frugal and repurpose packaging or make their own product packaging using paper or fabric. We understand the need for a fee for waste management and to stop the flood of overseas large manufacturers using single use plastic packaging.
However, the cost to pay the EPR compliance agent in each EU member state creatives ship to, is what has stopped so many micro enterprises immediately shipping to the EU.
We need a harmonised and proportional system. A system that exempts small micro enterprises whose sales are less than the EPR compliance fee in that EU member state.
I ask you to help resolve the issues for small creative businesses and other sector small businesses across the UK, so we can continue to contribute to the UK economy and continue to sell and ship to the EU.
Your attention to this matter is urgently needed, we have until 10 September to feedback to the EU, so your involvement is needed now.
Yours sincerely
Your Name
Your Full Address and Postcode (this is important as they will not deal with it if you don’t put your contact details)
Finally, a bit of bedtime reading …
There are many companies, including courier services, who have helped my research into this, but I recommend these:
https://www.business.gov.uk/business-academy/videos/eu-packaging-rules-ppwr-explained-2108/
https://smallbusiness.co.uk/what-is-extended-producer-responsibility-2569587/