Am I as a small business also affected by the PPWR?

Yes – the PPWR (Regulation (EU) 2025/40) applies in principle to all companies that place packaging on the EU market, regardless of company size. A blanket exemption for micro-enterprises does not exist.

However, the Regulation provides quantity-based exemptions for certain categories: companies that place less than 1 tonne of packaging material on the market per year are exempt from certain obligations – in particular the minimum recycled content requirements. This threshold may sound generous, but many SMEs exceed it faster than expected, as the calculation aggregates all types of packaging cumulatively (primary, secondary, and transport packaging).

Specifically relevant for SMEs since 12 August 2026:

- Labelling obligation: Every packaging unit must bear the standardised material sorting pictogram – with no quantity exemption. - Minimisation requirement: Unnecessary packaging volume must be reduced; void space in packaging is limited. - Digital Product Passport (QR code): For certain packaging categories, a GS1 Digital Link becomes mandatory – even for smaller quantities. - Documentation obligations: You must be able to document the conformity of your packaging to the relevant authorities.

A common misconception: companies operating exclusively in the B2B sector are not exempt from these obligations. The Regulation is tied to the act of placing products on the market, not to the distribution channel.

For a reliable assessment of your specific situation, please contact your local Chamber of Commerce – they offer free initial consultations on PPWR compliance.