PPWR hit today; I'm starting a buying group for small sellers. Anyone in?
As of 12 August, if you place packaged goods in an EU country where you're not established, you need a registration there and an authorised representative established there. Per country. No single EU window.
The recycling fees themselves are tonnage based and small if you ship small. The killer is the flat admin cost: a few hundred euros per country per year whether you ship 40kg or 40 tonnes.
That part is a procurement problem, not a legal one. Representative firms quote very differently at 200 clients than at one. So I'm setting up a Verein in Austria to negotiate as a block and to publish a free, open database of what every member state actually requires: the registers, the fields, the deadlines. Nobody publishes that openly because the whole sector monetises the confusion.
To be straight about limits: this can't become your legal producer, and it can't do your registration for you (in Germany for example that's legally personal). It's a buying group and a shared knowledge base.
I'm looking for the first 50 or so to make the numbers work. If you're affected, reply or DM I want to hear which countries you ship to and what you've been quoted.
Thank you and good luck!