There is no small-business exemption — check that first
This is worth stating plainly because the opposite is widely repeated. The regulation grants no general size exemption for the Article 39 declaration, the Article 6 recyclability duty or producer registration. Some obligations do carry scope conditions, but they turn on the packaging and the market, never on your headcount or turnover. Anyone telling you that under a certain size you are out of scope is selling you a surprise.
What actually makes it hard when you are small
- Nobody owns it. Compliance lands on whoever has the least full plate — usually operations, usually alongside their real job.
- The data lives with your suppliers. You sign a declaration about material composition you did not measure and cannot see.
- A consulting quote costs more than the packaging line it covers, and leaves you with a PDF that ages.
- One portfolio, several markets. EPR registration and reporting differ by country, and the smallest exporters hit the most of them.
What the first hour looks like
01
Assess, free, without an account
Six questions on your portfolio return a compliance score and a ranked list of gaps. No card, no call, no account. If the answer is that you are in decent shape, that is a legitimate outcome and you have lost twenty minutes.
02
Import the portfolio you already have
A spreadsheet of references is enough to start. Each unit gets its recyclability grade against Annex II and its own gap list, so you find out where the real exposure is instead of assuming it is everywhere.
03
Produce the first declaration
The Annex VIII declaration is generated from the unit data, field by field, with the guidance notes attached. Preview it free; export it when you are ready to sign it.
What it costs, in public
Starter is €29 a month. The assessment is free and needs no account, the declaration preview is free, and the prices are on the pricing page rather than behind a call. That is the whole argument: not a lighter obligation, a cheaper path through the same one.
45+ companies use PPWR Connect
What small companies actually ask us
Is there a size threshold below which PPWR does not apply?
No. The regulation sets no general small-business exemption and no headcount or turnover threshold for the core duties. Scope is decided by the packaging you place on the EU market and where you place it — not by how big you are.
We import and rebrand. Are we the manufacturer?
If your trademark is on the pack, you are very likely the PPWR manufacturer for it, and usually the EPR producer too — even if you printed nothing. That is the single most common surprise for small importers and private-label sellers.
Our supplier says the packaging is compliant. Is that enough?
Not on its own. You sign the declaration, so you carry it. A supplier statement is evidence to keep in the technical documentation, not a substitute for the declaration itself or for holding the underlying data.
How long does the first declaration really take?
For one packaging unit whose material composition you already know, under an hour. What takes longer is getting composition data from suppliers who have never been asked for it — which is why starting on one unit beats waiting to start on all of them.
We sell in three countries. Does that multiply everything?
The declaration follows the packaging unit, not the market, so it does not multiply — but it may need translating into the languages each Member State requires. EPR registration and reporting, on the other hand, are genuinely per country.
Do we need a consultant?
For an ordinary portfolio, no. A consultant earns their fee on unusual formats, contested classifications or a dispute with an authority. Producing and maintaining routine declarations is the part software does better and far cheaper.