PPWR for small businesses: what applies to a micro-enterprise, what can wait, and what does not apply
Last reviewed · Dataset v2026-10-03 · Reviewed by Pauli Parkkinen, General Manager, Toolcat Oy
There is no general size exemption in Regulation (EU) 2025/40. The rules apply to the packaging whatever the size of the company that places it on the market. That covers the substance limits (Art 5) and the design and labelling requirements (Arts 6-12). It covers the Annex VII technical documentation and the Annex VIII declaration of conformity (Arts 15, 38, 39). It also covers producer registration and EPR (extended producer responsibility) (Arts 44-45). Company size changes five things, listed below. Mostly it changes who must do the paperwork, never what the packaging must meet.
This page is informational, not legal advice. We checked it against the Official Journal text of Regulation (EU) 2025/40 and the Finlex consolidated jätelaki on 4 September 2026.
The words this page uses
- PPWR (Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation): the EU rules for packaging that apply from 12 August 2026, directly in every Member State.
- EPR (extended producer responsibility: the producer pays for collecting and recycling its packaging), run in Finland through producer communities (Arts 44-45).
- Delegated act and implementing act: acts the Commission adopts under the Regulation. A delegated act supplements it or amends certain of its thresholds, percentages and annex tables, and enters into force only if the European Parliament and the Council do not object (Art 64). An implementing act lays down uniform rules for applying it, such as a calculation method, a reporting format or the harmonised label (committee procedure, Art 65). Several dates below move with them.
- Technical documentation: the Annex VII file that shows the manufacturer's assessment of the packaging (Art 15(2)).
- EU declaration of conformity: the signed Annex VIII statement that rests on that file (Art 39).
- Manufacturer: who makes the packaging or has it made under its own name (Art 3(1)(13)).
- Producer: who registers and pays EPR fees in a Member State (Art 3(1)(15)). That is the operator established there that first makes the packaged product (or transport, service or primary production packaging) available there, or a seller from another country that supplies end users there directly. Unpacking goods without being their end user can also make you the producer.
- Authorised representative: two kinds. Art 17 sits in the conformity chain. Art 45(3) is the EPR representative. See the deadlines FAQ.
Are you a micro-enterprise?
A micro-enterprise employs fewer than 10 persons and has an annual turnover and/or an annual balance-sheet total of at most EUR 2 million (Recommendation 2003/361/EC, Annex, Article 2(3)). The PPWR uses that Recommendation as it applied on 11 February 2025. Later changes to it therefore do not move the PPWR thresholds (Art 3(1)(13)(b), Art 15(12), Art 21, Art 25(4), Art 29(13), Art 33(4)).
Count partner enterprises pro rata and linked enterprises in full (Annex, Articles 3 and 6). Count staff as annual work units (Annex, Article 5). It is about your company, not your catalogue: a micro-enterprise can hold 300 products. A 'small enterprise' (fewer than 50 staff, at most EUR 10 million) gets no relief anywhere in the Regulation.
The toolkit computes this test from the three numbers you enter (staff, turnover, balance-sheet total); it does not determine or confirm your status.
| Size class | Staff | Turnover / balance sheet | PPWR relief? |
|---|---|---|---|
| Micro-enterprise | fewer than 10 | at most EUR 2 million | Yes: five reliefs, listed below. |
| Small enterprise | fewer than 50 | at most EUR 10 million | None. |
| Medium-sized enterprise | fewer than 250 | at most EUR 50 million turnover or EUR 43 million balance sheet | None. |
Which of the four roles are you?
The Regulation hands out duties by role, not by size. Most small companies hold one of these four.
| Role | Who it is |
|---|---|
| Importer | Established in the Union and places packaging from a third country on the market (Art 3(1)(17)). Buying from another EU country does not make you an importer. |
| Own-brand seller | Has packaging or a packaged product made under its own name or trademark: the manufacturer (Art 3(1)(13)(a), subject to point (b)). An importer or distributor that rebrands packaging, or modifies it in a way that could affect its compliance, is treated the same way (Art 21). |
| Distributor / reseller | Makes packaging available that someone else placed on the EU market (Art 3(1)(18)). A shop or web shop selling to the end user is also the final distributor (Art 3(1)(21)). |
| Web shop selling cross-border | A producer in every Member State where it first makes packaged products available directly to end users (Art 3(1)(15)(c)-(d)), in addition to its own Member State (Art 3(1)(15)(b)). |
A Finnish importer of packed goods is the producer in Finland (Art 3(1)(15)(b)). A Finnish web shop shipping to Swedish consumers is the producer in Sweden (Art 3(1)(15)(d)). A Finnish wholesaler is the producer of the transport packaging it ships with, such as pallets and cartons, only where it is the first to make that packaging available in Finland, for example because it makes it or brings it in from abroad. Where it buys that packaging from a Finnish maker or seller, the supplier is the producer (Art 3(1)(15)(a)). For goods it unpacks without being their end user, it is the producer of the incoming packaging only where no one else is (Art 3(1)(15)(e)).
'Placing on the market' means the first making available of packaging, empty or with a product, on the Union market (Art 3(1)(10)). The full role-by-role journey is on the workflow page.
What applies from 12 August 2026
Read your column. A company can sit in more than one column: a Finnish importer that sells its own brand is the manufacturer, the importer and the producer at once.
| Duty | Manufacturer / own-brand seller | Importer | Distributor / reseller | Every producer (EPR) |
|---|---|---|---|---|
| Substances (Art 5) | Lead, cadmium, mercury and hexavalent chromium together: at most 100 mg/kg in the packaging or a component (Art 5(4)). From 12 August 2026 food-contact packaging must not contain PFAS (per- and polyfluorinated alkyl substances, often called forever chemicals) at or above 25 µg/kg for a single targeted PFAS, 250 µg/kg for the sum of targeted PFAS or 50 mg/kg for PFAS including polymeric (Art 5(5)). No transition, no size relief. You demonstrate compliance in the Annex VII file (Art 5(6)). | You check that the manufacturer demonstrated this in the Annex VII file (Art 18(2)(a)). | No substance duty of its own (Art 19(2)). | — |
| Conformity assessment and documents | You run the Art 38 procedure: Annex VII, Module A, internal production control, no notified body. You draw up the Annex VII technical documentation and the Annex VIII declaration (Art 15(2), Art 39). You keep both for 5 years (single-use) or 10 years (reusable) (Art 15(3)). | You ensure the manufacturer did all that (Art 18(2)(a)-(d)). You keep a copy of the declaration for 5 or 10 years and can produce the documentation within 10 days (Art 18(7), 18(8)). | None. You verify instead (Art 19(2)). | — |
| Identification and name on the pack | A type, batch or serial number, plus your name and postal address (Art 15(5)-(6)). Put them on the pack, in a QR code or data carrier, or in an accompanying document where the size or nature of the packaging does not allow it. | Your own name, trade name or trademark and postal address too (Art 18(3)). | You check that both are there (Art 19(2)(c)). | — |
| Labelling now | No label, mark, symbol or inscription likely to mislead or confuse end users about the PPWR sustainability requirements, other packaging characteristics or waste-management options for which the Regulation lays down harmonised labelling (Art 12(8)). Environmental claims about packaging properties the PPWR regulates: only where the property exceeds the PPWR minimum, saying whether the claim covers the packaging unit, part of it or all packaging you place on the market, and substantiated in the Annex VII file (Art 14). No false bottoms, double walls or unnecessary layers (Art 10(2)). | Art 10(2) binds you directly. Art 12(8) binds every economic operator, and Art 14 binds whoever makes the claim. | Art 12(8) binds you too. You check that the packaging is labelled per Art 12 (Art 19(2)(b)). | — |
| Distributor checks (Art 19(2)) | — | — | Before you make packaging available you verify three things (Art 19(2)). The producer is in the Art 44 register. The packaging is labelled per Art 12. The Art 15(5)-(6) and 18(3) markings are present. A distributor holds no declaration. | — |
| Registration and EPR | If you are the producer (Art 3(1)(15)), see the last column. | A Finnish importer of packed goods is the producer in Finland (Art 3(1)(15)(b)): see the last column. | The producer if you are the first to make the packaged product available in your Member State, for example because you bought it from another EU country (Art 3(1)(15)(b); point (a) for transport, service and primary production packaging). Usually not the producer if you buy from a supplier established in your own Member State. Also the producer where you sell directly to end users in another Member State (Art 3(1)(15)(c)-(d)), or where you unpack goods without being their end user and no one else is the producer (Art 3(1)(15)(e)). | Register in each Member State where you are the producer (Art 44(2)). Do not make packaging available there before you are registered (Art 44(4)). Until the harmonised national register under Art 44(1) exists (to be set up within 18 months of the first Art 44(14) implementing act entering into force; no act has been adopted yet), the existing national register applies. In Finland that is the tuottajarekisteri at Lupa- ja valvontavirasto. Selling directly to end users in another Member State: appoint an EPR authorised representative there by written mandate (Art 45(3)); see the status line below. Give fulfilment providers and marketplaces your registration number and self-certification at contract time (Art 45(4), 45(7)). A fulfilment provider checks that information, asks you to remedy it where it is inaccurate, incomplete or out of date, and suspends its service for your offering to consumers in the Union only if you fail to correct it (Art 45(8)). |
Status on 4 September 2026. The Commission's Environmental Omnibus proposal (COM(2025) 982 of 10 December 2025) would suspend the whole of Art 45(3) until 1 January 2035, including the mandatory appointment for producers established in the EU. It is a proposal, not law. The Council did not advance that part in June 2026. The European Parliament's ENVI (Environment, Climate and Food Safety) committee is pursuing a narrower exemption (up to 49 staff and EUR 10 million turnover). A first reading is not expected before October 2026. For producers established outside the EU it would let each Member State either require an EPR authorised representative or ensure traceability and enforcement by other means. Until anything is adopted, Art 45(3) applies as written. This status is compiled from secondary reporting and is re-checked against EUR-Lex before each republish.
What can wait — and until when
These duties bind the packaging whatever your size, but not yet. Where a date says 'whichever is the latest', a late Commission act moves it.
| Duty | Date | What moves it |
|---|---|---|
| Recyclability grade A, B or C (Art 6(3)) | From 1 January 2030 or 24 months from the entry into force of the delegated acts adopted pursuant to Art 6(4), whichever is the latest. Grade A or B from 1 January 2038. | Delegated acts due by 1 January 2028 (Art 6(4)). |
| Recycled content in plastic parts (Art 7(1)) | By 1 January 2030 or 3 years from the entry into force of the implementing act referred to in Art 7(8), whichever is the latest. | Implementing act due 31 December 2026 (Art 7(8)). Plastic parts under 5 % of the unit weight are outside it (Art 7(5)(b)). |
| Weight and volume minimisation (Art 10(1)) | By 1 January 2030. | Nothing. Art 70(1)(b) keeps Art 9(1)-(2) of Directive 94/62/EC applying until 31 December 2029 for the weight and volume minimisation essential requirement only (the Directive's Annex II point 1, first indent). There is no duty-free window. |
| Empty space in sales packaging reduced to the minimum (Art 24(4)) | By 12 February 2028. | Nothing. |
| 50 % empty-space cap for grouped, transport and e-commerce packaging (Art 24(1)) | By 1 January 2030 or 3 years from the entry into force of the implementing acts adopted pursuant to Art 24(2), whichever is the latest. | Implementing act due 12 February 2028 (Art 24(2)). Filling material counts as empty space (Art 24(3)). Sales packaging used as e-commerce packaging, and reusable packaging within a system of re-use, are exempt from the cap; such sales packaging must still meet Art 10 (Art 24(5)). |
| Harmonised material label (Art 12(1)) | From 12 August 2028 or 24 months from the date of entry into force of the implementing acts adopted pursuant to Art 12(6) or (7), whichever is the latest. | Implementing acts due 12 August 2026 (Art 12(6)-(7)). Packaging manufactured in the Union or imported before that date may be sold for 3 years (Art 12(12)). |
| Reusable-packaging label (Art 12(2)) | From 12 February 2029 or 30 months after its implementing act, whichever is the latest. | The Art 12(6) implementing act. |
| Decision 97/129/EC material codes repealed (Art 70(2)) | 12 August 2028. | Nothing. See the material codes page. |
| Annex V format bans (Art 25(1)) | From 1 January 2030. | Nothing. A Member State may allow micro-enterprises to keep point 3 formats: see item 4 below (Art 25(4)). |
| Re-use targets (Art 29(1)) | From 1 January 2030. | Nothing. A micro-enterprise is exempt for a calendar year in which it made not more than 1 000 kg of packaging available in the Member State: see item 2 below (Art 29(13)). |
| Bring-your-own-container in the HORECA sector (accommodation and food service, including take-away, catering and bars) (Art 32(1)) | By 12 February 2027. | Nothing. No size exemption. |
| Re-use offer for take-away (Art 33(1)) | By 12 February 2028. | Nothing. Micro final distributors are exempt (Art 33(4)). |
| Compostable tea and coffee bags and fruit stickers (Art 9(1)) | By 12 February 2028. | Nothing. |
'Whichever is the latest' means a late Commission act moves the date. The toolkit marks every such duty 'act pending' and names the act. Every date on this page, with the article behind it, is on the compliance timeline.
What the Regulation lets a micro-enterprise skip — and what it does not
Every relief below turns on the micro-enterprise definition as applicable on 11 February 2025. None of them touches what the packaging itself must meet. Items 3 and 4 concern the HORECA sector: accommodation and food service activities under NACE Rev. 2 (Art 3(1)(35)). That reaches beyond hotels, restaurants and cafés to take-away outlets, food trucks, caterers, canteens and bars.
- Who is the manufacturer. If you have packaging made under your own name and your packaging supplier is located in the same Member State, the supplier is the manufacturer (Art 3(1)(13)(b)). The Art 15 duties are the Annex VII file, the Annex VIII declaration, identification, and name and address. For those duties the same shift applies whenever the supplier is anywhere in the Union (Art 15(12)). The same applies to a rebranding importer or distributor, or one that modifies the packaging in a way that could affect its compliance (Art 21 second subparagraph). A supplier outside the EU never triggers the shift. A micro importer buying own-brand goods from China is the manufacturer with the full Art 15 duties. The shift moves the paperwork, not the requirements: Arts 5-12 still bind the packaging. It does not move producer status, registration or fees (Art 3(1)(15), Arts 44-45).
- Re-use targets. You are exempt from the Art 29 targets for a calendar year if two things hold (Art 29(13)). In that year you made not more than 1 000 kg of packaging available in that Member State (point (a)). And you are a micro-enterprise (point (b)). Two related reliefs are not micro-based. Transport-packaging targets do not apply to cardboard boxes (Art 29(4)(d)). A final distributor with a sales area of at most 100 m² is exempt from the beverage target (Art 29(10)).
- Take-away re-use offer. Micro final distributors need not offer take-away food and drink in reusable packaging (Art 33(4), duty from 12 February 2028). The Art 32 duty to fill a customer's own container (12 February 2027) has no size exemption.
- Annex V point 3 formats. These are single-use plastic formats for food and drink filled and consumed on HORECA premises. A Member State may allow micro-enterprises to keep using them after 1 January 2030 (Art 25(4)). The condition is that it has been demonstrated that it is not technically feasible not to use such packaging or to obtain access to re-use infrastructure (Art 25(4)). That is a Member State option, not a right. It helps you only if Finland adopts it. No Finnish provision exercising Art 25(4) appears in jätelaki as amended by act 648/2026 (Finlex, checked 4 September 2026).
- Reporting. Under 10 tonnes a year in a Member State, you file the simplified seven-material report by 1 June (Art 44(8)). That is the report in Annex IX Part B point 2, and it applies once the Art 44(1) register applies. A Member State may set a lower threshold (Art 44(8)). Producer responsibility organisations must not put a disproportionate burden on producers of small quantities (Art 46(5)). In Finland a producer under 50 tonnes a year may report on the light form (VNA 1029/2021 § 19 a, see the Finland section).
No size relief anywhere in these articles
- Art 5 substances
- Art 6 recyclability
- Art 7 recycled content
- Art 10 minimisation
- Art 11 reusable-packaging criteria
- Art 12 labelling
- Arts 15-21 operator duties (only who is the manufacturer can shift)
- Art 24 empty space
- Art 32 bring-your-own-container
- Arts 38-39 conformity assessment and declaration
- Art 44 registration
- Art 45 EPR contributions
Nothing in Art 71 defers the application date for small companies. The table above lists the main later dates, not every one: some duties carry their own later date (for example Art 9(3), by 12 February 2028), and Art 71 itself defers Art 67(5), which amends Part B of the Annex to Directive (EU) 2019/904 on single-use plastics, to 12 February 2029. The dated duties are on the compliance timeline.
Finland: no size threshold since 1 January 2024
Producer responsibility binds every operator that professionally places packaging on the Finnish market or sells it by distance sale directly to users (jätelaki 646/2011 § 48(1)). The EUR 1 000 000 turnover threshold in the old § 48(2) applied for the last time to 2023 (transitional provision of act 1096/2022). Since 1 January 2024 there is no turnover threshold.
The ELY Centres (ELY: the regional state authorities) ran the producer register until 31 December 2025. They, and now Lupa- ja valvontavirasto, treat an operator established in Finland that is not liable for VAT as not acting professionally. Rinki's guidance puts it the other way round: VAT-registered means professional operator. But that is scheme guidance, not the statute. Being liable for VAT is not on its own proof that you act professionally.
From 12 August 2026, jätelaki § 48(1) point 6 defines the packaging producer by reference to PPWR Art 3(1)(15) (act 648/2026). In practice producer responsibility for transport packaging moves from the packer to the packaging manufacturer or importer.
Route and dates
Join an approved producer community: Suomen Pakkaustuottajat Oy (served by Rinki) or Sumi Oy (jätelaki § 62). The alternative is to register yourself, as the exception the authority grants (§ 101). Do you sell packaged goods by distance sale directly to end users in Finland from another country? Then you appoint, by written mandate, an authorised representative established in Finland for producer responsibility (Regulation (EU) 2025/40 Art 45(3)). Jätelaki § 66 a refers packaging to that Article.
By 31 January you send the previous year's packaging data to your producer community. That is Rinki's contractual date. By the end of June the statutory return is due to Lupa- ja valvontavirasto (VNA 1029/2021 § 19(1)). VNA is the Valtioneuvoston asetus, the Government Decree on packaging and packaging waste. Your producer community files that return for its members (VNA 1029/2021 § 19(1)).
A producer placing under 50 tonnes a year may report in the light form and be charged an averaged fee (VNA 1029/2021 § 19 a).
What it costs a micro-enterprise
The figures below are from the Suomen Pakkaustuottajat (SPT) 2026 price list, light form, for producers under 50 000 kg a year. The recycling fee is EUR 0,1020/kg for consumer fibre packaging and EUR 0,2380/kg for consumer plastic, VAT 0 % (VAT is added on top). The annual company service fee is EUR 0,00199/kg per contract, at least EUR 74 and at most EUR 3 890 a year.
Worked example: 800 kg of consumer fibre packaging is 800 × 0,1020 = EUR 81,60. 120 kg of consumer plastic is 120 × 0,2380 = EUR 28,56. Recycling fees: EUR 110,16. Service fee: 920 kg × 0,00199 = EUR 1,83, raised to the EUR 74 minimum. Total: about EUR 184 a year plus VAT.
SPT 2026 price list as encoded in dataset v2026-08-01. The community's own invoice is the binding one, so check the current list on rinkiin.fi before relying on it. Sumi publishes its own list. This is an estimate, not an amount owed.
If you do nothing
Failing to join a producer community or to apply to the producer register costs 1 % of the previous financial year's turnover (jätelaki §§ 131-132). The charge is at least EUR 500 and at most EUR 500 000 (§ 132). Other listed failures cost EUR 500-10 000 (§ 132). The authority must first set a deadline of at least 30 days to remedy (§ 133).
Who supervises
From 12 August 2026 Tukes is the market-surveillance authority for PPWR Arts 5, 6, 8-12, 14 and 24-26 and for the Art 7 recycled-content minimums of other plastic packaging (Art 7(1)(d), 7(2)(d)) (jätelaki § 24 a; VNA 1029/2021 § 23). Tukes has held that role for packaging requirements since the 2021 reform. Lupa- ja valvontavirasto supervises producer responsibility and Arts 27 and 29-31, and the municipal food-control authority supervises Arts 28, 32 and 33 (jätelaki as amended by act 648/2026). The food-control authorities under the Food Act (elintarvikelaki §§ 24 and 27) supervise the Art 7 recycled-content minimums for contact-sensitive packaging and single-use plastic beverage bottles (jätelaki § 24 a(4)).
Routes, fee classes, Palpa deposits and the whole Finnish journey are on the Finland page.
What small companies ask about the PPWR
What is a micro-enterprise under the PPWR?
A micro-enterprise employs fewer than 10 persons and has an annual turnover and/or an annual balance-sheet total of at most EUR 2 million (Recommendation 2003/361/EC, Annex, Article 2(3)). The PPWR applies that Recommendation as applicable on 11 February 2025, so later changes to it do not move the PPWR thresholds (Art 3(1)(13)(b)). Count partner enterprises pro rata and linked enterprises in full (Annex, Articles 3 and 6). The test is about your company, not your catalogue. Sources: Recommendation 2003/361/EC, Regulation (EU) 2025/40.
Do I need a declaration of conformity if I only import?
Not for goods you resell under the manufacturer's name. You must check that the manufacturer carried out the Annex VII assessment and drew up the documentation (Art 18(2)(a)). You must keep a copy of the EU declaration of conformity for 5 years, or 10 for reusable packaging (Art 18(7)). If you sell under your own name or trademark, or modify the packaging in a way that could affect its compliance, you are treated as the manufacturer and draw up the declaration yourself (Art 21). There is one exception. If you are a micro-enterprise and your packaging supplier is located in the Union, the supplier is the manufacturer for Art 15 (Art 21 second subparagraph). Sources: Regulation (EU) 2025/40.
Does the 1 000 kg rule remove producer registration?
No, it does not. Art 29(13) removes only the re-use targets of Art 29, from 1 January 2030. The exemption applies in a calendar year in which a micro-enterprise made not more than 1 000 kg of packaging available in that Member State (Art 29(13)). Registration (Art 44) and EPR contributions (Art 45) stay. A separate, quantity-based relief lets any producer under 10 tonnes a year in a Member State file the simplified report (Art 44(8)). Sources: Regulation (EU) 2025/40.
Does being a micro-enterprise move the EPR fees to my supplier?
No, on the text of the Regulation. Producer status turns on who first makes the packaged product available in the Member State (Art 3(1)(15)). The micro rule in Art 3(1)(13)(b) and Art 15(12) changes who is the manufacturer, not who is the producer. Registration and fees (Arts 44-45) stay with the producer. In Finland, check Lupa- ja valvontavirasto's guidance for the authority's reading of the brand-owner case. Do not treat it as settled. Sources: Regulation (EU) 2025/40, Lupa- ja valvontavirasto.
My web shop ships to Sweden: do I have to register there?
Yes, if you sell directly to Swedish end users. You are the producer in Sweden for that packaging (Art 3(1)(15)(d)). You register there (Art 44(2)). Because you are not established there, you appoint an EPR authorised representative in Sweden by written mandate (Art 45(3)). The Commission's Omnibus proposal would suspend that appointment for EU-established producers until 2035. But it is a proposal, not law (status 4 September 2026). Sources: Regulation (EU) 2025/40, Commission proposal COM(2025) 982.
Is there a turnover threshold for packaging producer responsibility in Finland?
No, not since 1 January 2024. The EUR 1 000 000 threshold in jätelaki § 48(2) applied for the last time to 2023 (act 1096/2022). Since then producer responsibility binds every operator that professionally places packaging on the Finnish market (§ 48(1)). The authorities treat an operator established in Finland that is not liable for VAT as not acting professionally. Sources: jätelaki 646/2011, ELY Centres on the 1 January 2024 change.
Try it on your own catalogue.
Fourteen days free, five products, no credit card. Enter your three size numbers once and the toolkit shows, per product, which of these duties is open today.