Pollute More, Save More

Nobody running a small business needs telling to use less packaging. Every envelope, backing board, sleeve and bit of tape costs money. Wasting packaging is already wasting your own margin.

Which is why the new system can look so backwards from the bottom end of the market. The EU Packaging and Packaging Waste Regulation is supposed to make producers responsible for the packaging they put onto the market. Fine. But once registration, reporting and authorised-representative requirements are added in, the seller putting the least packaging into a country can end up facing the nastiest cost per parcel.

One sale can be enough to make the numbers ridiculous

Take the private compliance market that has grown around these rules:

€155 a year for Germany, €250 for France, €335 for Spain and €730 for Croatia.

Those are not official EU registration fees, and different providers charge different amounts.

If you make one sale into a country all year and the compliance route you use costs €155, that is effectively €155 of compliance cost sitting on that one sale before you have paid for the product, the packaging, the postage, payment fees or your own time.

At €730, the idea of testing a market with one or two low-value orders is finished before you start.

Since 12 August 2026, if you're a business outside Germany selling packaged goods directly to German customers, you have to appoint an authorised representative in Germany. Germany has an official packaging register called LUCID. The register itself is free, but you can't actually sign up to it until you've paid somebody else first.

The cheapest one I could find aimed at small shops charges €55 a year just to be your representative, then there's a minimum recycling charge of €28.90 on top. Another provider advertises Germany from €155.

That's the bit I find a bit daft. These rules have basically created a whole new layer of paid compliance jobs for work that really makes more sense when you're dealing with a smaller number of much bigger companies shifting thousands of orders.

Instead, you've now got the same sort of system being pushed onto hundreds of thousands of tiny Etsy shops and one-person businesses, some of which haven't even made 100 sales in total.

So you've got people paying representatives, recycling schemes and compliance companies just to send the odd envelope or parcel into Germany. For a massive company doing serious volume, fair enough. For somebody who's just got started with things on an e-com marketplace, it starts to feel a bit ridiculous.

The smaller seller already has a reason not to waste packaging. Every unnecessary bit comes straight off the margin.

Pollute more, save more

The title is meant to sound ridiculous because the incentive can be ridiculous. The more orders a business sends, the easier a fixed annual compliance cost is to spread. A seller doing five orders carries a much bigger compliance cost per parcel than a seller doing fifty thousand. The bigger operator may pay more overall, but the fixed part quickly becomes background noise.

That means the business putting very little packaging into a market can face the biggest barrier per item, while the business putting huge volumes through the same market gets the best economies of scale. The fixed administrative structure favours volume.

The same annual admin cost is a very different problem when it is spread across a handful of parcels instead of thousands.

This has created a compliance market

Once the law says a foreign seller has to appoint a representative before it can keep selling into a country, it has created compulsory demand for that service. Every small seller pulled into scope becomes another potential paying client for authorised representatives, producer-responsibility organisations and compliance agencies. That is not a tiny side issue. It is part of the economics of the system.

A huge marketplace or multinational can treat registration, reporting and representation as another line in the compliance budget. A tiny seller can be looking at the profit from months of occasional orders disappearing into the right to carry on making those orders at all. From the workshop end, the message is much blunter: pay the compliance bill or stop selling there.

Pay up or stop selling there

You do not need a leaked memo saying “push out small sellers” to see who this structure favours. Fixed costs reward scale.

If one low-value sale can carry an annual compliance cost while a huge operator spreads the same admin across thousands of orders, the outcome is predictable: more of the market is left to businesses that already have scale. Whatever language is used around the policy, that is exclusionary in practice.

The environmental bit is not the difficult part. Use sensible packaging, report what you put onto the market and pay a fair share towards dealing with it. The difficult part is explaining why the smallest seller should need to hire 27 people in the EU just to send a handful of parcels, or potentially none at all (Read about: 3 euro import fees destroying small business sales for low value goods). If the paperwork and fees costs more than the waste it is supposed to deal with, something has gone badly out of proportion.

Sources

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