Germany proposes EU‑wide packaging register and exemption for small producers

Berlin has formally asked EU member states to amend the EU Packaging Regulation by creating a single, EU‑wide registration system and by exempting small manufacturers that place less than 10 tonnes of packaging on the market each year from the requirement to appoint an EU‑wide representative.

Background to the amendment

The current packaging rules, which entered into force in the summer of 2026, obligate producers to register their packaging in every EU country where they sell it and to designate a representative in each member state. The German federal environment ministry has warned that the dual obligations generate “hohe bürokratische Hürden für Unternehmen” (high bureaucratic hurdles for companies). Small firms have previously signalled that the costs could force them to cease exporting.

According to Handelsblatt, the government’s proposal was submitted to the other EU members on 7 September 2026. The filing is part of a broader effort to “nachbessern” (tighten up) the regulation while preserving its waste‑reduction objectives.

Key elements of the proposal

• Replace the 27 national packaging registries with one central EU register. The text states: “Außerdem soll ein zentrales Register die 27 einzelnen Register ersetzen.”
• Allow manufacturers to register once at EU level rather than filing separately in each member state: “Hersteller müssen Verpackungen dann nicht mehr in jedem Mitgliedsstaat der EU einzeln registrieren – sondern nur einmalig europaweit eine Registrierung vornehmen.”
• Exempt firms that place under 10 tonnes of packaging material on the market per year from the EU‑mandated representative requirement. The threshold is explicitly listed as 10 tonnes per year in the source data.

The 10‑tonne threshold is drawn from the packet’s key numbers table, which records the figure as “Packaging volume threshold for exemption – 10 tonnes per year” (source: Handelsblatt).

Impact on small manufacturers

Small producers have argued that the representative requirement adds a “enormen Kostenfaktor” (enormous cost factor). By removing this obligation for firms below the 10‑tonne threshold, the amendment could lower compliance costs and reduce the risk of market exit. Handelsblatt reports that “Kleine Unternehmen hatten deswegen davor gewarnt, dass sie unter den neuen Bedingungen den Versand ins Ausland einstellen müssten.” The exemption therefore directly addresses that concern.

Because the proposal does not alter the overall waste‑reduction targets of the regulation, larger producers will continue to register in the central system and retain the representative requirement. The shift to a single register is expected to streamline reporting and reduce administrative duplication across the EU.

Political context and next steps

The amendment originates from the German federal environment ministry, which communicated the plan to EU counterparts through “Verhandlungskreise” (negotiation circles). The source excerpt notes: “Die Bundesregierung will bei der EU‑Verpackungsverordnung nachbessern.” The proposal now enters the EU’s inter‑governmental negotiation phase, where each member state will assess the impact on national implementation structures.

Implementation timing has not been disclosed. The packet does not contain a projected date for when the central register would become operational, nor does it specify how the EU Commission will evaluate the exemption’s compatibility with the overall regulatory framework.

Uncertainties and open questions

Several points remain unclear:

• The exact legal text of the amendment and whether it will amend the existing regulation or be introduced as a separate directive.
• How the EU will ensure that the central register maintains data quality and enforcement parity across member states.
• Whether the 10‑tonne threshold will be reviewed in future revisions, given that the current figure is based on German government proposals rather than EU‑wide consensus.
• The response of other EU countries that operate their own national registries and may have differing administrative capacities.

Analysts will watch the EU’s formal decision process closely, as the outcome will affect the cost structure of thousands of small and medium‑sized enterprises that rely on cross‑border packaging distribution.

Conclusion

Germany’s submission on 7 September 2026 seeks to simplify the EU packaging compliance landscape by consolidating 27 national registries into a single EU‑wide system and by exempting firms that place under 10 tonnes of packaging per year from the representative requirement. If adopted, the change could reduce administrative overhead for small manufacturers while preserving the regulation’s environmental goals. The proposal now moves into the EU’s inter‑governmental review, where its final shape and implementation timetable will be determined.