HOC asks the EC to simplify registration of packaging for small online retailers

The Croatian Chamber of Skilled Crafts (HOK) has called on the European Commission (EC) to simplify registration procedures for packaging and packaging waste for small online traders operating across EU member states. The request comes amid concerns over administrative burdens and fixed costs that could deter micro-enterprises and small businesses from engaging in cross-border e-commerce within the bloc. In a statement, HOK emphasized the need for the application of the “once-only” principle during registration, which would involve establishing a unified technical entry point through which entrepreneurs could submit data to multiple relevant national registers with a single input. Under the proposed EU Regulation 2025/40 on packaging and packaging waste (PPWR), small businesses that receive even a single order from another EU country may be required to register in that nation’s registry, join its extended producer responsibility system, which involves new costs, and appoint an authorized representative in that country. This requirement, according to HOK, imposes additional financial and procedural hurdles on micro-enterprises and small-scale producers who sell limited quantities of packaged goods internationally. To address these challenges, HOK has proposed several measures aimed at reducing the regulatory burden. These include significantly lowering or eliminating fixed registration fees for micro and small enterprises and those producing very small amounts of packaging. Additionally, HOK advocates for a proportional regime for mandatory authorized representation and simplified reporting requirements for producers placing less than ten tonnes of packaging annually onto the market in a given EU member state. The chamber has informed all Croatian representatives in the European Parliament of its concerns and requested their support for parliamentary initiatives aimed at securing a targeted impact assessment of the regulation's effects on micro and small businesses engaged in cross-border internet trade. It has also sought backing for the establishment of a single European access point, modeled after the VAT One Stop Shop system, tailored to accommodate sporadic cross-border sales and minimal volumes of packaging. According to HOK President Dalibor Kratohvil, fixed administrative costs that are disproportionate to the volume of packaging and actual business scope can place small traders in a situation where selling in certain countries becomes unprofitable. He warned that this could lead to restricted markets or even complete withdrawal from cross-border sales, contradicting the goal of a unified European market. Despite acknowledging the special circumstances of micro and small enterprises and providing some exemptions and simplifications in specific areas, the regulation does not offer a general exemption from registration and extended producer responsibility obligations. There is no threshold below which sporadic sales into another EU member state would automatically trigger these obligations. Simplified reporting applies only to producers placing less than ten tonnes of packaging annually in a particular member state, but this does not constitute an exemption from registration itself. HOK highlighted that the costs associated with fulfilling obligations under a national extended producer responsibility system and engaging a local authorized representative can be equal to or even exceed the total value of sales made in a given country. A particular challenge for small online traders is the unpredictability of future orders, making it difficult to anticipate which EU member state will be the next source of business. HOK has shared its comments on the regulation with all Croatian representatives in the European Parliament, as well as with EC Commissioners responsible for environment, water supply, and competitive circular economy, Jessica Roswall, and Commissioner for economic performance, implementation, and simplification, Valdis Dombrovskis. The initiative has also been brought to the attention of Kerstin Jorna, head of the Directorate-General for Internal Market, Industry, Entrepreneurship, and SMEs, and Dubravka Šuica, the EC Commissioner for the Mediterranean region.