The EU commission killed the indie mailorders as of today

From 12 August 2026, today that is, small European record labels and mail-order businesses selling CDs and vinyl across EU borders face a new layer of packaging bureaucracy. The environmental goal behind the PPWR is easy to understand, but the way cross-border EPR has been organised is much harder to defend. Actually, it’s not defendable at all, and you wonder how otherworldly these bureaucrats really are.

A packaging law with consequences far beyond packaging

Today, 12 August 2026, the EU’s Packaging and Packaging Waste Regulation, better known as PPWR, starts applying across the European Union. Most consumers will barely notice, but independent labels, artists, specialist record shops and small mail-order businesses could notice very quickly.

The PPWR is meant to reduce packaging waste, improve recycling and make producers pay for the collection and treatment of packaging they place on the market. Few small businesses will object to that principle. The trouble however starts when a tiny seller ships directly to a customer in another member state.

Under the new framework, the seller can become the packaging producer for EPR purposes in the country where the order is delivered and where the packaging will eventually become waste. A German label mailing a CD to France can therefore face French EPR obligations. A vinyl order sent to Germany brings German obligations into play. Austria, Italy, Finland or Portugal each add another national compliance system.

The European Commission’s own 2026 guidance confirms that a webshop selling packaged goods directly to an end user in another member state is the producer for EPR purposes in that destination country.

Who actually proposed this bureaucratic PPWR atrocity?

The cross-border representative requirement was not an amendment dreamed up later by the European Parliament or quietly added during negotiations with national governments as it was already present in the European Commission’s original PPWR proposal of 30 November 2022.

In that draft it appeared as Article 40(2). The Commission proposed that a producer should appoint an EPR representative in every member state other than its own where it placed packaging on the market. After the legislation was negotiated and renumbered, that provision became the current Article 45 requirement.

So where did it come from? The author of the proposal was the European Commission’s Directorate-General for Environment, DG ENV. The proposal was then adopted by the first Commission headed by Ursula von der Leyen on 30 November 2022.

The two politicians who publicly fronted the package that day were – of course who else – the climate extremists Frans Timmermans, then Executive Vice-President of the European Commission responsible for the European Green Deal, and Virginijus Sinkevičius, then European Commissioner for Environment, Oceans and Fisheries. Both presented and publicly proudly defended the Commission’s new packaging rules at their launch.

Parliament had the chance to remove the PPWR, but did nothing

But the responsibility does not end with the Commission. A Commission proposal does not become EU law on its own. In the European Parliament, the politician with primary responsibility for steering the PPWR through the legislature was Belgian MEP Frédérique Ries of Renew Europe/Mouvement Réformateur. She was appointed rapporteur for the Parliament’s Environment Committee in January 2023, drafted the parliamentary report and handled compromise amendments and negotiations on Parliament’s behalf.

The parliament had ample opportunity to amend or remove it during the legislative process, but surprisingly they hardly tried so the requirement survived. On 24 April 2024, the European Parliament approved the PPWR by 476 votes in favour, 129 against and 24 abstentions.

In short, a large majority of elected MEPs voted for the package that contained it.

National governments signed off too

On 16 December 2024, the Council formally adopted the PPWR. The vote was 26 countries in favour and one against. The only member state that voted against the final regulation was Slovakia. Belgium voted for it. France voted for it. Germany voted for it. The Netherlands voted for it. Italy, Spain, Austria, Denmark, Sweden, Poland and 16 other countries voted for it as well.

There is no shortage of people or institutions to hold politically accountable.

One small mailorder, but several national PPWR systems

For the independent music business, the result is painfully concrete. A label may press 300 copies of an album and sell 150 at home. The remaining copies go to customers scattered across Europe: ten to France, six to Germany, three to Finland, two to Portugal, one to Slovenia. Those are ordinary cross-border sales in what is supposed to be a Single Market. For packaging compliance, however, they can become separate national obligations.

There is no single EU packaging registration covering all 27 countries. There is no central declaration filed in Belgium, Germany or France that follows the seller across the Union. National registers, national schemes, national reporting and locally established representatives remain part of the system.

That may be manageable for Amazon or Universal Music, but It is a very different proposition for a mailorder selling a few thousand records per year.

Small volume does not mean no obligation

Many independent sellers will logically assume there must be a threshold below which none of this matters. But, there is no broad exemption based on turnover or parcel numbers.

The PPWR does provide lighter reporting for producers placing less than 10 tonnes of packaging per year on a national market. And almost every indie label or mailorder will sit far below that figure. The lighter reporting rules, however, do not erase the underlying producer status or the country-by-country EPR structure.

A label may send only a few kilograms of cardboard into a country during an entire year and still face fixed administrative costs that bear little relation to the amount of waste it actually generates.

A few records can trigger hundreds of euros in costs, per destination that is

A 2026 price list published by EPR compliance provider Eldris illustrates how quickly those costs can rise. Its published packages range from roughly €360 per year for Germany to €1,485 for Slovenia, depending on the country and services included. Adding the listed prices for all 27 EU member states produces a total of around €17,860 for the first year.

These are commercial prices, and other providers may charge less, but you get an idea how ridiculous this has gotten. Businesses can also handle parts of the administration themselves. Yet the reason such an EPR compliance industry exists is obvious: a small seller is being asked to cruise through different registers, schemes, representatives, declarations and deadlines across multiple countries.

The economics turn ugly very fast. If a label sells 20 records into one country and spends €400 annually on compliance there, that fixed cost equals €20 per order. Sell five records and it becomes €80 per order, before postage, VAT, payment fees, manufacturing, packaging and artist royalties enter the calculation.

Stopping sales to that country then becomes cheaper than complying with the rules required to sell there. And that is what is happening now. Small retailers have already started cutting EU destinations. German businesses Pikecraft and Valkyrie Parts explicitly blame PPWR for reducing the countries they will serve, while Betta Botanicals in the US has stopped EU shipping altogether.

The Commission knew it had created a problem with the PPWR, but still went ahead

This is where the story becomes particularly uncomfortable for the European Commission and all the politicians involved, hundreds that is in every member state.

By the end of 2025, the Commission was already trying to suspend the very authorised-representative requirement that had appeared in its own 2022 proposal. It proposed delaying the obligation for EU businesses until 1 January 2035, explicitly recognising that fragmented EPR requirements create barriers to cross-border business inside the Single Market.

That attempt failed to produce relief before 12 August 2026. On 24 June 2026, the Council reported that negotiations on the proposed changes had been discontinued after a large majority of member states raised strong reservations. The regulation therefore reached its general application date with the problem unresolved.

The Single Market starts looking less single after PPWR

This is the contradiction at the heart of the system. Europe spent decades removing barriers to cross-border trade, only to construct a packaging regime capable of making the destination country relevant again for a €20 CD. Charging a seller according to the amount of packaging waste it creates is defensible. Making that seller establish separate compliance arrangements because five people in another member state bought records is something else.

As a result, large retailers will absorb the change while small sellers will reduce their reach significantly.

PPWR does not discriminate between Amazon and an indie label on paper. That is precisely the problem. It subjects radically different businesses to fixed country-by-country obligations whose cost Amazon can spread over millions of parcels while an independent label may have only three customers in that country. Equal rules do not produce equal consequences when the compliance cost is largely fixed.

It remains to be seen whether common sense will return to Brussels.