When a company puts its own branding on packaging, it may be considered the "manufacturer" of that packaging, according to the PPWR. This can trigger some additional duties, including conformity assessments, documentation, and compliance checks.
Brand identity vs. compliance
For many businesses, packaging may be an important part of their brand identity. But, in consequence, being responsible for packaging compliance can become quite complicated and resource-intensive. On the other hand, plain, unprinted packaging may weaken brand recognition and customer engagement. As a result, businesses face a difficult choice between maintaining their branding and reducing regulatory complexity.
The debate has already attracted a lot of attention among small businesses: Just how quickly compliance can turn into a bureaucratic issue with public resonance is shown by the Janssen Bakery in Lower Saxony, Germany, as an Instagram Reel about the future of custom-printed paper bags received more than 5,200 likes and over 2,000 comments.
SMEs call for relief and simpler rules
While there are some exemptions for micro-enterprises, they only apply for businesses with fewer than ten employees and a maximum of two million euros in annual turnover or balance sheet total. Accordingly, many SMEs do not qualify for exemption. Clearly, the de minimis thresholds are not a one-size-fits-all solution for small businesses. For larger SMEs, there is no general exemption at all. Critics argue that these obligations can become disproportionate for businesses with low shipment volumes, seasonal sales, or niche products. Craftspeople, bakeries, carpentries, and online retailers are, among others, calling for more practical implementation rules, simplified procedures, and sensible thresholds for smaller businesses.
VERE e.V. is in contact with all relevant stakeholders and keeps its members informed of further developments via the “VERE Insider”.
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