PPWR for Micro-Enterprises: Which Obligations Apply (and Which Do Not)?
The special provision for micro-enterprises is not a blanket exemption from PPWR obligations. But what does it mean in practice for packaging licensing and other requirements? The PPWR has introduced certain relief measures for small businesses. Does this mean they are no longer required to license their packaging? Unfortunately not. Misconceptions like these are widespread and can become costly. The special provision for micro-enterprises does not exempt companies from PPWR obligations across the board.
PPWR and Micro-Enterprises: What Is It About?
Since 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40) has been applicable. In Germany, the Packaging Law Implementation Act (VerpackDG) complements the Regulation with national procedures, including the LUCID Packaging Register.
Under EU law, a micro-enterprise is a company with fewer than 10 employees (full-time equivalents) and an annual turnover or annual balance sheet total of no more than €2 million. In addition, the company must be economically independent. If another company owns more than 25% of the shares, its figures must be taken into account proportionately. The term “micro-enterprise” is not the same as the “small business” concept used in VAT law. In any case, company size does not determine whether packaging must be licensed.
Manufacturer Obligations May Be Transferred to the Supplier
The obligations under the PPWR depend on the role a company has within the supply chain. The PPWR distinguishes between two key roles: manufacturer and producer.
- A manufacturer manufactures packaging under its own name or trademark, or has it manufactured, and is responsible for ensuring compliance with the PPWR requirements.
- A producer is responsible for Extended Producer Responsibility (EPR) in the country where the packaging is first made available on the market. In Germany, this includes financing recycling through participation in a dual system.
There is a special rule for micro-enterprises regarding the role of manufacturer:
If a micro-enterprise has packaging or packaged products designed or manufactured under its own name or trademark and the supplier is established in the same Member State, the supplier is deemed to be the manufacturer. In that case, the supplier is responsible for conformity assessment, Technical Documentation, issuing and retaining the Declaration of Conformity, and fulfilling other PPWR product compliance requirements.
If the supplier is established in another country, the micro-enterprise generally remains the manufacturer.
Importers and Distributors Can Also Become Manufacturers
Importers and distributors are also considered manufacturers if they place packaging on the market under their own name or trademark or modify packaging already placed on the market in a way that may affect its compliance. If the importer or distributor is a micro-enterprise, a supplier established within the European Union may take over the manufacturer’s obligations.
Important: Packaging Licensing and Other EPR Obligations Still Apply
This is where many misunderstandings arise. The special provision only transfers the role of manufacturer, meaning responsibility for product compliance. It does not exempt companies from Extended Producer Responsibility (EPR). Any entity that first makes packaging available on the German market is considered a producer, regardless of company size. This primarily applies to sales packaging, grouped packaging, e‑commerce/shipping packaging and service packaging that typically become waste at private end consumers.
For micro-enterprises, this means:
- Registration in the LUCID Packaging Register
- Participation in a dual system
- Reporting packaging quantities both in LUCID and to the dual system
There is no minimum threshold. Even very small packaging quantities remain subject to licensing requirements.
PPWR Obligations for Micro-Enterprises at a Glance
If You Are a Manufacturer under the PPWR (Article 3(1)(13)) and Your Supplier Is NOT Established in the Same Member State:
- Conformity assessment
- Preparation and maintenance of Technical Documentation
- Issuing a Declaration of Conformity
- Packaging marking with the manufacturer’s identification details
If You Are a Producer under the PPWR (Article 3(1)(15)):
- Registration in LUCID
- Participation in a dual system (e.g. Noventiz Dual)
- Reporting packaging quantities to both LUCID and the dual system
- If placing packaging on the market in other EU countries for the first time: registration in the respective producer registers and fulfilment of local EPR obligations
Ob Whether you are a large company or a small business, there is no packaging licensing without LUCID registration, as the LUCID number is required to conclude an agreement with a dual system. Groß- oder Kleinunternehmer: Ohne LUCID-Registrierung gibt es keine Verpackungslizenz, denn die LUCID-Nummer wird für den Vertrag mit dem dualen System benötigt.
Additional Exemptions for Micro-Enterprises
Under certain conditions, micro-enterprises are exempt from further requirements, including some reuse targets. However, this only applies if they place no more than 1,000 kg of packaging on the market per calendar year in a Member State.
In addition, micro-enterprises that sell takeaway food or beverages are not required to offer reusable alternatives. However, they must still accept and fill containers brought by customers.
Conclusion: Relief Yes, Exemption No
The PPWR reduces certain compliance obligations for micro-enterprises, but only under clearly defined conditions. It does not eliminate packaging licensing obligations. Companies should therefore assess separately whether they qualify as a manufacturer and/or a producer.
With Noventiz, you can license your packaging in three simple steps: register in LUCID, conclude your contract online via our licensing calculator, and report your packaging quantities in LUCID and to Noventiz.
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