EU packaging consultation: will business feedback make a difference?

The European Commission is consulting on draft rules intended to harmonise how packaging producers register and report under the EU Packaging and Packaging Waste Regulation. The proposal would introduce common formats for national producer registers, covering company details, extended producer responsibility arrangements, producer responsibility organisation certificates and authorised representatives. It would standardise the packaging data companies submit.

For businesses operating in several Member States, greater consistency could reduce administrative fragmentation. However, this is not a single EU registration system: obligations would remain linked to each national market. Producers may therefore still have to manage multiple registrations, schemes and certificates.

The implications could be significant for small and medium-sized companies. Businesses will need information on the weight and composition of packaging components, including the separate materials used in composite packaging. The proposal distinguishes between producers placing less than 10 tonnes and those placing 10 tonnes or more on a national market, offering simplified reporting below the threshold. But the threshold is not a general exemption from extended producer responsibility. Smaller firms may still face data, systems and supplier-management costs that are proportionately heavier than for large companies.

The consultation, open from 6 August until 10 September 2026, has attracted more than 3,000 responses already, with almost a month remaining. That level of interest sends a political signal, but numbers alone do not ensure influence. A short submission may be recorded without materially shaping the final act.

Companies seeking meaningful change should make their response specific: identify problematic fields, quantify compliance costs, explain where data are unavailable and propose workable alternatives. They should coordinate with trade associations and like-minded businesses, provide evidence across several Member States and engage with Commission officials and national authorities. Consultation participation matters, but it is most effective as one element of an EU advocacy strategy.