Impact of EU packaging rules from a small business perspective (Reddit thread)

Quoting the content here, excuse the length. The author is the owner of a small Tamagochi repair business: https://ko-fi.com/tamaspa. Though he removed his offering from his shop until he’s sure he’s good with the regulation.

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Here is a summary of what this means in practice for me and my business, Tama Spa & Repair:

I design, manufacture and sell small electronic accessories for old and new Tamagotchi and similar virtual pets via my online shop. I place particular emphasis on ensuring that my products are as easy as possible to repair and that the schematics are available to others.

In addition, I also repair Tamagotchis and similar devices for customers, ranging from old models (1997) to new ones (2026). Often, only minor repairs are needed to get them working again, but most Tamagotchi enthusiasts are unable to carry these out themselves, either because they lack the right tools or do not have the necessary skills.

A recent example is the ‘Tamagotchi Paradise’, which was released in 2025. A problem with the resonator has been increasingly reported in this model, which makes it impossible to progress in the game. I have already replaced this component in a number of devices that were purchased abroad, making a warranty claim or return impractical for the customers. Without my service, these devices would have ended up in the bin.

What PPWR (packaging waste) and WEEE (electronics waste) mean to me:

As of now, I would have to register with the relevant authorities in every EU country to which I wish to ship goods, and pay annual registration, system and minimum fees, which vary depending on the Member State, plus volume-based charges. The latter are often negligible, as I would only be shipping very small quantities of products to the respective countries.

However, the remaining charges quickly add up to several hundred euros per country, which, for me as a manufacturer and seller of electronic products subject to both WEEE and PPWR, will mean that I will have to severely restrict the EU countries to which I can still ship without the charges exceeding my profit.

What ultimately led me to suspend EU-wide shipping and the provision of my repair services until further notice however is the requirement to appoint an authorised representative. Commercial providers such as Lizenzero charge €300 for an authorised representative, which would mean an additional cost of €600 per year for me for each EU country.

This is financially unfeasible for me because of the small quantities I would be sending to each EU country. The costs far exceed the profit I would make in any one EU country.

I’m not opposed to taking responsibility for my electronics and packaging waste: I’m registered in Germany with LUCID & Green Dot (PPWR) and will be with EAR (WEEE) in the near future. I use reusable packaging wherever possible, avoid unnecessary plastic, repair items that would otherwise end up in the bin, and ensure that my own products can be repaired.

In my case, the additional obligation to appoint an authorised representative under the PPWR and WEEE framework would not result in more packaging or electrical and electronic equipment being collected or recycled, nor would it make my business more environmentally responsible. Rather, it would simply mean that I would no longer be able to offer my products and repair services in neighbouring EU countries.

The absurdity becomes particularly apparent to me when carrying out repairs for customers from other EU Member States: if a customer sends me their Tamagotchi in packaging that has already been used, and I reuse that very same packaging for the return shipment after the repair, it is unfortunately not legally clear to me at present what PPWR obligations this might entail. In the worst-case scenario, I would have to fulfil obligations in the destination country and possibly even appoint an authorised representative for packaging that the customer provided themselves and which I deliberately reuse.

Furthermore, with this sort of used packaging provided by the customer, it is practically impossible for me to verify where and by whom it was originally first placed on the market, which is an obligation under PPWR in this case. In cases of doubt, this even creates the counterintuitive incentive for me to use new, clearly traceable packaging instead of this existing used packaging.

There is NO de minimis threshold with regard to obligations, neither under WEEE nor under PPWR. This means that, as a micro-enterprise, I face the same costs as Amazon if I want to ship throughout the EU. It’s crazy.

Approximate annual (conservative) cost estimates for the whole of the EU: - €300 per authorised representative × 26 = €7,800 - ~€150 fee for WEEE/PPWR × 27 = €4,050

Total: 11.850€

As my products and their shipping packaging are subject to both PPWR and WEEE regulations respectively, the total would be double that, i.e. around €24,000.

It’s important to bear in mind that this comes BEFORE the first parcel I send or the first product I sell.

The actual disposal charges for packaging waste and electronic waste, based on my estimated quantities, are usually only a few euros. In Germany, I would only have to pay 4 (FOUR) cents for that amount of electronic waste. The administrative costs therefore amount to many, many times more than the actual disposal charges.

Sorry for the wall of text – I’m a bit annoyed

PS: There are two proposals to suspend at least the obligation to appoint an authorised representative under the WEEE and PPWR directives until 2035, at least for micro businesses; the first parliamentary hearing is scheduled for October: 2025/0395(COD) (PPWR) and 2025/0396(COD) (WEEE).