The new Packaging and Packaging Waste Regulation (PPWR) aims to reduce packaging waste, strengthen the circular economy and reduce the environmental impact of packaging. Its objectives include improving the recyclability of packaging, increasing the use of recycled materials and harmonising rules across the EU Single Market.

The regulation has sparked widespread public discussion since the beginning of autumn. Ornamo has also received several enquiries from members about its practical implications. Small design businesses, sole professionals, artists and freelancers in particular have raised questions about what the new requirements mean for small-scale cross-border sales and exhibition activities.

Ornamo has brought members’ experiences and concerns forward and submitted a statement to the European Commission on the implementation of the PPWR. In the statement, we emphasise the need for proportionality: the obligations and costs arising from the regulation should be proportionate to the size of the business and the actual volume of packaging it places on the market.

For a small design business or an individual artist, separate registration, reporting and authorised-representative requirements in different EU countries can create a significant administrative and financial burden, even when sales volumes are very low. Fixed costs, the need for external expert services and the time required to navigate several national systems can become disproportionate to the value of individual transactions.

In our statement, we call, among other things, for:

• harmonised registration and reporting requirements across Member States
• a once-only principle for providing information wherever possible
• a simple one-stop solution for businesses operating in several EU countries
• clear and practical guidance for small-scale cross-border sales, the shipment of individual products and artworks, and exhibition activities
• a level playing field for European small businesses in relation to operators selling into the EU from outside the Union.

A functioning Single Market is in everyone’s interest. Achieving environmental objectives and maintaining a well-functioning European Single Market are not mutually exclusive goals. Small businesses and individual professionals must also be able to participate in the Single Market without fixed compliance costs and administrative work becoming disproportionate to the scale of their activities.

Thank you to our members for your active engagement and comments. The concrete experiences shared by members have been an important starting point for Ornamo’s advocacy work and our statement. Practical examples help us identify situations where the regulation creates uncertainty, costs or an unreasonable administrative burden.

The work continues. We are still collecting members’ experiences of the PPWR and will use them as the EU and Finnish authorities further clarify the implementation of the regulation and related guidance.

Share your experience of the PPWR

You can respond to the survey even if you have already been in contact with Ornamo. Concrete examples relating to online sales, shipping individual products or artworks to another EU country, or participating in exhibitions abroad are particularly valuable to us. You will find the link to the survey on our member newsletter (Sent out 3.9. & 16.9.) or in our member page.

We will continue to monitor the implementation of the regulation and bring members’ experiences into the discussion. Our aim is to ensure that the implementation is as clear, proportionate and workable as possible for small design businesses, artists and other professionals in the field.