When new regulation arrives, very small businesses hope to be kept out of its reach. With the PPWR, the picture is more nuanced: the regulation does provide relief for micro-enterprises, but never a general exemption. Confusing the two can prove costly. Regulation 2025/40, which applies from 12 August 2026, grants a few targeted exemptions to the smallest businesses while maintaining the core obligations that attach to placing packaging on the market. Understanding where that line falls is precisely what matters for a micro-enterprise.

Micro-enterprise: who does the PPWR mean

The category is not a matter of subjective judgement. Under Union law, a micro-enterprise is a business with fewer than ten employees whose annual turnover or balance sheet total does not exceed two million euros. It is this exact threshold that opens, or closes, the door to the relief on offer. A business that exceeds either ceiling leaves the micro regime and falls under the obligations that apply to other businesses.

What a micro-enterprise can be relieved of

The exemptions are real, but confined to identified subjects.

Reclassification from manufacturer to supplier

This is the most structural form of relief. When a micro-enterprise has packaging made under its own brand and its supplier is established in the same Union country, it is the supplier that is treated as the manufacturer for the purposes of the regulation. The micro-enterprise then does not have to carry the technical documentation and packaging conformity obligations itself, as these rest with the supplier. This mechanism does, however, require both conditions to be met: the own brand and the supplier in the same country.

Certain reuse obligations

The regulation sets reuse targets for several packaging categories, particularly in beverage distribution. The smallest businesses benefit from adjustments to part of these targets, which are aimed first at operators of significant size.

What still applies regardless

Relief should not be read as falling outside the scope. Several obligations apply whatever the size of the business.

Extended producer responsibility is still owed. A micro-enterprise that places packaging on the market must contribute to EPR and, in most cases, register on the producer register. That registration is in fact a condition for being listed on marketplaces by those who sell online.

Substance restrictions apply too. The ban on PFAS in food-contact packaging, effective from 12 August 2026, allows no derogation based on size.

Finally, where the reclassification mechanism does not apply, for instance if the supplier is outside the Union or the packaging is not under your brand, the packaging conformity obligations become yours once again.

The right approach

For a micro-enterprise, the right approach is not to ask whether it is exempt, but to check precisely which forms of relief apply to its situation, and therefore what remains its responsibility. The answer depends on your exact role in the chain, a subject we set out in detail in our article on who is affected by the PPWR.

For a quick read, the EPR Responsibilities tool places your case in a few questions and lists your concrete obligations. The regulatory roadmap gives you the deadlines, and the complete PPWR guide covers every requirement in detail.

A question about your specific situation? Write to us at contact@packaginghub.fr.