Articles · 2026-09-23
Is a micro-enterprise exempt under the PPWR?
Two articles of the same regulation describe the supplier differently, and in Czechia the rule inverts by packaging type. What a micro-enterprise actually owes.
A small company reads that there is an exception for micro-enterprises and stops there. The exception is real, it is narrower than it sounds, and the regulation describes it twice in words that do not match. Here is what it does and does not cover.
What counts as a micro-enterprise?
Fewer than ten people and a turnover or balance sheet total of no more than two million euro, on the EU definition the regulation borrows. It is a size test, not a trade test: a joinery, a coffee roaster and a cosmetics maker are all micro-enterprises at that size.
Is a micro-enterprise exempt from the PPWR?
No. It is not exempt from the regulation. In one narrow case the duty of the manufacturer moves to somebody else: where the company that would be the manufacturer is a micro-enterprise, the supplier of the packaging becomes the manufacturer instead — and with it the technical documentation and the declaration of conformity.
Where the regulation says two different things
Article 3(1)(13)(b) says the supplier must be established in the same member state. Article 15(12) describes the supplier as located in the Union. Those are not the same sentence. Under the first, a Latvian micro-enterprise buying boxes from Poland stays the manufacturer; under the second, it does not.
The Commission's own FAQ follows the definition rather than Article 15(12), so the safe plan is the same member state — and the other reading is worth keeping in mind, because it is in the text too. We publish both rather than pick the convenient one.
Does the exception cover EPR as well?
No, and this is the part that costs money. The PPWR manufacturer duty and the national EPR producer duty are different duties with different holders. Being relieved of the first says nothing about the second: registration, the kilograms and the scheme fee follow their own national rule. Who registers where, and what the register is called is set country by country.
Czechia inverts it by packaging type
EKO-KOM's methodology, in force since 12 August 2026, splits the question by what the packaging is for. A micro-enterprise is the producer of its own sales packaging, while transport, service and primary-production packaging falls on the packaging supplier — unless the micro-enterprise imports that packaging itself, and then it is back on the hook. And a micro-enterprise supplying an end user in another member state is the producer there for all of it.
One country, three different answers depending on the role of the packaging and where the goods go. That is what "an exception for small companies" looks like once it is written out.
What does a micro-enterprise actually have to do?
Know which of its packaging it is the manufacturer of, hold what that requires for the rest, and register where the country's own threshold says so. The size of the company does not remove the national threshold — it changes who answers for the packaging. What an EPR number is and how to apply for one covers the registration itself.
What a spreadsheet cannot do here
It can hold the numbers. It cannot hold the reason a line has no technical documentation — that the supplier is the manufacturer, on what date that was established, and under which reading of the two. When an inspector asks why a line is empty, the answer is that reason, not the empty cell.
What Tarafex does
Every country row in our EPR table carries the register, the threshold, the source and the date it was checked, and where sources disagree — as they do here — both are shown rather than one. Supplier answers are kept with the name of the person who answered and the date. Tarafex does not register you, is not your authorised representative and does not decide whether an exception applies to your company.
Sources: Regulation (EU) 2025/40, Article 3(1)(13)(b) and Article 15(12); the Commission's PPWR FAQ, second edition, section II.6; EKO-KOM, Metodika č. 1 — Povinné osoby dle PPWR, version 26/02, in force from 12 August 2026, read at source 19 September 2026. Checked 23 September 2026. This is information, not legal advice.