Simply not true. The helpful diagram you refer to does not consider the case where company A manufactures the packaging, company B buys the packaging, and then does a B2C delivery to another member state. In that case company B is the producer, even if B is a "micro-enterprise".
> the discussion here seems to have a lot of people who are in a big rush to demonize their perceived political opponents on ideological grounds.
No, it is the opposite. There are a whole lot of people trying to rationalize something crazy. Nevertheless, countless online shops in the EU run by small business have already closed thanks to these regulations. Even if your assertion that this is a giant misunderstanding were true, the damage is already done.
the case where company A manufactures the packaging, company B buys the packaging, and then does a B2C delivery to another member state
In that case company A is the producer. Also, even if the packaging is branded, company A is the producer if company B is a micro-enterprise. Looking through the document further, I notice that producers aren't even liable for detailed reporting until they put 10 tons of packaging material onto the market.
There are a whole lot of people trying to rationalize something crazy. Nevertheless, countless online shops in the EU run by small business have already closed
I'm sure you can find less emotive ways to make your point, like offering some approximate estimates of how many of these small businesses have closed.
The entity that introduces the packaging is responsible for upholding the packaging laws. The manufacturing entity of the packaging is not and cannot be responsible, because it does not decide to which countries the packaging is ultimately sent to.
And even if it worked that way, if you add a CE certified module to your product, the product as a whole still has to be CE certified.
Under definitions (page 9) there's a big section
> 6) Who is the ‘manufacturer’ of branded packaging? NEW!
And it starts off this blurb:
> According to the PPWR (Article 3(1), point (12)), if a packaging does not bear a name or trademark, the manufacturer will be the natural or legal person who manufactures packaging or packaged products.
Seems pretty obvious to me the generic bubble envelope example from the blogpost doesn't make sense because that is generic packaging where the manufacturer has to handle this.
>the manufacturer will be the natural or legal person who manufactures packaging or packaged products.
Manufactures packaged products means you buy flat pre-cut card board, fold it, insert the product and then close the box and tape it shut. Even if you bought fully assembled packaging and somehow teleport the product into the packaging, that would still be considered manufacturing a packaged product.
>Seems pretty obvious to me the generic bubble envelope example from the blogpost doesn't make sense because that is generic packaging where the manufacturer has to handle this.
I'm not sure about the part "doesn't make sense" because it could go either way (you disagree with the regulation or you disagree with the example), but what's obvious is that manufacturer is the Greek engineer and he is responsible for the packaging of the product.
This whole discussion is the reason innovation it's dead in Europe. The regulations are so complex that you need a team dedicated to navigating the bureaucracy nonsense. Small companies and startups can't do that.
My mom sometimes buys wool from online wool sellers which often are other 60 year old ladies who really don't know much about the internet or business.
These are affected, too, and will probably all stop selling to other EU countries because how could they ever fully grasp that regulation in all its details.
It's a shame, life and doing business is difficult enough already, and then millions of people get those regulations thrown at them.
They already had a big wave of newsletter closures when the EU's GDPR came around and everyone was scared to handle customer data. Now here's the next round.
Same tax on software, just less visible. A solo browser extension or a tiny site still has store review, OAuth consent, privacy pages, and a different "are we a company" answer in FR vs UK. No parcel, still a lawyer-shaped afternoon before you can take a euro. The FAQ-as-PDF problem is the product.
The article is actually saying they've had record sign ups this year and as far as I can see doesn't make any comment about a decrease in sales in the last 2 weeks since the implementation of this regulation. There is a first hand report of someone stopping their shipping really far down on this post, and then someone on that chain links to a reddit comment from someone as well.
I'm sure there's probably a few comments I missed, but idk if I'd say there's proof of countless here or in the article.
It does seem like it'd have a chilling effect if the article's interpretation is correct, and other comments here also stated that the EU commission wanted to have a central registry to minimize the overhead.
> the discussion here seems to have a lot of people who are in a big rush to demonize their perceived political opponents on ideological grounds.
No, it is the opposite. There are a whole lot of people trying to rationalize something crazy. Nevertheless, countless online shops in the EU run by small business have already closed thanks to these regulations. Even if your assertion that this is a giant misunderstanding were true, the damage is already done.