EU PPWR EPR Talks What Small Paper Tube Brands Should Prepare Now

The European Union is negotiating a targeted change to the Packaging and Packaging Waste Regulation, or PPWR, that could reduce one administrative burden for some cross-border producers. The issue is the obligation to appoint an extended producer responsibility, or EPR, authorised representative in every Member State where a producer makes packaging available without being established there.

As of 6 November 2026, the change is not final law. The European Parliament adopted its negotiating position on 20 October, and the Council agreed its mandate on 21 October. Their approaches differ. A buyer should therefore separate the current PPWR rule, the Commission proposal, the Parliament position and the Council position before changing registrations, contracts or packaging-data systems.

For small brands using custom paper tubes, the safest response is practical: identify who is the producer in each sales route, keep market-by-market packaging quantities and maintain component-level specifications. This article explains the preparation work and is not legal advice.

The Current Legal Position

The European Commission states that the PPWR authorised-representative requirement has applied since August 2026. A producer established in one Member State and supplying packaging into another may be required to appoint an EPR authorised representative in the destination state. A producer established outside the EU faces a similar question when it first makes packaging or packaged products available in a Member State.

On 10 December 2025, the Commission proposed suspending part of that requirement for certain EU-based cross-border producers. While the proposal is examined, the Commission has asked Member States to enforce the rule pragmatically and to refrain from sanctioning operators. That message does not amend the PPWR.

Keep Four Positions Separate

The Existing PPWR Rule

Until an amending regulation is adopted and applies, businesses should use the current rule as the legal baseline. Do not cancel an authorised-representative arrangement or skip a national registration merely because relief has been proposed.

The Commission Proposal

The Commission proposed a temporary suspension for EU-established cross-border producers, with the broader simplification expected to be addressed later through the Circular Economy Act. Other EPR responsibilities would continue. The proposal did not create a general exemption for packaging placed on the EU market.

The Parliament Position

The Parliament position supports targeted relief for small and micro enterprises established in the EU. It keeps the authorised-representative requirement for producers established in third countries and makes clear that the change concerns the appointment duty, not the rest of EPR. Parliament referred the file for interinstitutional negotiations after adopting amendments by 616 votes to 9, with 39 abstentions.

The Council Position

The Council mandate would allow an EU-established producer to avoid appointing a representative in another Member State when it places less than one tonne of packaging in that state during a calendar year. The mandate includes safeguards for breaches, a review by 31 December 2030 and a scheduled expiry in 2032. These details are a negotiating position, not a current exemption.

Why the One Tonne Number Is Not Yet a Rule

The one-tonne figure could affect low-volume brands testing several markets, but it is easy to misread. The Council describes a threshold per destination Member State and calendar year, not one EU-wide total. Parliament chose a different small-and-micro-enterprise approach.

The final text may follow one position, combine them or change the dates and safeguards. Businesses also need the final measurement and registration details before treating a threshold as operational. A spreadsheet labelled “under one tonne” is not enough unless the recorded packaging scope, destination market, period and responsible legal entity are clear.

Identify the Producer Before Ordering Packaging

EPR responsibility does not automatically attach to the factory that makes an empty paper tube. The responsible producer can depend on who first makes the packaging or packaged product available in a Member State and on the actual sales model. A brand selling directly to consumers, an EU importer buying finished goods, a distributor using its own name, or a contract packer may have different roles.

Map each route separately. Record the brand owner, seller, importer of record, fulfilment operator and destination Member State. Confirm which entity owns the EPR registration and which entity appoints the representative. Contracts should support the agreed allocation, but contractual wording cannot override legislation.

Build a Market by Market Packaging Record

For every SKU and destination, keep the number of units, shipment dates, packaging levels and controlled packaging version. Separate consumer-facing packaging from grouped and transport packaging where reporting rules require it.

For a paper tube package, the bill of materials should identify the paperboard body, printed wrap, adhesive, coating, liner, base, lid, seal, insert and label. Record the mass and material category of each component and document the test or weighing method. Include the corrugated shipping carton, dividers and protective material in the relevant transport-packaging record.

Do not use a design estimate forever. Weigh an approved finished sample, record the instrument and date, and update the dataset when the lid, liner, board grade, insert or carton changes. Link the value used for reporting to the artwork and specification revision.

What Possible Relief Would Not Remove

The current legislative discussion is narrow. Parliament’s research service explains that the proposed relief concerns the duty to appoint an authorised representative. Other EPR obligations, such as registration, reporting, financial contributions and compliance with packaging rules, would continue. A business below a future threshold could still need accurate data and other national arrangements.

Component weights, material classifications and market quantities remain useful under either position. They support registrations, producer responsibility organisation declarations, fee calculations, audits and future eco-modulation.

What to Request from a Paper Tube Supplier

· A controlled drawing with internal and external dimensions and the approved closure system.

· A component bill of materials that separates the tube body, wrap, liner, base, lid, seal and insert.

· Component and finished-pack weights with the measurement date, sample version and stated tolerances where available.

· Material descriptions that avoid unsupported recycling, recycled-content or certification claims.

· Artwork and specification revision codes linked to the approved physical sample.

· Written change notification before a material, supplier, coating, adhesive, liner, closure or insert is substituted.

Wenzhou Yiya Packaging Co., Ltd. states that it was established in 2000 and operates five fully automatic lines, three semi-automatic lines and three Heidelberg presses. These capabilities can support controlled printing and production versions, but the buyer should define the reporting fields and approve the exact package used in its EPR data.

A Practical Action Plan During Negotiations

Use the Current Rule as the Baseline

Maintain current appointments, registrations and deadlines unless the competent authority or qualified adviser confirms another approach. Save the Commission, Parliament, Council and EUR-Lex status pages with access dates.

Prepare Two Scenarios

Scenario one follows the existing appointment requirement. Scenario two models both the Parliament small-enterprise test and the Council per-Member-State threshold. Use the model for budgeting, never as adopted law.

Control Packaging Versions

Freeze the sample and bill of materials used for the market calculation. If a lighter lid or a different liner is introduced, update weights prospectively and keep the prior record for earlier shipments.

Review the Final Text Before Acting

Check the adopted amending regulation, its application date, definitions, thresholds and transitional provisions. National guidance may still be needed for registration and representative procedures.

Conclusion

The EU’s EPR authorised-representative debate may reduce administration for some small cross-border producers, but no buyer should treat the Council’s one-tonne figure or Parliament’s small-enterprise test as final law today. The durable work is to identify the producer, calculate packaging by destination, control the paper tube bill of materials and preserve evidence for every reporting version.

Contact Yiya Packaging with the product, destination markets, intended tube structure and reporting fields. Request a physical sample, component specification and controlled artwork version before mass production so the packaging data can follow the approved design.

Frequently Asked Questions

Is the One Tonne Exemption Already Law

No. It is part of the Council negotiating mandate agreed on 21 October 2026. Parliament has a different position, and the ordinary legislative procedure is still ongoing.

Would the Proposed Relief Apply to a China Based Producer

The Parliament position keeps the appointment requirement for third-country producers. The final rule has not been adopted, so a China-based seller or the relevant EU importer should obtain market-specific advice for each sales route.

Would Relief Remove EPR Reporting or Fees

No general removal is proposed. Official parliamentary analysis states that other EPR obligations continue even where the authorised-representative appointment is suspended or exempted.

What Paper Tube Data Should a Buyer Request

Request component materials and weights, the complete pack weight, packaging level, approved artwork and specification revisions, closure and liner details, measurement date and change-control records.

Is the Packaging Supplier Automatically the EPR Producer

Not necessarily. The producer role depends on who makes the packaging or packaged product available in the market and on the sales route. The brand and importer should document the role analysis; the supplier should provide accurate controlled packaging specifications.