Shipping Ten Boards Into Four EU Countries Now Costs About €1,150 a Year in Packaging Paperwork. The Packaging Weighs Half a Kilo.

Alain Pannetrat, who runs the open hardware marketplace Lectronz, published a worked example yesterday that is worth reading if you sell anything physical into the EU. An engineer in Greece designs a €25 open source sensor board. In year one he sells five to Germany, two to France, two to Austria and one to Belgium. Each one ships in an antistatic bag inside a padded envelope, about 50 grams of packaging per order. He has just become a registered packaging waste producer in four countries, and the indicative annual cost of that status is roughly €1,150.

Ten boards. Half a kilogram of packaging in total. The environmental contribution owed on that weight is measured in cents.

Where the €1,150 comes from

The EU's Packaging and Packaging Waste Regulation, PPWR, generally applies from 12 August 2026. Extended Producer Responsibility itself is not new; the EU has required producers to help finance collection and recycling of their packaging for years. The premise is fine and I am not going to argue against it. If you put packaging on the market, you should pay toward dealing with it.

What PPWR did not do is create one European system. It preserved the fragmented national model, so a business selling directly to customers across the EU registers and reports separately in every Member State where its packaging becomes waste. Pannetrat's figures, based on prices currently quoted by national schemes and compliance providers, break down like this:

• France: about €110 a year in scheme registration fees, plus €190 to €300 a year for an authorised representative
• Belgium: €50 to €100 a year in administrative fees, plus roughly €250 to €450 for an authorised representative
• Germany: registration is free, scheme participation starts around €10 a year, plus roughly €190 for an authorised representative
• Austria: about €250 a year in administrative fees, plus roughly €100 for an authorised representative

Take the cheapest number in every band and you get €300 for France, €300 for Belgium, €200 for Germany and €350 for Austria. That is the €1,150, and it is the optimistic reading. It does not price the hours spent registering, documenting and filing waste reports in four national systems in four languages.

Now extend the arithmetic to all 27 Member States, which is the entire point of a single market. To make that worth doing, our Greek engineer needs to be selling not ten boards a year and not a hundred, but thousands, from a standing start.

The cost scales with geography, not with anything real

This is the part I keep turning over. Almost every compliance regime I have dealt with as a solo operator scales with something: revenue, transaction count, headcount, data volume. You can model it. You can decide when you cross the threshold where it becomes worth the overhead, and you build toward that.

This one scales with the number of borders you cross, and it does so before your first sale in each country. The fee to be permitted to ship one padded envelope to Belgium is identical to the fee to ship ten thousand. There is no ramp. A regime with a fixed per-jurisdiction entry cost and no de minimis floor does not tax activity, it taxes existence, and it lands hardest on exactly the people generating the least waste.

The comparison that keeps coming up is VAT, and it is instructive. Cross-border VAT used to be similarly awful for small sellers until the One Stop Shop let you register once and file once for the whole EU. The mechanism exists. It works. It has simply not been applied here.

This is not only a hardware problem

Lectronz sells electronics, so the article frames it around makers, but the regulation covers packaging. That means it covers anyone shipping a physical object to an EU buyer. Artists selling prints. Craftspeople on Etsy or on their own storefront. Small food producers. And, relevant to a lot of readers here, anyone running merch as a revenue line next to a newsletter or a SaaS.

If you sell a book, a poster, a run of stickers or a hardware side project into the EU, you are in scope. Pannetrat is also explicit that this applies to any business selling to buyers in the EU, not only businesses established there, so a US or UK indie shipping into Europe is not outside it.

The absurd endpoint he arrives at is one I have not been able to argue my way out of. For a French micro-entrepreneur, shipping to the United States is now administratively simpler than shipping to Belgium, and that holds even accounting for US tariffs. When the cheapest route to your neighbour runs through another continent, the single market has stopped functioning for that class of seller.

What I would actually do

If you are already shipping into the EU at small volume, do three things this month.

First, work out your actual exposure country by country rather than in aggregate. The cost is per Member State, so a seller doing meaningful volume in two countries and one-off orders in six others has a very different problem from a seller spread evenly. In a lot of cases the rational move is to stop shipping to the long tail and keep the two or three countries that carry real volume.

Second, if you sell through a marketplace, ask them directly what they are doing about collective representation before you assume you are covered. Some platforms will absorb this and some will not, and the answer changes your numbers completely.

Third, spend ten minutes on the European Commission's open feedback page for the producer registers initiative, and sign the petition that Jeanette Koňarčíková, a Slovak independent artist, put up asking for a moratorium on cross-border EPR fees. I am usually sceptical about petitions. This one is aimed at a proposal that is genuinely still in motion, which is the only condition under which the exercise means anything.

The honest take, including where I might be wrong

Two caveats I want on the record.

Pannetrat is not a neutral observer. Lectronz takes 5% of transactions, waives the fee on a seller's first five sales, and by his own account currently generates roughly one modest salary. If a meaningful share of his sellers withdraw from the EU, Lectronz gets less viable. That does not make his figures wrong, and he sources them to named national schemes rather than asserting them, but it is the frame he is arguing from and you should know that while reading.

The bigger caveat is enforcement. Pannetrat says plainly that it remains unclear how national authorities will apply these rules to makers and micro-enterprises, and he tells his own sellers not to expect immediate disruption. Regulations that are technically binding on a Greek engineer selling ten boards are not necessarily regulations anyone will act on. It is entirely possible that in two years this reads as an overreaction, that enforcement targets Amazon and Temu and never reaches a garage in Thessaloniki.

I still think the alarm is correct, for a reason that has nothing to do with enforcement. The chilling happens before anyone knocks. A cautious person reading the rules today concludes that selling ten units across the EU is not legally clean, and simply does not start. You never see that loss, because there is no shutdown announcement for a business that did not exist. That is the cost I would push back on, and no amount of lenient enforcement recovers it.

The Commission has proposed suspending the requirement to appoint an authorised representative in each destination country until 2035. It has not been adopted. Even if it is, it removes the largest line item from my table above and leaves the registration fees, the reporting duty and the per-country structure fully intact. It is a discount on the wrong thing.

Author

Lukas

@lukcombinator

Sources

• How Europe is killing makers and micro-entrepreneurs
• Packaging and packaging waste: rules on national registers of producers (European Commission, have your say)
• Stop destroying EU micro-businesses: Immediate moratorium on cross-border EPR fees
• GPSR and EU product safety obligations for small manufacturers