A members' association · Vienna
Nobody should have to close their shop to Europe over paperwork.
Thousands of small makers stopped shipping to the EU this year — not because they did anything wrong, but because the admin costs more than they earn. KontorBund is the group that buys it together, publishes what each country really needs, and refuses to let this be normal.
0 / 100 founding members
Signups plus the open Discord. We go and negotiate at 100.
What changed
There is no single European window.
Put packaged goods on the market in an EU country where you aren't established, and that country wants two things: a registration in its own register, and an authorised representative based on its own soil. Per country. Twenty-seven times, in twenty-seven languages, with twenty-seven deadlines.
The fees aren't the problem
The recycling fees themselves are worked out by weight. Ship a little and you pay a little — that part is fair, and it isn't what's closing shops.
The paperwork is
Registration and a representative cost roughly the same whoever you are. That flat charge is what makes selling a few hundred euros of handmade goods into a country stop making sense.
Art. 45(3), and it
applies wherever you aren't established. What is fragmented is everything
underneath: twenty-seven registers, twenty-seven procedures, twenty-seven
providers to buy from. The Regulation does require the registers to converge and
to link to one another, but member states have eighteen months from the
Commission's implementing act to build them and the first harmonised report isn't
due until 2030. So this is the transition, not the design — which is a reason to
argue about how it was sequenced, and no help at all to anyone shipping a parcel
this week.
The cost
Same paperwork for a shoebox as for a warehouse.
A maker shipping 40 kg a year
A distributor shipping 40 tonnes a year
A thousand times the volume. Exactly the same paperwork bill. A fixed cost with no volume threshold isn't a fee on trade — it's a fee on being small. That's the thing we're here to change.
And that isn't only unfair. It's against the rules.
This is the part almost nobody quotes, so here it is in full.
Art. 46(5) of the same Regulation that created these duties says:
"Producer responsibility organisations shall ensure equal treatment of producers regardless of their origin or size, without placing a disproportionate burden on producers of small quantities of packaging, including packaging of packaged products, including small and medium-sized enterprises."
That binds the schemes themselves — ARA, Interzero, Citeo, Der Grüne Punkt — not
just governments. Art. 44(11)(d) adds that registration fees must be
"cost-based and proportionate", and Art. 45(2) that EPR costs must be
set "in a transparent, proportional, non-discriminatory and efficient way".
Which is why the Observatory is the other half of this association and not a side project. A median cost per €1,000 of revenue is a talking point. The same number, put to a scheme that is legally required not to place a disproportionate burden on small producers, is evidence. Nobody has collected it yet. That's the job.
What we do
Pool it. Publish it. Prove it.
Pool it
We negotiate representative and registration fees as one block instead of everyone paying the retail rate alone. Where a country allows it, the representative we appoint can handle your registration too. A hundred small shops turning up together is a completely different conversation.
Publish it
A free, open, country-by-country guide to what each member state actually asks for — every entry dated and re-checked. Nobody else publishes this openly, because the sector makes its money from the confusion.
Prove it
We collect real quotes from members, aggregate them so no shop is ever identifiable, and take the median cost per €1,000 of revenue to the people writing the rules. Nobody has that number yet, because nobody is collecting it.
From the community
If EPR changed how you sell, that's evidence.
Lea Henke | Lea Terletzki runs the EU EPR / PPWR Microbusiness Experience Survey — an independent project documenting what compliance actually looks like for micro and small businesses: registrations, fees, the research, restricted shipping, markets given up. KontorBund supports it with outreach and distribution, and does not receive access to raw survey responses.
What the survey documents
- What registration, fees, representatives and the research itself cost you
- The administrative workload, country by country
- Countries you stopped shipping to, or considered dropping
- Workarounds you had to build
- Other consequences for your business
Taking part
- Around 5–10 minutes
- You can take part anonymously
- Free-text answers in your preferred language
- Findings may be used in aggregated or anonymised form, for policy briefs and outreach on PPWR, EPR simplification and the European Single Market
“I can't promise that filling this out will change the law. What it can do is help make sure that the real effects on microbusinesses are actually documented when those rules are discussed.”
Lea Henke | Lea Terletzki · EU EPR / PPWR Microbusiness Experience Survey
If EPR has affected your business in any way, your experience is useful evidence.
Take the survey — 5–10 minutesYou're not the only one
What it sounded like when the shops closed.
When the Commission opened feedback this August on packaging and recycling criteria, twenty-nine people wrote in — most of them one-person shops, describing the fortnight they closed their EU shipping. Every card links to the submission it is quoted from.
A microenterprise gets treated like a multinational polluter for shipping a few boxes.
Sole trader, Hungary Feedback F33563810 · 18 August 2026 “We looked into the requirements and found that we would have to pay around 5,000 per year to register for PPWR compliance across Europe.
Board-game shop, Germany Feedback F33559730 · 15 August 2026 “I do not understand how my one person pottery business, that ships 30-45 packages across Europe PER YEAR needs to research, register, complete endless paperwork and pay the same as Amazon.
Pottery, Portugal Feedback F33558702 · 14 August 2026 “Expecting a one-person shop to register in multiple EU countries, pay hundreds of euros in fixed annual fees, and hire foreign representatives just to send a few handmade parcels a year is absurd.
Independent creator, Slovakia Feedback F33563944 · 18 August 2026 “A regulation that makes trade within the EU harder than trade with a country outside it is a reversal of the principle the single market was built on.
Small company, Estonia Feedback F33563597 · 17 August 2026 “…olemme tänään 17.8.2026 poistaneet Oy Juho Jussilan verkkokaupan asiakasmaista kaikki EU:n jäsenmaat omaa maatamme lukuun ottamatta…
Family firm since 1923, Finland — every EU country but Finland removed from the shop Feedback F33563698 · 17 August 2026 “…le commerce intra-européen devient tout simplement économiquement impossible pour une micro-entreprise comme la mienne…
Artisan, France Feedback F33563132 · 16 August 2026 “Die Kosten für Bevollmächtigte und Compliance-Agenturen sind höher als der erzielbare Gewinn.
Watches & jewellery, Austria Feedback F33557606 · 14 August 2026 “Obwohl ich im Jahr nur Kleinstmengen (weniger als 20 bis 30 Schallplatten und CDs) in einzelne Mitgliedstaaten (wie die Niederlande oder Frankreich) versende, werde ich rechtlich wie ein Großkonzern behandelt.
Independent music label, Germany Feedback F33559820 · 15 August 2026 “I am unable to afford the fees I would need to pay to be able to sell to each individual EU country, while large scale companies will be able to do this with no issue.
Art business, UK Feedback F33563930 · 18 August 2026 “It should never be easier for an EU resident to sell outside the EU than within it, and yet this policy has created these situations by treating each member state individually, eroding the benefits of the single market.
Sole trader, UK Feedback F33563929 · 18 August 2026 “…most small business will stop exporting to Europe, therefore much less packaging will enter. Well done the EU. Kills business to kill waste.
Two-person exporter, UK Feedback F33559822 · 15 August 2026 “No small business can afford the ridiculous suggestion of having a representative in every EU State.
Craft business, Ireland Feedback F33563079 · 16 August 2026 “Leider wurde uns nun mehrfach mitgeteilt, dass ein Versand aus dem europäischen Ausland nach Österreich nicht mehr möglich ist, da die vielfache Registrierung unverhältnismäßig Aufwand und Kosten verursacht.
A buyer, Austria Feedback F33563771 · 17 August 2026 “It is clear that the European Union offices were unable to develop a unified structure similar to the VAT One Stop Shop for the PPWR regulation.
Micro business, Germany Feedback F33563102 · 16 August 2026 “Von unserem Betrieb leben 6 Personen deren Zukunft mit der PPWR nunmehr unsicher ist.
Antiques dealer since the 1960s, Germany Feedback F33563945 · 18 August 2026Verbatim excerpts from the Commission's public feedback register for the initiative on sustainability criteria for plastic recycling technologies, where they were published under each submitter's own name. Read the full submissions there — including the ones that disagree with these.
The Kontor
One desk for every country.
Each desk is kept by a member who actually ships there and re-checks it every quarter. All twenty-seven are up. Every one is a draft with no keeper yet — so if you ship to a country and know its register, you can improve that desk faster than we can.
Twenty-seven desks. Pick a country on the map, or scroll the rail.
Before you join
Three things to be straight about.
Plenty of people will sell you something that sounds like this. Here's exactly what we do and don't take on.
We're not your authorised representative.
We don't hold your liability. We negotiate the terms — the contract is still yours to sign.
Registration works differently in every country.
Art. 44(3) lets each member state decide whether registration may be handled for you under a written mandate, normally by the authorised representative we help you appoint. Some took that option; Germany didn't, so there it's a personal duty you have to complete yourself, and anyone offering to do it in your name is selling you something that isn't compliant. It's a per-country answer by design, and knowing which is which is a large part of what we're for.
We don't give legal advice.
Everything we publish is shared experience with a date on it. For an answer you can rely on, talk to a lawyer.
Straight answers
The four questions we get asked most.
How exactly are you going to help me?
Three concrete things, and nothing else.
We tell you what each country actually asks for. There's a desk for all twenty-seven — what the register is called, who runs it, what it costs, and whether you can be registered under a mandate or have to do it yourself. Dated, re-checked, and free to read whether you join or not.
We negotiate as a block. Representative and scheme fees are quoted at retail to a one-person shop and at a discount to anyone with volume. A few hundred small sellers arriving together is a different conversation from you emailing alone. Where a country allows it, the representative we appoint can handle your registration too.
We collect the evidence nobody has. Real quotes from members,
aggregated so no shop is identifiable, to produce a median cost per €1,000 of
revenue. Art. 46(5) obliges the schemes themselves not to place a
disproportionate burden on small producers — that number is how you hold them
to it. That's what the Observatory is for.
Are you going to act as an AR for me?
No — and be wary of anyone who answers this too quickly.
We are not your authorised representative and we don't hold your liability.
Art. 45 requires an AR in each member state where you aren't
established, and that contract stays yours to sign. What we do is negotiate the
terms and the price, then introduce you. You sign directly with the provider.
Registration is a separate question from representation, and the answer changes
by country. Art. 44(3) lets each member state decide whether
registration may be handled for you under a written mandate, normally by that
same representative. Several took the option.
Germany didn't — there it's a personal
duty you complete yourself, and anyone offering to register in your name is
selling you something that isn't compliant. Knowing which country is which is a
large part of what we're for.
Is this going to cost me money?
Joining costs nothing. The founding list is free, there's no obligation, and the country desks stay free and open whether or not you join. If a paid membership ever comes — once there's a negotiation service worth paying for — the founding list hears it first, and nobody is moved onto it automatically.
What costs money is the compliance itself — registration fees, scheme fees, and a representative in each country where you aren't established. You owe those with or without us; they are the reason the fortnight after 12 August went the way it did. Getting that bill down by negotiating it collectively, instead of you paying the single-shop rate, is the entire point of the association.
We won't quote you a saving we haven't got in writing. When there's a pooled rate, you'll see the real number next to the retail one and decide for yourself.
Will I be able to keep selling into the EU?
Honestly: we can make it affordable and navigable. We can't make it permitted — only your own compliance does that, and no membership substitutes for it.
For most small sellers the blocker was never willingness. It was that a fixed per-country cost made shipping a handful of parcels uneconomic, and that the paperwork came in twenty-seven different shapes. Both of those are fixable, and with a pooled rate and a desk telling you exactly what your countries require, a lot of routes that closed in August open again.
Not all of them, and we won't pretend otherwise. For very low volume into one expensive country the honest answer may still be that it isn't worth it — and the desk will tell you that rather than sell you a registration you'll never earn back. Where a country has an easement for the smallest producers, it's on that country's desk. What we can promise is that you'll know where you stand, country by country, without paying the single-shop rate to find out.
Join us
Add your name to the founding members.
Tell us where you're based and what you ship. That's enough for us to work out which rules actually apply to you — and to count you when we go and negotiate.