7,133public responses (7,667 submitted)
69countries
53.9%of respondents were private individuals
38.5%asked for a threshold or exemption for small senders
21.2%asked for one EU register or a single entry point
95.0%of responses were individually worded, not templates
Source: European Commission, "Have Your Say", initiative 15352, "Packaging and packaging waste – rules on national registers of producers". Analysis: Regtrue.
What the consultation was about
Under the Packaging Regulation, a producer must register in each Member State where it makes packaging available for the first time (Art. 44(2)). The Commission sets the format of register entries and reporting in an implementing act (Art. 44(14)). The draft of that implementing act was open for feedback on the Commission's "Have Your Say" portal. The Commission's counter shows 7,667 submissions, of which 7,133 are public; the remaining 534 are not published and we cannot see them.
Who responded
Responses by country (self-declared)
Germany2,457 · 34.4%
France410 · 5.7%
Netherlands398 · 5.6%
Spain346 · 4.9%
Italy343 · 4.8%
Austria340 · 4.8%
Poland277 · 3.9%
United Kingdom248 · 3.5%
Belgium232 · 3.3%
Portugal222 · 3.1%
Sweden196 · 2.7%
Lithuania191 · 2.7%
Finland (#13)189 · 2.6%
Latvia (#18)86 · 1.2%
Estonia (#22)64 · 0.9%
Type of respondent
EU citizen3,596 · 50.4%
Company2,972 · 41.7%
Non-EU citizen252 · 3.5%
Business association182 · 2.6%
Other92 · 1.3%
Public authority13 · 0.2%
NGO12 · 0.2%
90.1% of responding companies described themselves as micro-enterprises.
When people responded
More than half of the responses (53.7%) arrived within seven days of the consultation opening. The peak was 10 August, with 1,225 responses in one day. The final week brought 10.4%.
What respondents asked for
A response counts towards an ask when it matches one of the stated keyword rules. To check precision we read 10 random responses per ask.
Threshold or exemption for small senders2,749 · 38.5% · precision 9/10
Authorised representative requirement is a cost or burden1,605 · 22.5% · precision 10/10
One EU register or single entry point1,512 · 21.2% · precision 10/10
Harmonised data fields and formats326 · 4.6% · precision 9/10
Machine-readable formats and APIs145 · 2.0% · precision 10/10
In addition, 37.1% of responses mentioned fees or other costs, and 32.1% mentioned harm to the single market or trade barriers.
Who asks for what
Micro and small companies most often mention a threshold for small senders, the cost of an authorised representative and one EU register. Business associations and medium and large companies are far more likely to mention harmonised data fields and machine-readable formats.
| Private individuals | Micro and small companies | Medium and large companies | Business associations |
|---|
| Threshold or exemption for small senders | 31.6% | 49.4% | 21.9% (25/114) | 27.5% (50/182) |
|---|
| Authorised representative requirement is a cost or burden | 13.0% | 35.4% | 25.4% (29/114) | 19.8% (36/182) |
|---|
| One EU register or single entry point | 14.0% | 30.9% | 20.2% (23/114) | 20.9% (38/182) |
|---|
| Harmonised data fields and formats | 2.3% | 5.2% | 21.1% (24/114) | 28.6% (52/182) |
|---|
| Machine-readable formats and APIs | 0.8% | 1.7% | 13.2% (15/114) | 22.5% (41/182) |
|---|
| n = 3,848 | n = 2,858 | n = 114 | n = 182 |
The business association count is an upper bound: some respondents ticked "association" although they are ordinary companies. Many self-declared private individuals write as sole traders.
Respondents from Estonia
64 responses came from Estonia (0.9%, joint rank 22). Of these, 40 came from EU citizens, 3 from non-EU citizens, 17 from companies, 2 from business associations and 2 from NGOs. None of the Estonian responses was a template.
The most frequent asks in Estonian responses were:
- Threshold or exemption for small senders: 14
- One EU register or single entry point: 10
- Authorised representative requirement is a cost or burden: 7
- Harmonised data fields and formats: 4
- Machine-readable formats and APIs: 2
Because the sample is small, we give counts only for Estonia, not percentages.
What this means for businesses
The implementing act has not been adopted, and the consultation does not tell us what the final text will say. Once it enters into force, each Member State has 18 months to set up its register (Art. 44(1)). From then on, a producer must be registered in each Member State where it first makes packaging available or unpacks packaged products, before doing so (Art. 44(2) and (4)). Until then, national EPR registration rules continue to apply. If you sell into other EU countries, it pays to know now in which countries you are a producer.
Method and limitations
- Corpus: all 7,133 public responses as of 11 September 2026 (the consultation closed on 10 September 2026). We analysed the Commission's English translation where available, otherwise the original.
- Respondents chose to respond, so the results do not represent all EU businesses.
- Country, respondent type and size are self-declared.
- Respondents' statements (for example "I stopped selling abroad") are claims, not verified facts.
- Keyword rules show mentions, not stance or importance. Precision was checked with 10 responses per ask; recall was not measured.
- Templates: 357 responses (5.0%) repeat essentially the same text; they are included in the figures. This is a lower bound on coordination: many more responses use the same arguments in their own words.
- Of the 1,605 responses mentioning the authorised-representative cost, 206 come from one German-language template.
- Organisations' longer positions are under-represented: the 265 attachments were not read and 534 submitted responses are not public.
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