I realise that title sounds rather dramatic, but I can't help but worry about the future of my micro business right now. You may have noticed on my website that I have had to pause shipping to the EU following the introduction of EU packaging regulations (PPWR) yesterday. This is not a decision I've taken lightly, but I was left with no choice.
The intention of these regulations is to ensure that businesses selling things to consumers are responsible for any packaging waste created through the sale - and this is something for which I definitely applaud the EU. But the way these regulations are being implemented will have a catastrophic impact on micro-/small businesses that sell to the EU AND within the EU, as well as EU suppliers that UK businesses buy from. Although the UK is a 3rd country, these regulations also go against the principle of a single market through the enforcement of different national rules within the EU. It's utter madness!
In principle, the idea of manufacturers taking responsibility for their packaging makes sense through volume-based levies (and in some countries there are minimum thresholds for this which exempt smaller businesses), but it's the set up fees that fall disproportionately on micro/small businesses. There is a requirement to register in each EU country a business sells to, as well as a requirement to have an "authorised rep" (AR) to manage the process in each country with currently no exemptions for small businesses (note we already pay annually for an authorised rep or "Responsible Person" in order to comply with EU cosmetic regulation). Current EPR registration prices range from 350-1,100 Euros per country, per year, and then there are annual AR fees per country on top of this, so the costs will quickly build up for smaller businesses with low sales volumes, before even factoring in the levies for the amount of packaging used. What's most frustrating is that these set up costs are the SAME whether you're a micro business like me, or a large company like Amazon, Shein, L'Oreal. These fees are probably a rounding error for large multinationals, but for micro / small businesses, they will force them to close shop. Bigger, waste-producing companies will effectively be paying less than smaller ones - there is an inherent unfairness in this. Larger companies have entire compliance departments to deal with all of this. Micro businesses like mine are often "solopreneurs" managing everything themselves so this adds a huge administrative burden (on top of the existing compliance we follow).
I have tried to be mindful with my approach to packaging ever since I launched my brand. I got rid of outer cartons to minimise waste very early on, use reusable and recyclable paper and card filler material to send my parcels, my thank you card inserts are TINY - there's no other branded material in my parcels, but I'll need to account for every bit of paper, card and twine that I use to protect my products so they arrive safely in your hands. No product packaging is perfect as it all has an environmental footprint (and that impact will vary at different stages of the lifecycle), but aluminium and glass are at least recyclable and my bottles themselves aren't larger than they need to be for the capacity they hold (in contrast with those weighty jars and bottles you'll find in mainstream skincare that hold a lot less product for their size, but give the impression you're getting more product).
And in all of this, we lose sight of the simple fact that the best thing we can do for the environment is BUY LESS AND NOT PROMOTE OVERCONSUMPTION. Look at the industry, what kind of companies are promoting overconsumption and fast beauty? Large corporations with a "profit at all costs" model who are launching new products to the market at such a rapid, unsustainable pace. The very ones that will be largely untouched by these regulations (and the authorised reps who will be raking it in!). Incidentally, there's also a huge loophole for wholesale orders that are exempt from these regulations. So the likes of Coca Cola, or La Roche Posay, who typically sell wholesale into beauty retailers, will be exempt from these regulations. They're creating plenty of waste but not having to pay for it!
What I would like to see is an exemption of registration / AR fees for micro/small businesses based on a minimum turnover, as well as a centralised platform for managing packaging (in keeping with the idea of a single market). Packaging should be levied at the original point of sale i.e. the packaging I have sourced and paid for is likely to have had levies applied, so why charge these again? Levy charges should be fair and proportionate, and ideally, agreed at an EU-wide level.
The EU Commission has picked up on some (understandable) outrage on social media but their response doesn't help smaller businesses in the meantime (they have "suggested" to national authorities to avoid sanctioning non-compliant businesses, and give them a warning instead) - but why would I risk sending orders out, not knowing if they'd be blocked at the destination country and sent back, disappointing my customers and leaving me out of pocket? These are businesses that don't have the luxury of external funding. Businesses that exist often because their owners are unable to be employed by companies because of disabilities, childcare or other caring commitments. These aren't businesses looking for world domination, they're makers that create products they love (in small volumes) and are just trying to earn enough to survive. These regulations are set to destroy them whilst allowing larger companies to continue polluting the environment (just as long as they've paid to do so).
If you happen to see read this blog post before 10th September, you can provide your feedback / objections to the regulations on the EU consultation that's currently open until then here.
