on the morning of 12 august, the posts started stacking up: independent studios — ceramicists, furniture makers, lighting designers — announcing that they would pause shipping to other eu countries. not because demand had dried up, but because a regulation with an unglamorous name had begun to apply: the eu packaging and packaging waste regulation, ppwr, regulation (eu) 2025/40.
some of that worry is justified. some of it is not. the difference is worth understanding precisely, because it decides whether a studio needs to change anything at all.
two roles, constantly confused
the ppwr assigns duties to roles, not to industries — and the two central ones sound similar while meaning very different things.
the manufacturer is whoever produces packaging, or has it produced under their own name. the product rules — conformity assessment, technical documentation, design requirements — sit here. a studio that buys standard cartons and fills them is not a packaging manufacturer. if you have read that the ppwr "only concerns packaging producers", this is the half-truth behind it.
the producer, in the regulation's epr chapter, is whoever first places a packaged product on the market of a given member state — explicitly including distance sales. ship a chair from lisbon to a collector in vienna, and for that shipment's packaging you are the producer in austria. producers register in each destination country, report volumes, and pay fees that finance collection and recycling there. this is the role that catches small studios — and it is not new: germany's lucid register, for one, has required this since 2019.
what actually changed on 12 august
the genuinely new piece is article 45. since 12 august, a producer selling into a member state where it is not established must appoint an authorised representative for epr in that country. one per country. no single window. and — this is the part that stings — no exemption by company size: the regulation's relief for micro-enterprises concerns technical documentation, not epr.
before, direct registration was enough in several countries. now, a studio shipping to ten member states needs ten representatives, each with a mandate and an annual invoice. for a business selling a few pieces a year per country, the arithmetic collapses — which is why "we are pausing eu sales" is not hysteria. it is, for many, simply the honest sum.
two clarifications spare unnecessary worry. first: a studio selling only inside its own country saw almost nothing change this week — national epr obligations existed before and continue. second: the dates that dominate the headlines — harmonised labelling, format bans, recycled-content targets — arrive from 2028 and 2030, not now.
will it be softened?
on the whole, nothing supports planning on it: a spring petition by more than a hundred large companies did not move the application date, and the commission answered in june with a 58-page guidance document, not a delay. but one piece is genuinely in motion. a commission proposal — com(2025) 982 — would suspend the representative requirement for eu-established producers until 2035. it has not been adopted: the council broke off its negotiations in june, and the proposal now sits with the european parliament, with a committee vote expected in early october. until then, article 45 applies as written.
the practical reading: a studio deciding this week should decide on the law as it stands — and a studio signing representative contracts should keep them short.
the three honest options
a small studio that wants to keep selling across the eu has, as far as we can see, three routes.
carry it yourself. register in each destination country, appoint the representatives, report the volumes. workable for studios with real volume in a handful of markets; disproportionate below that.
shrink the map. sell domestically and to non-eu markets, pause the rest. defensible — and quietly expensive, because eu collectors are where much of collectible design's demand lives.
let a seller of record carry it. when a gallery or platform sells on consignment and acts as seller of record, it — not the studio — is the producer in the destination country: its registrations, its representatives, its fees, once per country for all of its designers. that arithmetic works at gallery scale precisely because it fails at studio scale. (disclosure: spazio works this way for its consignments; several platforms have chosen instead to discontinue compliance support, which is the same decision seen from the other side.)
none of these routes is morally superior. they are different answers to the same invoice — and knowing which role the regulation actually assigns you is the difference between a considered answer and a paused shop.
this article explains the mechanics as we understand them and is not legal advice. primary sources: regulation (eu) 2025/40; the commission's guidance document of 5 june 2026; com(2025) 982 and its parliamentary file; the decision trees of national registers such as germany's zsvr.