Does the PPWR also apply to a sole trader or small web shop?

Yes, the PPWR also applies to a sole trader or small online shop

Company size is not in itself a ground for exemption under the PPWR: a sole trader or small online shop is in principle subject to the regulation just as much as a large enterprise. There is a specific micro-exemption, but it is narrower than often thought. It applies only when the brand owner is a micro-enterprise — fewer than ten employees and a turnover or balance sheet total of at most €2 million — and the packaging supplier is established in the same Member State. In that case, the supplier is the manufacturer, not the online shop itself. If the supplier is in another country — for example, a Dutch online shop sourcing packaging material from Germany or Poland — the exemption falls away entirely and the online shop itself is the manufacturer, with the associated obligations.

Even those who do fall under the exemption do not escape all registration obligations: these vary by country and are separate from the question of who is the manufacturer. In the Netherlands, an online shop below 50,000 kg of packaging per year does not have to register with Verpact, although that threshold is expected to disappear once the PPWR producer register comes into operation, at the earliest in August 2027. Germany has no such threshold: whoever places even a single package on the German market must be registered in LUCID from that point on. A small online shop that stays below the threshold in the Netherlands but also ships to Germany is therefore immediately subject to registration there.

Substantiation: guidelines on the concept of manufacturer

The micro-exemption follows from the European Commission guidelines C/2026/3084 on the concept of manufacturer, which provide further detail on the definitions in Article 3 of Regulation (EU) 2025/40. These guidelines describe when the packaging supplier rather than the brand owner is considered the manufacturer, and expressly state the condition that the supplier and brand owner are established in the same Member State.