Micro-exemption PPWR: does your supplier's country of establishment also matter?
Yes, it can. The micro-exemption in the European packaging regulation is not only linked to the size of your own business — think of the number of employees and annual turnover — but the regulation also looks in certain situations at where the person who supplies you with packaging material or packaged products is established. If that supplier is in the same Member State as you, then the exemption may work out differently than when the supply comes from another EU country.
This is precisely the detail that entrepreneurs often miss. They read that a micro-exemption exists, count their employees and their turnover, conclude that they fall within it, and assume that the matter is then settled. But the place of establishment of your supplier is a second layer that must be assessed separately, and that layer differs per situation — which is precisely why there is no ready-made answer for everyone here.
What the micro-exemption precisely entails
The regulation distinguishes between businesses by size: micro-enterprises receive a lighter regime in some respects than larger businesses. This is intended to keep the administrative burden manageable for the smallest players. But an exemption that is linked to business size is not automatically a free pass for everything related to packaging. The exemption applies to specific obligations, not to packaging regulation as a whole.
Where things often go wrong is that entrepreneurs treat the exemption as a simple yes-or-no question about their own business. In practice, a second question comes into play: from whom do you obtain the packaging, and where is that party established? That question partly determines whether the exemption applies to your situation, and that makes the subject less clear-cut than it appears at first glance.
Why your supplier's Member State matters
The underlying idea is that the regulation aims to prevent packaging obligations from disappearing between two Member States. If a small enterprise is exempt and the supplier is located in a different country than where the obligation would normally apply, a gap can emerge where no one is responsible for registering that packaging. To prevent this, the assessment of the micro-exemption factors in whether the supplier and buyer are in the same Member State.
In practice, this means that two companies with exactly the same size and the same packaging can reach a different outcome once one of them sources its packaging material from abroad instead of domestically. That feels unfair, but it is an intentional choice in the regulation's system to keep responsibility clearly defined across borders.
What this means in practice
For you as an entrepreneur, this means above all that you cannot answer the question without looking at your supply chain. It is not enough to know how many employees you have and what your turnover is; you must also know where your packaging material supplier is established, and sometimes even where the product filling takes place. For companies sourcing material from multiple countries, the outcome can differ per packaging type.
This is also why a generic checklist falls short on this point. The outcome depends on the combination of your own size, the country in which you are established, and the country of your supplier — three variables that together determine whether the exemption applies to a specific packaging stream. the role finder answers this combination in a few questions, per packaging type and per country, and immediately indicates when the micro-exemption does and when it does not apply to your situation.
When you can have this looked into better
If your company only sources and sells domestically, the likelihood that this detail becomes relevant to you is small. Once a border comes into play — a supplier in Germany, Belgium or further afield — it is advisable to examine this point explicitly rather than assuming that the exemption automatically grows along with your own company size. The official text and the guidelines are decisive here, and if in doubt about the precise interpretation of your situation, it makes sense to consult a legal professional or the competent supervisory authority.
For more information about how the micro-exemption relates to other parts of the regulation, the background can be found in the knowledge base with explanation per subject. Common cases of doubt, including cross-border sourcing, are clearly listed in the frequently asked questions, and for anyone who wants to know where the information on this site comes from, you can read that via the explanation of our working method.
If you are uncertain whether the micro-exemption applies in your case, you do not need to make assumptions about it. Take the free quick scan or work through the role finder: in a few questions you will see where you stand for your packaging and your country, including the reason why.