Simply not true. The helpful diagram you refer to does not consider the case where company A manufactures the packaging, company B buys the packaging, and then does a B2C delivery to another member state. In that case company B is the producer, even if B is a "micro-enterprise".

> the discussion here seems to have a lot of people who are in a big rush to demonize their perceived political opponents on ideological grounds.

No, it is the opposite. There are a whole lot of people trying to rationalize something crazy. Nevertheless, countless online shops in the EU run by small business have already closed thanks to these regulations. Even if your assertion that this is a giant misunderstanding were true, the damage is already done.

I don't see a diagram on page 13, but I read a few pages around there. I don't see anything about it not applying to micro-enterprises. I see one diagram (PDF page 14/page num 11) that says a farmer selling "under own name or trademark to end user in another Member State" (without saying there's an exception for a micro-enterprise) means that the "Farmer is producer," which sounds like the opposite of what you said.

There are a dozen small business owners in this thread alone, giving specific details of how this legislation is irrationally hurting their business and the economy.

Even if true, I wonder if it really helps if I basically need to hire a lawyer ($$$) to find out which regulations may or may not apply, and if I'll get myself into trouble.

It is not a coincidence that here in Germany there are whole law firms specialized in suing small business owners (Abmahnkanzleien.)

I think for a lot of people the tradeoff might not be worth it.

The exact scenario from TFA is listed just before the diagram you're referencing :

"If a farmer packs a few apples in a container (sales packaging) and sells it under its own name or trademark to a retailer or consumer in the same Member State, the farmer is a producer [for the purpose of EPR obligations]"

And :

"If the farmer sells the packed apples under its own name or trademark in another Member State, the farmer is only the producer if the recipient is the end user of the apples."

And :

"If the farmer is a micro-enterprise, which is often the case, and the supplier of the apple container is established in the same Member State, such supplier becomes the producer"

That last exemption is quite restrictive, it can be a problem. I can attest that a French manufacturer of antistatic packaging refused to sell to me as a micro enterprise when I was selling electronics kits a long time ago and I had to buy them from China. Some states might not even have packaging manufacturers. So the concerns from the article are founded.

EU web sites are such an epitome for the EU as a whole: Inscrutably bureaucratic.

Instead of a FAQ page that starts with, you know, the FAQ, the actual information is hidden in a PDF download. Once you click it, there is another popup to confirm. That then leads to a PDF with 9 pages of misc front matter before you can see the first question. And the answers themselves are completely unreadable.

Take for example "3) Are envelopes containing letters, invoices, statements and other correspondence which serve a communication function considered to be packaging under the PPWR? NEW!": Three paragraphs of legalese just to say "no" in the most complicated and hard to understand way.

The whole document is 27847 words. If we ignore the complexity and assume the reading-speed number of 238 wpm that I often see cited, that's two hours of extra compliance overhead just to read the FAQ.

And for extra hilarity, the page is also covered in so many popups and warts that fight each other that on mobile you have to accept all cookies because the decline button is covered.

Edit: Also, I've been unable to find any diagram on either the page numbered 13 on the bottom of it or the page numbered 13 by the PDF reader (not the same thing, in 2026...). There are two diagrams nearby but none of them seem helpful. If you mean the one in "9) Who is the ‘producer’ of transport packaging?", it only covers a subset of cases (company A sells the packaging in the same member state). The text states "If company A sells the cardboard boxes to Company C in another Member State, and Company C fills the boxes to transport packaged products, then Company C would typically be the producer in that Member State." so we're back to square one.