Did the EU just kill the hobbyist aftermarket with PPWR?

Hi all,

I don’t intend to get into a political rant here, but there’s a very good chance that the EU killed the pan-european market for hobbyists - and to be honest, any start-up company that produces some type of goods that has to be packaged - with the introduction of the new Packaging and Packaging Waste Regulation (PPWR).

Without getting into the minutiae of the regulation, the main issue is that it puts an undue burden on companies who want to sell their products to customers in other countries within the EU.

All companies will have to register - or pay a consultant to register for them - with the environmental protection agency in each country they want to sell to and they have to report how much and of what kind of packing material they ship to each country.

As an example, if I was the manufacturer of a simple model kit that uses the same style of packaging used by Tamiya for their model kit, I would have to report:

  • The origin and type of plastic used for the bags the sprues are packaged in (this includes letters of conformity from the manufacturer of the bags)
  • The origin and type of cardboard used for the box the kit is packaged in if it has my logo on it (this too includes letters of conformity from the manufacturer of the boxes)
  • The origin and type of packing material I use to protect the kit when I ship it to a customer in another EU-country

If I ship direct to consumers, I also need to include the information above with each shipment, so the customer knows how to recycle all the packaging.

If I dare importing product to sell together with my own, I need to report the information above for those products as well.

The cost for all this? The company I work for - which has fewer than 25 employees - will have to spend an approximate €9,000 per year for all the fees and administrative work.

Oh, and I haven’t even mentioned that you will have to pay a fee to each country for them to handle the recycling of the packaging you shipped.

Now, imagine you’re a one-man-shop armed with a 3D-printer and a burning passion for making aftermarket parts. Prior to August 12, you could build your business on having customers throughout the EU and the rest of the world. Today, unless you have some mighty big coffers to spend from, you will have to build your business on the domestic market until you have reached a large enough turnover that you can afford to branch out of your domestic market.

Also, PPWR affects actors outside the EU who want to sell their products within the union. I have already seen a number of manufacturers - inside and outside the hobbyist world alike - stating that it is no longer worth if for them to ship to customers within the EU because of the administrative burden it poses.

Yeah, I’m a little pi$$ed at the short-sighted politicians who thought this was a good idea.

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My bet is that affected 3D modelers will end up emailing the files to home 3D printers overseas or 3D printing shops who will produce the actual parts. Shipping costs zero and no need to package a darned thing. Won’t happen immediately but someday.

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Some manufacturers will need to reduce the empty space inside the boxes (Dragon, I’m talking about You).
This could be a benefit for some modelers with way too many unnecessarily large boxes.

The packaging manufacturers will have to handle most of this.
When model maker X buys packaging material from Huge Cardboard Box conglomerate
the paper mills have already done all the certifications.
Packaging used for other types of consumer products already have recycling markings/instructions.

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This is definitely a very likely route for our hobby.

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The packaging manufacturer will only have to handle the reporting on what they themselves export, not what their customers export. Yes, European packaging manufacturer usually already have the DoC for their products available (due to other environmental legislation already on the books).

I actually think there will be move to limit the quantities of smaller box sizes and boxes with box art in favor of plain boxes that can be used for multiple types of products for the sake of making reporting easier limit the “producer responsibilities”.

Yeah, I’m pessimistic.

Many after market producers already use plain boxes with a
simple printed paper glued to the lid.
Those boxes are standard boxes bought from wholesale
box suppliers.
Some of my purchases from Ukraine have come in a larger
shipping box with all the sprues in separate plastic bags and the
actual printed cartons as flat, pre-cut, sheets that I folded
and stapled the corners to make boxes and lids.
When I bought a largish amount of replacement tires for Centurion
roadwheels from Australia I told the vendor that I didn’t need the
boxes since the tires would get stored in the Centurion kit boxes.

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Ah yes, indeed.
The packaging manufacturers customers will ask for the information and a packaging manufacturer that does not want to restrict the available market will need to provide it.
“Buy top quality cardboard boxes from us but you may only use them for domestic sales”
doesn’t sound like a winning marketing slogan in my ears …
Those standard boxes will have the EU certification numbers printed on them or they will soon be gone from the market.

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I do not understand this law. If the government wants to reduce waste that cannot be recycled, which is a laudable goal, why not require shipping boxes, shipping tape, and shipping inserts to meet a standard and then only allow the sale of packing material meeting the standard, causing all the bad packaging to cease to exist going forward? Am I missing something?

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You’re missing the fact that politicians are greedy and stupid.

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We are a 1-person company with a set of 3D-printers and my kids do the packing.

When we fill a customer’s order, the aftermarket model parts we produce are individually placed in protective bubble pouches obtained via Amazon from a manufacturer in China and come to us with no environmental labeling whatsoever. Those model part-filled pouches are then placed in a cardboard box we buy via Amazon, also produced in China, for shipping to the customer. The carboard boxes come to us with no environmental labeling whatsoever.

This is is the packaging that we can afford to buy.

We certainly can’t afford to hire an EU-based consultant to register for us with individual EU countries.

Unfortunately, we already lost most of our valued European and Canadian customers due to political rhetoric. This just puts the last nail in the coffin. It seems several governments, including our own, are determined to put us out of business.

Looks like we’re f_cked and so are our valued EU customers.

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I think the Chinese producers will adjust to the new rules,
not for your sake and definitely not for mine but they will
look after their own best interests.
If their packaging customers in China want to ship boxes
to EU then they will ask their box-makers to provide the
required papers. The cost for doing all the certifications
are HUGE for you but the box-factory in China where
they make millions of these boxes each year will barely
notice the cost.

How many of those bubble pouches and boxes do you
think Amazon ship to the EU and ship from Amazon
facilities within EU?

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The village well is polluted. The village council orders that every household in the village must pay for an inspector to certify that residents of the house are not using polluted water from the well and only purchasing approved clean water.

Why not clean up the well and take care of the problem at the source?

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Why fix something and be done with it when instead you can turn it into an income stream for the unforeseeable future?

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This resembles the scaremongering of a certain so called journalist who went on to an unsuccessful political career who made his name making up scare stories about the EU.

The reality on the ground is that this is aimed at the big companies the Amazons, Temu and the rest. Who have huge volumes.

This will hardly effect the smaller mom and pop businesses. Remember it’s not just models. There’s art, clothes, craft and food businesses and the rest. They’re not the target.

Also by the way the EU is not one big monoglot. Every country has it’s own version of the rules and ignores any that don’t suit them.

There are a lot of rules that are simply ignored in the EU.

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As a German that now lives in the US I do follow and understand the topic to a certain degree.

It’s one of these laws that has been created by companies with big pockets. They lobbied politicians to create a law like this to get rid of all the small companies that interfere with their business. Big companies have no problems of following the law, they already have their own packaging and their own people in every country anyways.
It’s a law purely against small businesses. It’s just made to push small businesses into the hands of the big players so they HAVE to offer their services and goods through their fulfillment and pay high fees to do so.

This law should have never been released like that. The most laughable part is that they made that law “officially” to reduce waste. But how is it reducing waste if you CAN’T REUSE a box from a previous shipment because you have not bought and licensed the box yourself…

Absolute insanity.

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Before we all shout “the sky is falling!” does anyone have evidence of this new-ish regulation being enforced in a way that burdens small-scale sellers? I can see it hitting packaging manufacturers, forcing them to make their products conform and maybe include suitable markings, but that will probably have little impact on those who buy the stuff to pack their AM goodies. We already see such markings on pretty much everything, from cereal boxes to plastic drinks bottles. I’ll wait to see if this has any noticeable impact.

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Yes, I have an evidence of a small Hungarian model base company which doesn’t want to send me the base I ordered from them and paid even before PPWR came into effect.

Mario

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I would say, you lost european customers, because of the massive increase in US postal fees…

Thats my reason why I am not buying from US any more, long before your 47er problems

Rabbits

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Why can’t the companies create a list of the requires labels online and just print a code on the box that allows you to view the specific certifications online instead of printing in every container shipped. That would drop their cost.

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Having spent a couple hours reading about these new regulations I now understand the concerns. They affect businesses operating in, or shipping to, all 27 members of the European Union in a unified framework. The law is very complex with many provisions that phase in over time.

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