Stop the EU madness, Mr Merz!

Paderborn, 15 October 2026

Dear Federal Chancellor,

You promised citizens and businesses less bureaucracy. Since 12 August 2026 bakers, butchers, publicans, traders and medium-sized companies have been experiencing the opposite: with the EU packaging regulation every piece of packaging – right down to the bread roll bag – has become a regulated product with market access requirements of its own.^[1][2] The German accompanying act, the packaging law implementation act, was introduced by your federal government, the Bundestag passed it on 11 June 2026, and it has been in force since 12 August 2026.^[3][4] Small traders have already suspended deliveries to other EU countries, because the costs and effort are out of all proportion.^[5] Even the chamber of commerce for the Middle Lower Rhine sees open questions on practicability, costs, bureaucratic effort and legal certainty.^[6]

In what follows I show you, with 20 examples from everyday life, what the new packaging rules mean in practice for every business and every citizen. Every example is documented with a source – from the text of the regulation through chambers and authorities to the EU Commission itself.

Chronology: from Brussels to the bread roll bag

20 examples anyone can understand

What the new packaging rules mean in everyday life – from the baker to the supermarket.

Bakery and butcher

1. The bread roll bag with a logo. If the bakery’s name is on the bag, the bakery is the “producer” and “manufacturer” of that packaging – with all the obligations that entails.^[12] That means: conformity assessment, technical documentation, an EU declaration of conformity under Annex VIII and producer identification.^[2][6]

2. The same bag without a logo. With plain bags from within Germany the bakery is only a “distributor” – but it has to satisfy itself that the manufacturer is registered and that the bag carries the prescribed information.^[2][12] Its own name on the bag decides a whole catalogue of obligations.

3. The old stock of bags in the storeroom. There is no period for using up stock. Plain bags that the supplier placed on the market before 12 August may continue to be used. With bags carrying its own logo the bakery is itself the producer; on the EU Commission’s guidance there is much to suggest that the new PFAS limits apply to them, even if they were bought before the cut-off date.^[14][16][17]

4. Limits in ppb – the test method open. Permitted are 25 ppb per individual PFAS substance.^[2] There is as yet no uniform EU test method; work on a common test protocol is only beginning.^[16][18]

5. The printing ink of the logo. The requirements apply to the packaging as a whole – including labels, printing inks, varnishes, coatings, glues and adhesives.^[16][18]

6. The coffee-to-go cup. If the bakery buys cups with its logo, it is the producer and manufacturer – regardless of whether the supplier is in Germany or abroad.^[14][19]

7. The wrapping paper at the butcher’s. If the butcher cuts the paper from the roll himself, he is, in the view of the chamber of commerce and the central packaging register, manufacturer and producer. If he buys it ready-cut, the usual rules apply as with the bag.^[20][21]

8. A filing cabinet for a bag. Documentation and the declaration of conformity have to be kept for 5 years (single-use) or 10 years (reusable) and presented to the authority within 10 days on a reasoned request.^[2]

9. A batch number for the packaging. The packaging must be identifiable by a type, batch or serial number or another marking.^[2] That the bread roll itself is traceable is not necessarily enough, in the view of the Austrian chamber of commerce.^[18]

10. The simple route disappears. Until now one could buy service packaging for which the obligations had already been discharged (“pre-registered”). This route now falls away in most cases.^[6][11][19]

Crafts, retail and mail order

11. The film over the ironed shirt. Dry cleaners can be affected too: if the film carries their logo or they source the film from abroad, they have to register in the LUCID packaging register and report packaging volumes.^[11][19]

12. The advertising letter in an envelope. Anyone sending advertising post in envelopes may be a manufacturer within the meaning of packaging law.^[6] Whether an envelope containing mere advertising is packaging at all is, however, disputed before the courts.^[22]

13. The pallet and the stretch film. For transport packaging there is in principle no exemption. If the pallet carries the customer’s name, the customer becomes the producer.^[2][18]

14. The small online shop. Traders report that in every EU country into which they deliver directly to end customers they need an authorised representative – around 300 euros per country per year. The first businesses have suspended EU deliveries.^[2][5]

15. The shipping box. From 2030 at the earliest the empty space in transport and shipping packaging may be at most 50 per cent.^[2]

Hospitality, hotels and supermarkets

16. The customer’s own container. From 12 February 2027 to-go providers in hospitality have to fill containers that customers bring – at no higher price than in single-use packaging and with a clearly visible notice.^[2]

17. The statutory duty to “endeavour”. From 12 February 2028 to-go providers in hospitality have to make a reusable offer; micro-businesses are exempt. From 2030 they have to “endeavour” to offer 10 per cent of their products in reusable form.^[2]

18. Ketchup sachets and hotel shampoo. From 2030 single-use individual portions of plastic for sauces, sugar or coffee cream are banned in hospitality, except for food to take away. In hotels single-use miniatures for toiletries disappear, whatever the material.^[2]

19. 1.4 kg of tomatoes against 1.6 kg of tomatoes. From 2030 single-use plastic is banned for fresh fruit and vegetables under 1.5 kg. The threshold is sharp – above it the ban does not apply. Only the member states can lay down exemptions.^[2]

20. The sticker on the apple. From 12 February 2028 certain packaging has to be compostable – for instance stickers on fruit and vegetables.^[2][6]

So that nobody can talk their way out of it

Yes, there is an exemption for micro-businesses. For businesses with fewer than 10 employees and at most 2 million euros of turnover the supplier counts as the producer – but only if it is in the same EU country.^[2][18] There is no general exemption from producer responsibility.^[16] The bakery with 15 staff and its own logo bags carries the full obligations.

Yes, much of it is still to come. What applies today is above all the substance requirements such as PFAS. Labelling and recyclability depend on EU legal acts that are still missing.^[23] That is precisely the problem: businesses are supposed to meet obligations today whose details will only be laid down tomorrow.

Yes, the aim is right. The EU Commission expressly names baking paper and pizza boxes as examples of PFAS in food packaging.^[24] Nobody wants forever chemicals in their food. But that is solved at the paper manufacturer – not with forms in every single business.

Our demands on you, Chancellor

1. Pull the emergency brake in Brussels. In the environment omnibus, push through a suspension of the producer and documentation obligations for service packaging and for medium-sized business. Your proposal of 7 September – no authorised representatives below 10 tonnes of packaging, registration suspended until mid-2028 – is right, but far too small.^[15][25]

2. No fines while the rules are unclear. The penalty provisions for the directly applicable obligations of the regulation take effect from 12 February 2027.^[11] Suspend enforcement until uniform test methods and all the EU legal acts are available.^[16]

3. A logo must not be a bureaucratic trap. Anyone printing their name on a bag must not thereby become a “producer” with a declaration of conformity. The responsibility belongs with whoever makes the material.

4. Widen the small business exemption. From under 10 to under 50 employees – and regardless of whether the supplier is in Germany or elsewhere in the EU.

5. Solve PFAS at the paper manufacturer. Confirmation from the supplier has to be enough, with legal certainty, for bakers, butchers and publicans – without technical documentation of their own.

6. Keep to your own rule. The coalition agreement wants to bring the effort arising from EU requirements into the “one in, one out” rule and develop it into “one in, two out”.^[7] For every new packaging obligation, two old ones must go.

Chancellor, the EU packaging regulation was adopted in Brussels before your government took office. But the German implementing act was introduced by your government – and it is your government that has to push the correction through in Brussels. In February 2026 the record of your bureaucracy promises was: “promised, barely delivered”.^[26] Change that. Start with the bread roll bag.

Keep your word.

Andreas W. HerbFounder and CEO, MBG Group, Paderborn

The editorial team’s assessment

The packaging regulation was adopted by the European Parliament and the Council in 2024; it applies directly as EU law.^[2] The Merz government is responsible for the German accompanying act. According to its explanatory memorandum, business incurs from it an additional burden of around 2.5 million euros a year and around 4.5 million euros one-off, arising, according to the federal government, entirely from the implementation of EU law. A substantially less bureaucratic design would be possible only through simplification at EU level.^[3]

Something is moving in Brussels: on 5 October 2026 the European Parliament’s environment committee voted, with none against, for a temporary suspension of the authorised representative obligation for micro and small enterprises established in the EU. The plenary and the Council still have to agree.^[27] The federal government now includes the effort arising from the 1:1 implementation of EU law in the “one in, one out” rule; the decision on “one in, two out” is, according to the federal government, still outstanding.^[28]