Business owner forced to stop selling instruments to Europe because of new EU packaging rules

Mauri Meronen, 41, a solo entrepreneur from Tampere who has been self-employed for around two years, has been forced to at least temporarily halt shipments of his product to the EU because of the new packaging rules.

Meronen’s company Tele Tunes manufactures 3D-printed flutes and has sold them to several European countries as well as to the United States, South Korea, and Japan, among others. EU sales over the past 12 months have totalled around €20,000.

For distance sales within the EU the EU Packaging and Packaging Waste Regulation (PPWR) requires producers to appoint an authorized representative in every member state where they sell packaged products directly to end users.

That requirement is toxic for Meronen’s business.

“Even if I sell a single flute to Spain, I still need a named representative there for just one parcel.”

Meronen found out about PPWR by chance, after seeing another entrepreneur’s similar experiences on social media. His calculations showed that continuing EU sales is not currently worthwhile.

“If I had an authorized representative in every EU country I sell to, the cost would be somewhere between €7,000 and €17,000. I’ve seen estimates in the same range from other entrepreneurs.”

The representative fee is charged annually. Meronen is currently calculating whether it would be worth resuming EU sales to his best-performing markets, Germany and France, at the start of next year.

“If I concentrated all my annual sales there, it might make financial sense to keep going. I could earn back the representative costs. But if I continued selling to all countries, I’d spend around 90% of my operating profit on representative fees,” the Tampere-based entrepreneur says.

He says the practical implementation of the requirements of PPWR has been botched. Meronen is required to report the amount of packaging waste for each country he sells to through separate portals.

“I don’t understand why the EU hasn’t built a centralized system where I can log figures by country. As it stands, I have to use more than twenty portals to report how many centimetres of tape I’ve used for packaging sent to each country. This feels like a bungled rush job,” the entrepreneur says.

Despite the challenges posed by PPWR, Meronen still sees opportunities for flute sales in other markets such as the United States.

Opportunities in the US

Meronen’s interest in making instruments was sparked about ten years ago when a bamboo flute he had bought in Peru could not withstand the Finnish climate and broke. Initially he built flutes at home from electrical conduit pipe, and a little later began printing the more difficult parts on a library 3D printer. The business only really got going when new, better, and faster 3D printers came on the market. Meronen was able to use them to reliably print a complete wind instrument in a short time, with a small margin of error.

The one-man company makes instruments that, when collapsed, are no bigger than a thumb. When extended to full length, the flute is ready to play. Meronen sells his products through his own online shop and on Etsy, the marketplace for independent makers. He also sells digital print files, which customers can use to 3D-print a flute themselves.

Despite the challenges posed by PPWR, Meronen still sees opportunities for flute sales in other markets such as the United States. Previously, more than half of his sales came from across the Atlantic – until President Donald Trumplaunched a trade war and goods traffic was cut off. Meronen solved the problem by moving production to the United States. The manufacturer there now also handles shipping to customers.

In Europe, Meronen might be able to continue selling through wholesalers.

“In Germany it could work by having a wholesaler resell my products. The wholesaler would then be responsible for appointing a representative.”

“It feels absurd to stuff filler”

Last year, all of Meronen’s European parcels generated around four kilograms of cardboard waste. He sold 300 flutes in the EU.

“Recycling that amount of cardboard can’t cost more than a few dozen euros at most. That wouldn’t be a problem, but the representative fee is.”

One of the aims of the EU’s PPWR is to reduce the amount of packaging waste. Yet at the same time, producers like Meronen cannot pack their products in as small a package as they would like.

“My lightest flutes weigh 25 grams. Even so, they have to go in an oversized cardboard box, because that’s the only way to get tracked delivery through Posti. Posti’s rules don’t allow tracking for letter envelopes.”

Meronen has still sent some deliveries in envelopes. Products have gone missing in the post on several occasions.

“When that happens, I have to resend the product – but financially it still makes sense, because sending in an envelope costs €5, while a cardboard box costs €30. It feels absurd to stuff filler into a big box just to get tracking on the shipment.”

Read the PPWR guidance in the Yrittäjät Information Bank

“Unsustainable, especially for small businesses”

The EU Packaging and Packaging Waste Regulation (PPWR) began to apply on 12 August. At the same time, the previous Packaging and Packaging Waste Directive was repealed.

The regulation’s requirements put small business owners in a particularly difficult position. Even if a business owner sells modest volumes to several EU countries, they must investigate their obligations in each export country separately, join a producer responsibility organization in each destination country – where membership may be mandatory – to arrange waste management and recycling, and pay the required fees.

This multi-window system can be an insurmountable obstacle for small business owners, both in terms of time and cost. Tiina Toivonen, Legislative Affairs Manager at Suomen Yrittäjät, the Finnish SME association, describes the new obligations as “unsustainable, especially for smaller companies”.

“Many businesses now have to ask whether exporting or selling online within the EU still makes economic sense. The new regulation does nothing to promote the free movement of goods in the single market,” Toivonen says.

She says solutions to the problem must be found rapidly at EU level.

“The most sensible approach would be a one-stop-shop service through which a company could meet all its waste management obligations in a single process. There must also be exemptions from payment obligations for low-volume sales and smaller companies.”

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