It was decided that the registration is left to the individual countries (which I personally agree with, at least I think I do). Now the deadline has come and passed and some of the individual countries have not provided easy ways of registering. At what point should which entity done what?
Should I as a SMB been keeping track of the registries for the individual countries and lobbied my government to apply pressure to the other governments to set up the registrations?
Should my representative have lobbied harder to take control away from the individual countries in the union so this issue could not arise? (Should I have done so as an SMB even though I on a personal level agree with the individual registries?)
Because, again, right now we have a law on the books with relatively harsh punishments but nonexistent enforcement, this benefits no one.
(Absolutely in good faith here as well, just angry at local governments not doing their job)
It was decided collectively(!) that a registration in the individual countries is the process to use. Against the original draft, in which the European Commission explicitly(!) proposed EU-wide packaging requirements due to concerns of fragmented processes.
The result is a nationalization of the packaging compliance for a producer, while the obligations for the product inside that packaging, the seller, the buyer, the payment transfer etc. are all already regulated on EU-level.
This should have been reviewed by the country members with local experts, in your case a duty of the German representatives in the EU, and ultimately opposed as bad solution for SMB (the very business that the government claims to support).
Now it is a enforced regulation. You can of course give feedback to the EU [0], but in my opinion the only meaningful (yet exhausting) move as a SMB is to put the pressure on your LOCAL government (directly and via the local chamber of commerce) that they frankly f#cked up in representing your interests, causing you a competitive disadvantage in the European single market.
We will need to extinguish every attempt to blame this on "the EU". Germany was THERE when this regulation was written, there were 14(!) sessions within the European Council and 5 sessions in the European Parliament on this topic throughout 2023 and 2024 [1]
The EU is very transparent on this process, e.g. in case of Germany you can look up that Delara Burkhardt of SPD was one of the rapporteurs of the process, but there is no noted contribution from German parliament to this regulation at all (but from Czech, Italy, Spain, Romania, Poland)
(Don't get me wrong, all the proposed steps above apply to me as well. We now need to create noise to rectify something that could have been easily avoided if elected representatives would also ... represent)
Thank you, I see my disconnect now, in my mind "the problem" was that there are no easily useable registries for other countries, when in fact "the problem" is that the regulation itself should have been looked at harder and probably be changed now that the neccesary public outcry is here.
In that case I'm pretty happy with the situation, our industry rep got in touch with the commission and they were receptive and provided guidance relatively quickly. Really not fair to blame on EU, if my local trade board can bug us about the placement of fire extinguishers they could also bug us about giving an input into industry-affecting legislation.
It was decided that the registration is left to the individual countries (which I personally agree with, at least I think I do). Now the deadline has come and passed and some of the individual countries have not provided easy ways of registering. At what point should which entity done what?
Should I as a SMB been keeping track of the registries for the individual countries and lobbied my government to apply pressure to the other governments to set up the registrations?
Should my representative have lobbied harder to take control away from the individual countries in the union so this issue could not arise? (Should I have done so as an SMB even though I on a personal level agree with the individual registries?)
Because, again, right now we have a law on the books with relatively harsh punishments but nonexistent enforcement, this benefits no one.