A members' association · Vienna
Nobody should have to close their shop to Europe over paperwork.
Thousands of small makers stopped shipping to the EU this year — not because they did anything wrong, but because the admin costs more than they earn. KontorBund is the group that buys it together, publishes what each country really needs, and refuses to let this be normal.
What changed
There is no single European window.
Put packaged goods on the market in an EU country where you aren't established, and that country wants two things: a registration in its own register, and an authorised representative based on its own soil. Per country. Twenty-seven times, in twenty-seven languages, with twenty-seven deadlines.
The fees aren't the problem
The recycling fees themselves are worked out by weight. Ship a little and you pay a little — that part is fair, and it isn't what's closing shops.
The paperwork is
Registration and a representative cost roughly the same whoever you are. That flat charge is what makes selling a few hundred euros of handmade goods into a country stop making sense.
Art. 45(3), and it
applies wherever you aren't established. What is fragmented is everything
underneath: twenty-seven registers, twenty-seven procedures, twenty-seven
providers to buy from. The Regulation does require the registers to converge and
to link to one another, but member states have eighteen months from the
Commission's implementing act to build them and the first harmonised report isn't
due until 2030. So this is the transition, not the design — which is a reason to
argue about how it was sequenced, and no help at all to anyone shipping a parcel
this week.
The cost
Same paperwork for a shoebox as for a warehouse.
A maker shipping 40 kg a year
A distributor shipping 40 tonnes a year
A thousand times the volume. Exactly the same paperwork bill. A fixed cost with no volume threshold isn't a fee on trade — it's a fee on being small. That's the thing we're here to change.
And that isn't only unfair. It's against the rules.
This is the part almost nobody quotes, so here it is in full.
Art. 46(5) of the same Regulation that created these duties says:
"Producer responsibility organisations shall ensure equal treatment of producers regardless of their origin or size, without placing a disproportionate burden on producers of small quantities of packaging, including packaging of packaged products, including small and medium-sized enterprises."
That binds the schemes themselves — ARA, Interzero, Citeo, Der Grüne Punkt — not
just governments. Art. 44(11)(d) adds that registration fees must be
"cost-based and proportionate", and Art. 45(2) that EPR costs must be
set "in a transparent, proportional, non-discriminatory and efficient way".
Which is why the Observatory is the other half of this association and not a side project. A median cost per €1,000 of revenue is a talking point. The same number, put to a scheme that is legally required not to place a disproportionate burden on small producers, is evidence. Nobody has collected it yet. That's the job.
What we do
Pool it. Publish it. Prove it.
Pool it
We negotiate representative and registration fees as one block instead of everyone paying the retail rate alone. Where a country allows it, the representative we appoint can handle your registration too. A hundred small shops turning up together is a completely different conversation.
Publish it
A free, open, country-by-country guide to what each member state actually asks for — every entry dated and re-checked. Nobody else publishes this openly, because the sector makes its money from the confusion.
Prove it
We collect real quotes from members, aggregate them so no shop is ever identifiable, and take the median cost per €1,000 of revenue to the people writing the rules. Nobody has that number yet, because nobody is collecting it.
You're not the only one
What it sounded like when the shops closed.
Every line here was posted in public by a small seller this year. Reading twenty of them together is a different experience from reading one.
Sadly, we are now closed to everyone in the EU except Ireland, for all orders for the foreseeable future.
Artwork & printsIf any other businesses are struggling with this, or have found some way around it — please tell me.
Enamel pinsIt is far too costly, and simply unattainable for 99% of artists and small business owners.
Handmade creationsI've turned off shipping to the EU for now. This is the first time in nine years I've had to do that.
CeramicsWe will close down shipping to almost every EU country on Wednesday.
Subscription boxesCan't believe I have to say goodbye to almost 700 people.
StationeryDer direkte Versand ins europäische Ausland ist nicht mehr machbar.
Pet supplies, GermanyThese new regulations will make it so I can't ship to the EU at all.
IllustrationMy last day of being able to sell to my wonderful EU and NI customers.
Craft suppliesI really am so sorry that I am not in a position to be able to continue offering my creations to those of you in the EU.
Handmade giftsI will not be able to ship to the European Union on my next restock.
ApparelIt's a very sad day for us.
Art studio, IrelandQuotes are from public posts, shortened and stripped of any name, shop or handle. These sellers are not members and this isn't an endorsement — they are here because they describe the problem better than we could.
The Kontor
One desk for every country.
Each desk is kept by a member who actually ships there and re-checks it every quarter. All twenty-seven are up. Every one is a draft with no keeper yet — so if you ship to a country and know its register, you can improve that desk faster than we can.
Before you join
Three things to be straight about.
Plenty of people will sell you something that sounds like this. Here's exactly what we do and don't take on.
We're not your authorised representative.
We don't hold your liability. We negotiate the terms — the contract is still yours to sign.
Registration works differently in every country.
Art. 44(3) lets each member state decide whether registration may be handled for you under a written mandate, normally by the authorised representative we help you appoint. Some took that option; Germany didn't, so there it's a personal duty you have to complete yourself, and anyone offering to do it in your name is selling you something that isn't compliant. It's a per-country answer by design, and knowing which is which is a large part of what we're for.
We don't give legal advice.
Everything we publish is shared experience with a date on it. For an answer you can rely on, talk to a lawyer.
Join us
Add your name to the founding members.
Tell us where you're based and what you ship. That's enough for us to work out which rules actually apply to you — and to count you when we go and negotiate.