The PPWR micro-enterprise exemption: when it really applies
Under 10 staff and €2m turnover is not enough: the exemption only applies if every packaging supplier is established in your own Member State.
Three conditions, all at once
Article 15(12) exempts micro-enterprises from conformity assessment, technical file and declaration. The conditions are cumulative: fewer than 10 employees and turnover or balance sheet not above €2 million, counted across the whole group under Recommendation 2003/361/EC; and packaging designed and produced by a supplier established in the same Member State, on whom the obligation then falls.
One Portuguese cork, one French capsule or one label printed in Slovenia is enough to lose the exemption and put the full obligation back on you.
Count the group
If your company belongs to a group — a family holding, a linked farming company — headcount and turnover add up. Many businesses that think they are micro are not.
What to do anyway
Even an exempt business should keep its suppliers' declarations: if a customer or an authority asks for evidence, "my supplier is the exempt party" only works with the documents in hand.
Other guides: Who actually signs the packaging declaration of conformity?Article 16 supplier request: a ready-to-use template
Data collection and document tooling. Not legal advice. The declaration is signed by the manufacturer's legal representative, who remains responsible for it.