Shipping within the EU

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Unfortunately, I can currently only ship the RCT to nine EU countries, despite the fact that we supposedly have a unified European single market.

This single market exists only in theory and is practically blocked by a multitude of absurd laws. Small businesses and individual developers like myself are particularly affected by this.

The unified European single market is hindered by something as mundane as a cardboard box. Yes, you read that right, a cardboard box. We’re not talking about shipping dangerous goods, just a cardboard box.

To put it simply: If you want to ship something commercially to another country, packaging waste is generated in that country (usually the product and shipping packaging). This packaging waste must be licensed with a local recycling system in that country (in Germany, for example, the „Duale System“ / „Green Dot“).

It sounds simple, but it’s cumbersome and expensive. First of all, each of the 27 EU countries has its own implementation of the EU directive, and many countries don’t even offer an English-language website for registration, yet they impose hefty fines for non-registration.

In two-thirds of the countries, there is an annual minimum fee and a volume-based fee starting from the first box. The price range is from about 30 EUR per year (e.g. Germany) to several hundred euros per year. Additionally, there are a few euros per kg of packaging material and possibly a one-time registration fee. An overview can be found, for example, here.

And as if that weren’t expensive enough, some countries even require a local representative, a notarially appointed „authorized representative,“ to report the total amount of packaging material delivered.

One might think that the EU would strive to harmonize this madness, but quite the opposite: Until 2023, for example, Austria allowed licensing for a 12 EUR annual minimum fee plus volume charges. Since 2026, it’s 199 EUR annually service fee, 75 EUR annually for the authorized representative, and the actual costs per kg of packaging. A joke? No, reality, as seen here for Austria and a few other countries (z.B. Spain).

There are now so-called licensing services that handle registration and reporting – of course – for a fee. Costs of several hundred euros per country are common (e.g. 449 EUR per year and country). This is not a viable alternative. Many small retailers have stopped shipping to other European countries in recent years. As a result, many interesting products are no longer available across Europe.

Update November 2025:

From August 2026, I will no longer ship to other EU countries unless a de minimis threshold applies. From August 12, 2026, the new EU Packaging and Packaging Waste Regulation (PPWR) will stipulate new rules on how to legally place packaged products on the market. An authorized representative will then have to be appointed in each country. With the Green Dot system, this will cost a one-time fee of €89 and then €189 per year for each individual country. In addition, there will be „external“ costs, such as notary fees and, of course, licensing fees for the EPR systems and country-specific charges.

The IT-Recht Kanzlei provides a good overview of the planned changes.

Meanwhile, the press is also noticing what a mess is coming out of Brussels.:

Update August 2026:

The internet has woken up: The petition on Change.org, launched four years ago and with just 5,000 signatures at the beginning of 2026, has exceeded the 10,000 mark. On X, the first bloggers and retailers are posting that they are suspending shipping within Europe.

Posts auf X.com

und viele weitere Posts auf X.com („PPWR“).

Several online magazines, news papers and blogs are writing about it:

Articles in online magazines and news papers

The costs appear to be settling at approximately 300 EUR per EU country, plus the costs charged by local recycling systems for collection, disposal, and recycling. Costs may be slightly lower in some countries, but significant bureaucracy is to be expected. For all EU countries combined, the costs will ultimately amount to 8,000 – 10,000 EUR per year, in addition to numerous hours spent on documentation and reporting.

The EU Commission really outdid itself on August 12th: „We have called on the European Parliament and the EU member states to abolish the requirement that EU companies shipping goods to other EU countries must appoint an authorized representative.“ (see link above to the Händlerbund) This whole mess comes from the EU Commission, and simply abolishing the requirement for an authorized representative doesn’t solve the problem, as companies would still have to register locally in 27 countries. Furthermore, the law is in effect; an Instagram post by the EU has no effect on overriding it.

 

Alternative delivery options:

However, some users have found a solution to this problem by obtaining a German shipping address. As seller, I ship to a clearly German address, and the shipping service provider forwards the package on behalf of the customer.

I would love to ship directly to you, as we used to be able to do within the EU, but unfortunately, this cumbersome and incomprehensible interim solution is now required in an allegedly unified EU single market.

For more details on shipping arrangements, please inquire with the respective shipping service providers. You organize the onward transport from the providers to you yourself.

A few well-known shipping service providers are:

I do not guarantee the quality of these providers, so please do your research before using them. The costs are usually no higher than for direct shipping, as these service providers have special conditions with the transport companies. If you send via a forwarding service, I will grant a discount of 4 EUR, so the resulting costs should be comparable to direct shipping.

The feedback I received indicates that the shipping costs via the forwarder, including the discounted shipping costs within Germany, were lower than the direct shipping costs (e.g. 16 EUR via the forwarder compared to 18 EUR for direct shipping to Hungary, due to the better contracts the forwarder has).

 

Further reading
Further reading: