A one-person tabletop game shop in The Hague submitted order-level data to a European Commission consultation on 13 August 2026 showing that packaging registration across nine European Union member states would cost between 2,400 and 4,300 euro a year against roughly 130 euro of genuine recycling liability.

The filing came from SuperBuff B.V., trading as The Role Play Goblin, a single-location shop on Westeinde in Den Haag with a webshop attached. Its owner, Kevin Toet, addressed the submission to the Commission consultation on the producer register implementing regulation and published the underlying workings under the shop's own name. The document is not a survey, an industry estimate or a trade association position. It is a five-page annex built from one merchant's transaction records.

That distinction matters because the argument about extended producer responsibility costs has, until now, been conducted largely in aggregate. Trade bodies cite burden. Regulators cite proportionality. Neither side has often put a specific shop's order ledger on the table.

What the filing contains

The dataset covers every order placed between 28 November 2025 and 12 August 2026, roughly eight and a half months, and was extracted from the shop's WooCommerce REST API on 13 August 2026. According to the evidence pack, the pull returned 2,109 orders in total. Of those, 1,258 were in-store point of sale transactions. Only 271 orders resulted in a shipped parcel.

Of the 271 parcels, 149 went to Dutch addresses and 122 crossed a border. Those parcels reached 21 destination countries, 18 of them EU member states. Total shipped revenue was 20,559.49 euro. Cross-border shipped revenue was 10,861.54 euro. The total weight of goods shipped, across every destination in the entire trading history, was 374.12 kilograms.

Three non-EU destinations appear in the same period: one parcel each to Great Britain, Iceland and Switzerland.

The shop qualifies as a micro-enterprise under the EU definition, with fewer than ten staff and turnover well below the two million euro ceiling. It is, on the numbers, close to the smallest unit of cross-border commerce that the single market produces.

Nine countries, 98 parcels, 130 euro of environmental liability

The core table in the filing sets recurring annual compliance cost against the environmental liability that cost is supposed to fund. It covers nine member states where the obligation is described as live.

Belgium took 30 parcels. The recurring cost is put at 350 to 1,050 euro a year against an eco-fee of 2 euro, a multiple of 175 to 525 times. Germany took 24 parcels, at 190 to 340 euro against 20 euro of eco-fee. Spain took 14 parcels at about 302 euro against 3 euro. France took 10 parcels at 270 to 680 euro against 80 euro, the narrowest ratio in the table at 3 to 9 times. Finland took nine parcels at 76 euro against 2 to 4 euro. Ireland took five parcels at no recurring cost at all. Denmark took three parcels at 431 euro against 7 to 9 euro. Sweden took two parcels at 390 to 740 euro against 10 to 13 euro. Austria took one parcel at 390 to 650 euro against 2 to 10 euro.

Across the nine, 98 parcels generate a recurring compliance cost of 2,400 to 4,300 euro a year and an environmental liability of about 130 euro. The aggregate multiple runs from 18 to 33 times.

Set against cross-border revenue of 10,861.54 euro over eight and a half months, registering in all nine would consume between a fifth and two fifths of the money that crossed a border.

The per-country register list in the filing names the schemes involved: Fost Plus in Belgium, LUCID plus a dual system contract in Germany, the MITECO producer register plus a SCRAP in Spain, the ADEME register plus CITEO in France with a unique identification number required, Rinki in Finland, Repak in Ireland, Dansk Producentansvar in Denmark, Naturvardsverket plus FTI in Sweden, and the EDM register plus a collection system in Austria.

Austria as the limit case

The Austrian line is the clearest single illustration in the document, and it is the one Toet led with when he approached PPC Land.

One parcel, four items, 82.32 euro of revenue, across the shop's entire trading history. The recycling fee genuinely owed on that packaging is put at 2 to 10 euro. The authorised representative costs 300 to 500 euro per year. The licensing minimum adds 90 to 150 euro per year. Total cost of continuing to ship that one order lawfully: 390 to 650 euro a year.

The multiple in that single market runs from 39 to 325 times.

Where the money actually goes

The filing locates the cost precisely, and the location is not the eco-contribution.

According to the evidence pack, the authorised representative fee runs from roughly 150 to 1,000 euro per country per year, is entirely insensitive to volume, and accounts for 70 to 90 percent of the total cost in every country that requires one. A shop sending one parcel pays what a shop sending ten thousand parcels pays.

The remainder sits in fixed licensing minimums, which do not fall below their floor, and in owner time spent registering and reporting across up to 18 national portals in as many languages. The filing states plainly that there is no compliance staff and that every hour spent on registration comes out of running the shop.

The per-kilogram tariff, described in the document as the only genuinely proportionate component, is the 130 euro.

That structure produces a specific behavioural prediction. Below a few hundred parcels per country per year, the filing argues, the arithmetic does not yield cheaper compliance. It yields a decision to stop shipping to the country, or to route orders through a channel where the obligation already sits with someone else.

Under Article 45(3) of Regulation (EU) 2025/40, a producer not established in the destination member state must appoint an authorised representative there by written mandate. There is no single European licence. A Spanish registration confers nothing in Germany, France or Italy, and for a direct-to-consumer seller the destination market is where the packaging is first made available.

The countries charging most

Ranked by the top of the range in the filing, Belgium is the most expensive single market in the shop's set. Fost Plus registration through an authorised representative is put at 350 to 1,050 euro a year. Sweden follows at 390 to 740 euro through Naturvardsverket and FTI, then France at 270 to 680 euro across the ADEME register and CITEO, then Austria at 390 to 650 euro for the EDM register plus a collection system. Denmark is quoted as a single figure rather than a range, at 431 euro through Dansk Producentansvar. Germany sits at 190 to 340 euro for LUCID plus a dual system contract, Spain at about 302 euro for the MITECO register plus a SCRAP, and Finland at 76 euro through Rinki. Ireland is nil.

Rank the same nine by the bottom of each range and the order changes. Denmark moves to the top at 431 euro, because it has no lower bound to fall to. Austria and Sweden follow at 390 euro, then Belgium at 350 and Spain at 302, with France dropping to sixth at 270 euro. The spread inside a single country is in several cases wider than the gap between countries, which is a function of provider choice rather than of national policy.

The ranking that carries the operational weight is neither of those. Divide each country's upper-bound cost by the parcels actually sent there and the figures separate sharply. Austria costs 650 euro for one parcel. Sweden costs 370 euro per parcel across two. Denmark runs to roughly 144 euro per parcel across three, France to 68 euro across ten, and Belgium to 35 euro across thirty. Germany, the second-busiest destination at 24 parcels, comes down to about 14 euro per parcel, and Finland to under 9 euro across nine. Those per-parcel figures are calculated from the filing's own cost ranges and parcel counts rather than quoted from it.

Measured against revenue, the picture inverts the usual assumption that the biggest markets carry the biggest compliance bills. Austrian recurring cost at the top of its range is close to eight times the 82.32 euro the market produced. Swedish cost is more than three times the 214.85 euro from two parcels, and Danish cost is nearly twice the 229.34 euro from three. France sits at roughly four fifths of its 857.37 euro. Belgium, the largest cross-border market in the set at 2,539.13 euro, absorbs about two fifths at the top of its range. Germany and Spain, at around a fifth each, are the only markets where the cost reads as a normal operating expense. One qualification applies throughout: the fee figures are annual while the revenue figures cover eight and a half months, so the ratios are conservative in the schemes' favour rather than against them.

A separate ranking emerges from the multiple between fee and liability. Belgium leads at 175 to 525 times, followed by Austria at 39 to 325 times and Spain at about 100 times. France, the market with the largest genuine eco-fee in the set at 80 euro, records the narrowest ratio at 3 to 9 times. The correlation across the nine is not with volume or with revenue. It is with whether a paid intermediary is mandatory.

Two member states that already do it differently

The section of the filing carrying the most weight is not the complaint. It is the pair of counterexamples.

Ireland charges nothing. Repak obligations sit behind a cumulative statutory threshold written into primary law, applying above 10 tonnes of packaging and above one million euro of Irish turnover. The Role Play Goblin is roughly 666 times under it. No representative is required and no registration attaches, because the tonnage in question is negligible.

Finland charges 76 euro a year. Rinki still accepts direct registration from a foreign seller with no authorised representative required.

Neither member state, the filing notes, has suffered an environmental consequence as a result. The argument follows from that: what is being requested is not a novel exemption but the adoption elsewhere of two arrangements that already operate inside the single market.

The threshold that does not travel

The asymmetry the document identifies is a domestic one. In the Netherlands, the Verpact threshold sits at 50,000 kilograms of packaging placed on the Dutch market per calendar year. Total goods weight across every destination in the shop's whole trading history is 374 kilograms, and the packaging is a fraction of that again.

A Dutch shop selling only to Dutch customers therefore has no packaging contribution and no reporting obligation. The identical shop, selling identical products, becomes subject to full registration, a paid representative and periodic reporting the moment a single parcel crosses into Germany, France, Spain or Austria.

The filing draws the conclusion directly: the compliance burden is triggered by the act of trading across a border rather than by environmental impact, which it characterises as the definition of a barrier to the internal market.

What the numbers do not cover

The document is unusually explicit about its own limits, and several of them cut against the headline figures.

The compliance costs are ranges built from published scheme tariffs and quotes for authorised representative services gathered in August 2026. They are not invoices paid. In his covering email, Toet flagged the same point without prompting: "the fee figures are researched estimates of published rates rather than invoices, since I haven't registered anywhere yet."

Packaging weight is tracked separately from goods weight. The kilogram figures in the filing are shipped product weight, not packaging weight, which means the 374 kilogram total is not the number a scheme would actually assess.

Of 866 physical products in the catalogue, 328 currently have no recorded weight, so unit weights for part of the range are estimated. The filing states this affects precision rather than order of magnitude.

The trading window is eight and a half months rather than a full year, and the document concedes that annualised figures would be higher.

Two further gaps sit in the arithmetic rather than the caveats. The nine-country table is headed "parcels per year" while the 98 parcels it counts were shipped over the eight and a half month window, so the annual rate implied is understated. And the nine countries costed are a subset of the 18 EU destinations the shop reached. Poland, Greece, the Czech Republic, Portugal, Italy, Romania, Slovakia and Hungary account for a further 21 cross-border parcels, and the per-country table lists a register requirement against each of them. The 2,400 to 4,300 euro range therefore describes part of the exposure, not all of it.

A smaller inconsistency runs between the documents. The email cites roughly 10,700 euro of cross-border revenue where the evidence pack gives 10,861.54 euro, and describes the Austrian position as about 500 euro a year against a stated range of 390 to 650 euro. The evidence pack also attributes its source dataset to software called PackTrack EPR, while the publicly available product carrying the same country reference is published as EPR Tracker.

The commercial interest attached

That software is Toet's own, and the filing and the product share an author.

According to the EPR Tracker documentation, the plugin derives a per-order packaging record from WooCommerce order data, with each package described as a recipe of individually weighed items so that re-weighing one item updates every box using it. Orders store a snapshot of the weights they were logged with, so correcting a weight changes future records rather than filed ones. Packaging records sit in custom tables in the merchant's own database, and the free tier makes no external requests.

The product requires WordPress 6.4 or later, WooCommerce 8.0 or later and PHP 8.1 or later, and ships in English with a Dutch translation. It runs on WordPress, which is open source, and is not affiliated with Automattic. A free tier covers the materials library, per-order records, annual totals by material and destination country, and a summary CSV. A paid tier costs 100 euro per year excluding VAT for one shop and adds per-order detail export, Excel output, arbitrary date ranges and automatic assignment rules.

The documentation states directly that the plugin does not file anything and does not provide legal advice, and that whether a merchant must register with a scheme is determined by the scheme rather than by the software.

None of that invalidates the order data, which is the merchant's own transaction record rather than a modelled estimate. It does mean the filing was produced by a party with a commercial interest in merchants tracking packaging obligations, and the Commission case handler reading it will weigh that alongside the numbers.

Toet's account of how the obligation surfaced is in the product documentation rather than the filing. "I found out I had a packaging obligation after the deadline had already passed," he wrote. "That's how most people find out, it turns out. Nobody sends you a letter when you start shipping parcels."

What is being asked for

The submission closes with four requests, ordered by preference.

First, a de minimis threshold applied consistently across all member states, below which a micro-enterprise selling cross-border is exempt from registration and reporting. Second, recognition of a producer's home member state registration for small cross-border volumes, so that one registration covers the single market. Third, removal of the mandatory authorised representative requirement for micro-enterprises, or a cap on what may be charged for it. Fourth, failing all of the above, a single EU-level registration and payment point in place of 27 national portals.

The filing notes that the first and third asks are already operating law in Ireland and Finland respectively.

Whether any of them lands is a separate question. The Commission proposed suspending the Article 45(3) representative obligation until 1 January 2035 through COM(2025) 982, published on 10 December 2025 as part of the Omnibus VIII environmental simplification package. The Council discontinued negotiations on that file and its parallel instrument on 24 June 2026, citing strong reservations from a large majority of member states and a comprehensive review of producer responsibility frameworks expected under the circular economy act in autumn 2026. European Parliament draft reports published in May 2026 proposed narrowing any exemption to companies with up to 49 employees and turnover up to 10 million euros. None of that is adopted text.

Why this matters for the marketing community

Shipping eligibility and advertising availability are the same variable inside a product feed. A merchant that switches off a destination country removes the underlying inventory from shopping feeds, and with it the campaigns pointed at that market. The mechanism registers as disapprovals and coverage loss rather than as a paused campaign, because shipping settings and country targeting are governed separately from campaign structure in Merchant Center.

European regulatory changes to cross-border parcels have already demonstrated how fast that transmission runs. The EU abolished its 150 euro customs duty exemption on 1 July 2026, replacing it with a flat 3 euro charge per item. Within a week, auction data across roughly 500 European advertisers showed Temu cutting Google Shopping spend and Shein approaching a full exit. By early August, Pinterest reported European advertising growth of 12 percent while citing pressure from Asia-based cross-border retailers, and Criteo cut full-year guidance in the same earnings cycle.

The packaging file inverts the incidence. A per-item customs charge scales with volume and is absorbable by high-volume operators. Registration and representation are fixed per market. The Role Play Goblin's own table is the clean demonstration: 98 parcels carry the same nine mandates that 98,000 parcels would carry. That is a cost curve pointing away from the smallest advertisers in the European market, and those advertisers are the base of the self-serve layer that platforms have spent three years building products for.

The demand-side context is not marginal either. Research covered by PPC Land found that 45 percent of shoppers are deterred by high delivery costs or long delivery times and 41 percent by customs and duties, with proximity dominating European purchasing patterns. A compliance regime that prices small sellers out of neighbouring markets acts on the same channel from the supply side.

There is a measurement point buried in the filing that outlasts the policy question. The shop could produce this argument because it had per-order destination and weight data at all. Most merchants of comparable size cannot reconstruct kilograms of packaging placed on a foreign market after the fact, which is why the debate has run on estimates. Order-level records turn a lobbying position into an audit trail, and the same records are what a scheme would ask for if it came looking.

Timeline

Summary

Who: Kevin Toet, owner of SuperBuff B.V. trading as The Role Play Goblin, a single-location tabletop roleplaying game shop with a webshop in Den Haag, filing with the European Commission. The submission also implicates national packaging registers and producer responsibility organisations including Fost Plus, LUCID, MITECO, CITEO, Rinki, Repak, Dansk Producentansvar, FTI, CONAI and Verpact.

What: A five-page evidence pack built from 2,109 WooCommerce orders showing that packaging registration in nine EU member states carries a recurring cost of 2,400 to 4,300 euro a year against roughly 130 euro of genuine recycling liability, a multiple of 18 to 33 times, with the authorised representative fee accounting for 70 to 90 percent of the total. The filing requests a consistent de minimis threshold, home-state registration recognition, removal or capping of the mandatory representative requirement for micro-enterprises, or a single EU-level registration point.

When: The dataset covers 28 November 2025 to 12 August 2026. The extraction, the filing and the approach to PPC Land all took place on 13 August 2026, one day after Regulation (EU) 2025/40 began to apply.

Where: Twenty-one destination countries, 18 of them EU member states, from a shop established in the Netherlands. Nine of those markets are costed in the filing; the remaining nine EU destinations and three non-EU destinations are not.

Why: Registration and representation are fixed costs per market that do not scale with parcel volume, which places a shop shipping one parcel to Austria on the same fee schedule as a shop shipping ten thousand. Ireland and Finland already operate arrangements that remove the cost for volumes this small, without recorded environmental consequence, which is the basis on which the filing asks the other member states to follow.