The German home theater retailer Patrick Schappert has stopped shipping to other EU countries, and his protest has made its way from his own YouTube channel to news reports on WDR, tagesschau.de, and RTL. But is there any truth to his criticism? STEREO GUIDE has compared the 124 pages of the new Packaging Ordinance, current explanations from the European Commission, information from industry associations, and statements from other retailers. The analysis reveals that while Schappert may be exaggerating some of the consequences, he does hit on a sore spot in the European single market.
GROBI.TV usually focuses on projectors, screens, speakers, and creating the biggest possible movie theater experience right in your own home. But at the end of July, Patrick Schappert, CEO of the home theater retailer Grobi in Kaarst, suddenly held up not a new generation of projectors but a stack of paper in front of the camera: the 124-page EU Packaging and Packaging Waste Regulation (PPWR).
On Facebook, the algorithm showed me one of his videos. The tone was more reminiscent of a protest rally than the channel’s usual, sometimes quite detailed product presentations. But while opinions may be divided on Schapperts penchant for dramatization, his decisive action caught everyone’s attention: Grobi stopped shipping internationally.
During my subsequent research, I came across other small retailers who had removed EU countries from their online stores for the same reason. As a result, what started as an angry YouTube video turned into an issue that extends far beyond the hi-fi and home theater industries.
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From a projector review to the TV news
With approximately 94,000 subscribers, GROBI.TV has a considerable reach for a specialized home theater retailer. Schappert’s videos eventually reached media outlets outside the industry as well. RTL West visited him in Kaarst, and WDR covered the story and published an in-depth interview, which also appeared on Tagesschau.de.
In the RTL West report, Schappert holds up a printed copy of the law to the camera and asks, “As a business owner, how am I supposed to implement all of this exactly as written? It’s simply not possible.”
As of August 10, 2026, Grobi’s online store will only accept shipping addresses in Germany. According to the company, this move means it is forgoing a significant six-figure annual revenue. Schappert cites costs, documentation requirements, legal uncertainty, and the mandatory authorized representatives in the respective destination countries as reasons for this decision.
These figures could not be independently verified. In a phone call with STEREO GUIDE, Schappert referred to his own publications and elaborated on his points of criticism, which he has since addressed in another video. His revenue figures and the individual risk assessment therefore remain the company’s own statements.
A serious problem—and an understandable goal
Despite all the criticism, we shouldn’t forget why the EU took action in the first place. According to Eurostat, 79.7 million metric tons of packaging waste were generated in the European Union in 2023. That amounted to an average of 177.8 kilograms per resident. Germany, at 215.2 kilograms, was well above that average.
EU Regulation 2025/40 on packaging and packaging waste is intended to reduce packaging, make it more recyclable, decrease the use of new raw materials, and regulate the financing of collection and recovery. It entered into force on February 11, 2025, and has generally been directly applicable in all member states since August 12, 2026.
There is little to criticize about the environmental approach. The problem arises when a regulatory framework—which is actually intended to harmonize the single market—is combined with 27 national registries, waste disposal systems, and points of contact.
Not all 124 pages apply at once
The stack of papers that Schappert effectively holds up to the camera gives the impression that a dealer must immediately incorporate all 124 pages into his business operations. That is not entirely true.
In addition to the actual provisions, the text contains extensive recitals, tasks for authorities and member states, and provisions covering a wide variety of packaging types and industries. Furthermore, many of the requirements will take effect in phases.
As of August 12, 2026, new definitions of “packaging,” obligations to identify certain packaging responsible parties, and substance limits—including PFAS limits for food packaging—will take effect, among other provisions. The major requirements regarding recyclability, recycled content, and the reduction of weight and volume will largely take effect starting in 2030. The harmonized material labeling requirements will also not take effect across the board on the first effective date.
The European Commission’s FAQ dated August 3, 2026, explicitly states that the general obligations must be read in conjunction with the respective transition periods set forth in the individual substantive regulations. That said, 124 pages still don’t make for light vacation reading. But neither are they 124 pages of immediate obligations for an individual home theater or hi-fi retailer.
A manufacturer is not the same as a producer
The first stumbling block lies in the German terminology itself. Among other things, the PPWR distinguishes between “distributor,” “manufacturer,” and “producer.” The last two terms, in particular, seem almost reversed. In the English version, the German “Erzeuger” is translated as “manufacturer,” while “Hersteller” is translated as “producer.”
| Role | Essential Meaning | Typical Responsibilities |
|---|---|---|
| Distributor | Resells packaging or packaged goods | Check registration and identification; if in doubt, stop the sale |
| Producer | Manufactures packaging or has it manufactured under its own name or brand | Conformity, Technical Documentation, EU Declaration of Conformity, and Identification |
| Manufacturer | Puts packaging or packaged goods on the market for the first time in a Member State | Registration, Participation in the System, Financing of Waste Disposal, and Volume Reporting |
A retailer can fulfill multiple roles at the same time. Someone who resells a pre-packaged amplifier purchased in Germany exclusively within Germany is, in this supply chain, primarily a distributor. Anyone who imports equipment or packaging from a third country may also be considered an importer and a manufacturer. Anyone who has their own products or custom-branded packaging manufactured may be considered a producer.
And anyone who ships directly from Germany to an end customer in Austria, France, or the Netherlands becomes the manufacturer in that country for the purposes of extended producer responsibility—regardless of who manufactured the product or the shipping box.
The Central Agency for Packaging Registration now summarizes the difference quite clearly: The producer is responsible for the design and compliance, while the manufacturer is responsible for financing disposal in the country where the packaging is expected to become waste.
The real sticking point lies across the border
The most significant part of Schapperts’ criticism therefore does not concern the manufacture of a shipping box, but rather Articles 44 and 45 of the PPWR.
A retailer who supplies products directly to end users in another Member State must, as a general rule, register in the respective destination country and comply with extended producer responsibility requirements there. In addition, Article 45(3) requires that, for such cross-border direct sales, a representative authorized in writing be appointed in each Member State in which the company is not itself established.
There is no de minimis threshold for the first shipment. The frequently cited 10-metric-ton packaging volume does not constitute a general exemption. Reporting requirements may simply be simplified for shipments below this threshold.
Schapperts’ figure of at least 300 euros per country is not a legally mandated fee. However, it falls within the realistic range charged by commercial service providers. In the provider directory of the BVT brochure on the Packaging Ordinance linked by Grobi, a corresponding EPR compliance service is offered starting at 299 euros per year and per country. The European Commission also cites standard market entry prices of several hundred euros in its impact assessment.
Someone who only occasionally sells a cable to Belgium or a projector to Austria may end up paying more for administrative costs than for packaging—even before factoring in the actual disposal fees. For a corporation operating throughout Europe, these fixed costs are spread across a large volume of sales. For a specialized retailer, however, they can make doing business with individual countries unprofitable.
However, registration and disposal obligations were not entirely invented on August 12, 2026. Many member states already had national EPR systems in place prior to that. The German E-Commerce and Mail Order Association (Bundesverband E-Commerce und Versandhandel) even told WDR that numerous retailers were simply unaware of their existing obligations. However, the PPWR now explicitly mandates the appointment of an authorized representative for cross-border direct sales throughout the EU—without simultaneously establishing a central European point of contact.
Does an address label make an electronics shipper a manufacturer?
This is where the most intriguing contradiction in the entire story begins. The BVT brochure, published in July 2026, classifies retailers as producers if they package goods themselves using cardboard boxes, tape, or packing material. Even in the case of a used cardboard box, legally speaking, a new packaging unit is created by resealing it, addressing it, or covering old labels.
According to the EU Commission’s FAQ, which was published shortly thereafter, this interpretation goes too far.
The Commission explains, using the example of a plain, standard cardboard box, that the box already takes its final form at the manufacturer’s facility—even if it is delivered flat and is only unfolded before shipment. Accordingly, the manufacturer of the physical cardboard box remains the producer. Assembling the cardboard, adhesive tape, and other pre-manufactured packaging components does not automatically create new packaging. A simple shipping label is expressly not considered a brand label and does not make the shipper the producer.
Rules that allow for interpretation
Even before this FAQ was published, Hanna Hillnhütter, a lawyer with the Händlerbund, had already refuted the stricter German interpretation in an interview on GROBI.TV. Her succinct conclusion: “We do not share this legal opinion.”
Meanwhile, the Swabian Chamber of Industry and Commerce (IHK) has also openly pointed out the conflicting interpretations. According to the new EU FAQs, a shipping label does not establish producer status. At the same time, the Chamber emphasizes that neither the FAQs nor the guidelines are legally binding. Ultimately, only courts can provide a definitive and binding interpretation.
This means that Schappert did not pull this conflict out of thin air. His account reflects information that was actually disseminated by German authorities and associations. However, according to the European Commission’s most recent interpretation, the simplistic equation “address label equals producer” does not hold true for standard neutral cardboard.
The situation may be different if a retailer orders packaging under its own brand, specifies its design, or modifies existing packaging in a way that could affect its compliance.
Falk Steiner reaches a similarly nuanced conclusion in his analysis for Heise Online: The burden posed by country-specific producer responsibility is real, while the broad interpretation of labeling requirements set forth in the Commission’s most recent guidelines has lost significant ground.
Do used cardboard boxes have to go in the trash?
In the WDR report, Schappert holds up a used cardboard box and says, “If I make a mistake here, it’s really going in the trash.”
That would be a rather cynical consequence, especially in the name of a regulation on waste prevention. However, the disposal of existing cardboard boxes is not required.
According to the Commission’s FAQs, packaging produced before August 12, 2026, that is still in stock does not need to be destroyed, remanufactured, or completely relabeled. For such inventory, the required manufacturer information may also be provided via accompanying documents. Packaging that was already placed on the market before the effective date may generally continue to be used.
Even a plain shipping box does not automatically become “newly produced packaging” simply by adding a new shipping label. The blanket assertion that every box that is relabeled or re-addressed triggers all producer obligations on the part of the retailer is not supported by the Commission’s subsequent interpretation.
Nevertheless, it remains important to be able to trace the origin and characteristics of the packaging used. In the case of packaging that has been custom-printed, modified, or actually manufactured from scratch using individual materials, the classification may differ.
Inspection requirements and sales bans are a real problem
The fact that neutral shipping boxes are no longer a concern does not mean that pure retailers have nothing to do with the PPWR. Article 19 requires distributors to verify, among other things, before making a sale, whether the relevant manufacturer is registered, whether the required markings are present, and whether the producer or importer has fulfilled their identification obligations.
If there is reasonable suspicion that a package does not comply with regulations, it may not be made available on the market until the matter has been clarified. In this respect, the focus on inspection, recall, recycling, and possible sales bans mentioned by the BVT is indeed accurate.
The obligations go even further for companies that import packaged products or empty packaging from third countries, offer private-label products, or have packaging manufactured under their own name. Depending on their role, they must either maintain technical documentation and declarations of conformity or require them from their suppliers.
However, the warning about imminent five- or six-figure penalties also requires some clarification. Under the new Packaging Act Implementation Act, the German provisions governing fines directly related to PPWR violations will not take effect until February 12, 2027. National violations—such as those related to registration and participation in recycling systems—can, however, be prosecuted as early as August 12, 2026. In addition, there may be warnings under competition law and restrictions on sales.
Fines of up to 200,000 euros are imposed for certain violations. However, this does not mean that every incorrectly sorted cardboard box automatically results in a six-figure bill.
HiFiPilot: “Good goal, poor execution”
Jens Hörmann’s responses show that these concerns are not limited to Grobi. He is one of the managing directors of HifiPilot GmbH, which sells hi-fi and home theater products directly to consumers and operates a showroom in Sulzfeld.
When asked in what capacity his company was affected by the PPWR, Hörmann replied to STEREO GUIDE: “Both as a manufacturer and as a producer.”
This is entirely plausible for a company that engages in direct sales, cross-border shipments, and international supply chains. However, even at HifiPilot, the specific role assigned to each individual package depends on the particular product and the flow of goods.
Hörmann explicitly considers the underlying environmental concept of the PPWR to be sound. His assessment of its practical implementation, however, is far less favorable: “The basic concept is good, but the implementation and communication—typical of the EU, as usual—are a complete disaster.”
He anticipates a significant amount of work related to documentation, packaging information, service providers, and separate volume reports in each country. Depending on the number of countries supplied, this could result in annual costs of several thousand euros.
His proposed solution is obvious: a centralized European system modeled after the one-stop shop for value-added tax. A retailer would report packaging volumes and destination countries in one place; fees and data could then be distributed among the member states. It is difficult to justify that, in 2026, the single market would have a central portal for VAT but could require up to 26 additional intermediaries for a single shipping box.
M.A.D.: European Expansion on Hold
Markus Pajonk, commercial director at the hi-fi distributor M.A.D. Anja Hobbs, describes the specific implications for business decisions. Among other products, the company distributes speakers from the British manufacturer Acoustic Energy in Germany and specializes in affordable British hi-fi equipment as well as brands with “British Soul.”
According to Pajonk, the company learned of the new requirements in February or March 2026 through the compliance service provider Take-e-way. In the meantime, plans for further expansion in Europe as well as the launch of additional brands have been put on hold for the time being. The company first wants to clarify which registrations and other requirements must actually be met in each country. The differing national systems also complicate cooperation with European partners.
Pajonk’s brief assessment: “Expansion plans for Europe are on hold.”
Pajonk now estimates that the total time required for an employee to read and implement EU and federal regulations, as well as coordinate with suppliers, amounts to about 1.5 hours per day. That amounts to nearly one full workday per week. This figure explicitly does not refer solely to the PPWR. However, it illustrates the proportion of time that regulatory tasks can now take up in a small sales department.
APHEUM: Sustainably packaged—but still affected
Christopher Colshorn has a different starting point. He is the managing director of Newstyle Vermögensverwaltung UG (limited liability), which offers digital art displays to end customers under the APHEUM brand. According to the company, it uses only paper and cardboard packaging and is already working to limit the amount of packaging to what is necessary for product protection and shipping.
Colshorn therefore does not expect any significant changes to packaging materials. Nevertheless, APHEUM will need to address issues such as documentation, material composition, supplier verification, registrations, and other compliance matters. Colshorn, too, only became aware of the scope of the PPWR through his own research.
The basic regulatory burden does not grow in proportion to the volume of packaging generated. Large platforms could centralize and automate their processes and spread their fixed costs across millions of transactions. This is not possible for a small, independent provider. Colshorn therefore sees a risk that such companies will abandon their own cross-border sales and integrate more closely into the infrastructure of large marketplaces.
His concern: “Regulation intended to promote sustainability could thus indirectly contribute to further concentrating market structures in favor of very large platforms.”
Where were the Chamber of Industry and Commerce and the trade associations?
According to Hörmann, he only learned of the specific consequences a few days or weeks before the deadline, and more or less by chance. Despite being a mandatory member, he said he had received no information that was meaningful to him from the government or his Chamber of Industry and Commerce.
However, the companies were not left entirely without information resources. That said, there were regional differences, and the timing also appears less than ideal. The Middle Lower Rhine Chamber of Industry and Commerce (IHK), in whose district Grobi is located, had already announced a free webinar on the PPWR for October 29, 2025. The German Chamber of Industry and Commerce (DIHK) also distributed a nine-page fact sheet outlining roles, deadlines, and key obligations.
However, this fact sheet in particular highlights the challenges of obtaining timely information. It lists the extended producer responsibility in a table with a blanket date of “starting in 2027,” even though registration and authorization under the PPWR have generally been in effect since August 12, 2026. A 40 percent reuse rate is described succinctly as “sales packaging (distance selling),” while Article 29 specifies certain types of packaging and explicitly excludes cardboard boxes.
Such overviews provided guidance, but did not reliably answer the practical questions that are crucial for small online retailers. The Commission did not release its detailed FAQs until nine days before the regulation took effect. In them, it partially contradicted the interpretation that had previously been advocated in Germany.
Meanwhile, even DIHK department head Christoph Petri has told the Tagesschau news program that the regulation is “too cumbersome” and is calling for a pause due to legal gray areas and the fact that this is uncharted territory for many companies.
It would therefore be unfair to conclude that the Chamber of Industry and Commerce (IHK) and the trade associations did absolutely nothing. However, the information they provided clearly did not prevent affected companies from being confronted with conflicting interpretations and unanswered questions regarding specific details immediately before the deadline.
Not an isolated case from Kaarst
Grobi is neither the only retailer to stop shipping internationally, nor is the problem limited to high-end consumer electronics.
Wollkontor Erlangen informed its customers that, due to the PPWR, it is currently unable to ship goods to other EU countries. Heinrich Obermüller, a long-established haberdashery retailer, explained that direct shipping to Austria is impossible due to regulations and costs. In the meantime, the company is using the Austrian Post’s “AllesPost Deutschland” forwarding service as a workaround.
A few such cases do not yet prove a widespread collapse of European e-commerce. However, they do reveal a structural effect: fixed costs and country-specific expenses hit those retailers the hardest who generate only low sales in individual countries. Small specialty retailers, in particular, will therefore remove countries from their delivery areas, while large companies can spread the costs across millions of shipments.
For customers, this means fewer options and possibly additional detours via package forwarding services. It is doubtful whether longer transport routes and additional handling stations serve the goal of waste reduction.
The frequently made claim that merchants from third countries do not have to worry about any of these rules at all is also too sweeping. The PPWR requires online marketplaces to verify the registrations and self-declarations of their sellers. Member states may also require companies outside the EU to appoint authorized representatives. However, enforcement is likely to remain more difficult against a small seller in the Far East than against a company in Kaarst or Sulzfeld.
The EU wanted to correct itself
Ironically, the most compelling evidence of this bureaucratic impasse comes from the European Commission itself. In December 2025, it proposed suspending the requirement for EU-based companies to appoint EPR authorized representatives until January 1, 2035.
In its reasoning, the Commission cites costs, administrative problems, and competitive disadvantages. Otherwise, companies might be forced to appoint representatives in up to 26 additional member states.
However, the relief measure did not take effect in time. According to a document from the Council of the European Union dated June 19, 2026, the suspension met with significant reservations from an overwhelming majority of member states. Negotiations on these two parts of the relief package were suspended. The requirement for authorized representatives therefore remains in effect.
This creates a remarkable situation: The Commission recognizes a regulation as a burden on the competitiveness of European companies, proposes suspending it for several years—and yet the member states still allow the rule to take effect on the effective date.
What Remains of Schappert’s Protest
Patrick Schappert is a key figure in this story, but he is not a neutral authority on the interpretation of European packaging law. The 124-page document suggests more immediate obligations than a single retailer actually faces. According to the Commission’s current interpretation, a shipping label on a plain, standard cardboard box does not make Grobi a producer. Used cardboard boxes do not have to be disposed of across the board. And not every mistake immediately results in a five- or six-figure fine.
At its core, however, his criticism is valid. Anyone who ships directly from Germany to an end customer in another EU country becomes a manufacturer there for the purposes of extended producer responsibility. They must register, comply with national obligations, and, as a general rule, appoint an authorized representative—even if they are shipping just a single package.
Based on our research, an address label does not automatically make Grobi a producer. However, the shipping address in Austria designates the company as a manufacturer in Austria. This small linguistic distinction determines fees, registration, and the entire process of international trade.
The fact that retailers have to study a 124-page regulation, additional guidelines, about 70 pages of FAQs, and contradictory fact sheets to clarify these roles illustrates the problem almost better than any outraged YouTube video.
The PPWR pursues a worthwhile environmental goal. Yet, ironically, precisely where it was intended to harmonize the European market, it largely allows the patchwork of national regulations to remain in place and reinforces it with an additional requirement to appoint an authorized representative. Schappert exaggerates some of the details. Nevertheless, he has hit the nail on the head.
Status of legal and political developments: August 16, 2026. This article is intended to provide a journalistic overview and is not a substitute for individual legal advice.
