alt Hacker NewsI believe the view layed out in the article is wrong. The German Wikipedia has an article about the PPWR. One Paragraph is saying: "The distributor must verify that the manufacturer and, where applicable, the importer have fulfilled their requirements, that all necessary markings are affixed to the packaging, and that the manufacturer is registered in the producer register pursuant to Article 44." That does not sound like you are responsible for registering yourself but you need to purchase your packaging from registered vendors and you need to verify that. Sound reasonable to me.
Unfortunately, for direct cross-border sales, the regulation explicitly makes the seller the "producer" in the customer’s Member State, and requires registration there. Buying an envelope from a registered Greek supplier does not register the seller in Germany or France.