Small tabletop RPG designers and publishers are expressing concerns about the regulatory changes introduced by the Packaging and Packaging Waste Regulation (PPWR), which aims to promote sustainable packaging practices across Europe. The initial requirements took effect on August 12, replacing the previous Packaging and Packaging Waste Directive (PPWD) that had been in place since 1994. Johan Nohr, visual artist and creator of MÖRK BORG, noted on Bluesky that the regulation affects all businesses shipping to any EU country.
While the framework addresses environmental concerns, achieving compliance is complex. Designers have highlighted the Extended Producer Responsibility (EPR) as a significant challenge. Businesses must comply with the PPWR across all 27 EU member states, each with its own specific packaging regulations and fees. Josh Fox, designer and founder of Black Armada, mentioned that some countries, like Spain, impose ongoing annual fees in addition to initial registration costs.
Fox stated, "This is another piece of EU legislation that appears not to have considered small businesses at all." Several designers, including those from Black Armada and Genesis of Legend Publishing, have temporarily ceased shipping to EU countries while they assess their options. Fox advised that businesses should determine which states are profitable enough to offset compliance fees, but this is complicated by the varying regulations.
Jason Pitre, founder of Genesis of Legend Publishing Inc., expressed concerns about the potential loss of access to the EU market, which could impact his revenue. He noted that navigating the new regulations has consumed significant time, and he is uncertain about future sales to the EU. Pitre described the situation as "just another nail in the coffin for my business," citing the challenges posed by both the PPWR and the EU’s General Product Safety Regulation (GPSR).
The PPWR document is filled with complex legal language, making it difficult for many publishers to understand. Pitre highlighted the differing labeling requirements based on business roles, while Fox pointed out the ambiguity surrounding what constitutes packaging. Some sellers may need to produce additional packaging to comply with the regulations, complicating their operations further.
Working with international distributors may help navigate these complexities, but the costs can be prohibitive for small businesses. John Scott, a tabletop designer, noted that distributors have raised their prices due to the new regulations, which could lead to increased costs for customers in the EU.
Overall, the new regulations, combined with market volatility, have left the tabletop RPG industry in a challenging position. Pitre suggested that larger publishers might bear the brunt of these regulatory burdens, but small publishers and independent designers face significant uncertainty. Maz Hamilton, business director of Rowan, Rook and Decard, indicated that the intricacies of the PPWR remain unclear, and some businesses are choosing to restrict their sales to specific countries. Le Sueur concluded that while regulations are important, they should not apply uniformly to all companies, regardless of size.