Small tabletop RPG designers and publishers are struggling with compliance under the new Packaging and Packaging Waste Regulation (PPWR) in the European Union. The regulation, which replaced the 1994 Packaging and Packaging Waste Directive (PPWD), took effect on August 12, 2026, and introduces complex Extended Producer Responsibility (EPR) requirements. Johan Nohr, creator of MÖRK BORG, expressed concern on Bluesky about the lack of awareness among designers regarding PPWR’s broad impact.

Josh Fox of Black Armada noted that EPR fees vary significantly across the 27 EU member states, with some countries like Spain charging ongoing annual fees in addition to registration costs. Fox advised publishers to analyze which EU markets remain profitable after fees, but acknowledged the difficulty due to differing national rules. Several companies, including Black Armada, Genesis of Legend Publishing, and Colin Le Sueur of By Odin’s Beard, have temporarily halted EU shipments.

Le Sueur estimates losing access to the EU market could cost him 10% of annual revenue, though he does not see it as an existential threat. Publishers cite excessive time spent navigating compliance, with some still fulfilling crowdfunding rewards to EU backers despite the challenges.