【文章标题】：PPWR对岌岌可危的桌面游戏行业再添重击
【文章正文】： PPWR lands another blow to an already precarious tabletop industry 《包装与包装废弃物法规》（PPWR）对原本就岌岌可危的桌面游戏行业再添重击
Regulatory compliance takes up far too many resources and hours. 合规监管消耗着过多的资源与时间。
Small tabletop RPG designers and publishers have expressed concerns about meeting the regulatory changes recently introduced by the Packaging and Packaging Waste Regulation (PPWR), a new legislative framework for promoting sustainable packaging practices across Europe. 小型桌面角色扮演游戏设计师与出版商对欧洲新出台的《包装与包装废弃物法规》（PPWR）带来的合规挑战表示担忧。这项旨在推动可持续包装实践的新立法框架，
With initial requirements being applied from August 12, the framework replaces the previous Packaging and Packaging Waste Directive (PPWD) in place since 1994. 自8月12日起实施初始要求，取代了1994年颁布的旧版《包装与包装废弃物指令》（PPWD）。
“Dont wanna be overly alarmist, but why don’t I see more people and designers freaking out over PPWR? It affects everyone shipping anything to any EU country,” said visual artist and MÖRK BORG creator Johan Nohr on Bluesky. 视觉艺术家兼《MÖRK BORG》创作者约翰·诺尔在Bluesky上表示：“不想危言耸听，但为什么没看到更多从业者为PPWR焦虑？这影响所有向欧盟国家发货的人。”
While this framework is clear about addressing environmental concerns around packaging waste, the reality of how one achieves regulatory compliance isn’t as straightforward. 虽然该框架明确要解决包装废弃物引发的环境问题，但实际合规过程却复杂得多。
One issue many designers cited is the inclusion of the Extended Producer Responsibility (EPR). 许多设计师指出的核心问题在于”延伸生产者责任”（EPR）条款。
Not only do businesses need to adhere to the PPWR, which is being enforced across all 27 European Union (EU) member states, but they must also abide by each country’s specific packaging regulations, with rules and interpretations that can vastly differ amongst one another. 企业不仅要遵守在欧盟27国统一实施的PPWR，还需符合各国差异巨大的具体包装法规——这些规则的解释可能天差地别。
At the same time, this includes fees as part of the EPR, an existing policy that producers — companies that manufacture or import goods — are obliged to fulfill. 同时这还涉及EPR费用——现行政策要求生产商（制造或进口商品的企业）必须承担。
Making matters even more complex is the fact that each EU state implements these EPR fees differently. 更复杂的是，各欧盟国家执行EPR费用的方式各不相同。
They may include one payment for registration, and then a secondary payment that varies across countries and is dependent on materials used. 可能包含注册基础费，以及因国家和材料而异的附加费。
Josh Fox, designer and founder of Black Armada, pointed out that some countries, such as Spain, even charge an ongoing annual fee in addition to the initial registration fee. Black Armada设计师兼创始人乔什·福克斯指出，西班牙等国除初始注册费外还会收取持续年费。
“This is another piece of EU legislation that appears not to have considered small businesses at all,” said Fox in an email to Rascal. 福克斯在给Rascal的邮件中表示：“这又是欧盟完全没考虑小企业的立法案例。”
“Black Armada absolutely loves our EU customers, but we will be going over our sales stats and each member state’s fees to figure out which we can still afford to sell to.” “我们非常珍视欧盟客户，但必须核算各国费用与销售数据来决定保留哪些市场。”
Several designers and publishers like Black Armada, Genesis of Legend Publishing, and Colin Le Sueur of By Odin’s Beard have immediately ceased shipping to countries that are part of the EU, at least temporarily, until they can figure out their next steps. 包括Black Armada、Genesis of Legend Publishing等多家发行商已暂停向欧盟国家发货，至少会持续到他们制定出应对方案。
That’s because one of the primary issues they face is the sheer amount of resources that they need to invest into remaining PPWR compliant. 因为他们面临的核心问题在于维持合规需要投入巨大资源。
“Multiply [the fees] by 27 states, and you have a big problem,” said Fox. 福克斯表示：“27个国家的费用叠加就是大麻烦。”
“The best advice for tabletop RPG folks is to figure out which states are sufficiently profitable to offset these fees, and stop selling to the rest. But it’s not simple because each member state has its own arrangements, so you need to research each one individually.” “对桌游从业者的最佳建议是计算哪些国家利润能覆盖成本，放弃其余市场。但这不简单，因为各国制度不同，需要逐一研究。”
Some shared that Fox’s guidance loses feasibility when publishers still have crowdfunding campaign rewards to fulfill. 有从业者指出，当发行商还需履行众筹回报时，这种建议就难以实施。
Even Black Armada is still figuring out the logistics of sending games to campaign backers from the EU states. 就连Black Armada也在研究如何向欧盟众筹支持者发货。
Losing access to the EU market is another concern. 失去欧盟市场准入是另一重隐忧。
Jason Pitre, founder of Genesis of Legend Publishing Inc., told Rascal that the fear of incurring prohibitive extra costs has dissuaded him from simply ignoring the new rules — a concern also echoed by Le Sueur. Genesis of Legend Publishing创始人杰森·皮特尔表示，天价合规成本让他不敢忽视新规——科林·勒苏尔也持相同观点。
“I am concerned about fines and fees, considering I would have to potentially register with all EU member states or pick and choose who I sell to,” said Le Sueur to Rascal. 勒苏尔告诉Rascal：“考虑到可能需在全部欧盟国家注册或选择性销售，我很担心罚款问题。”
He added that the PPWR may hinder his reach with his EU audience and result in his inability to sell to the EU market, which amounts to losing 10% of his annual revenue. 他补充说PPWR可能切断与欧盟玩家的联系，导致年收入损失10%。
It’s not an insignificant sum, but he pointed out that it wouldn’t put his business under threat for now. 虽非小数，但他指出目前尚不危及公司生存。
“I’ve spent far too many hours this month navigating these new changes, and with the constant possibility of more on the horizon, I’ll have to make a decision whether to ever resume sales to the EU,” he said. “本月已耗费太多时间应对新规，考虑到未来可能还有变化，我必须决定是否恢复欧盟销售。”
Pitre, however, offered a bleaker outlook, referring to this situation as “just another nail in the coffin for my business.” 但皮特尔持更悲观态度，称这是”压垮生意的又一根稻草”。
He explained to Rascal that the byzantine requirements around PPWR compliance are another obstacle in the already tumultuous tabletop RPG landscape, pointing to the US tariff debacle, which made selling directly to customers in the USA “extremely difficult.” 他向Rascal解释，PPWR的复杂要求是桌游行业困境的新障碍，此前美国关税问题已使直销变得”极其困难”。
Then there’s the EU’s General Product Safety Regulation (GPSR), which was instituted at the end of 2024. 还有2024年底实施的欧盟《通用产品安全法规》（GPSR）。
When combined with new PPWR legislation and the elimination of the de minimis exemptions in July 2026, the thought of shipping his games to EU states is giving him pause. 叠加PPWR新规和2026年7月取消的小额豁免政策，他对向欧盟发货产生迟疑。
“Historically, about 50% of my games were exported to the United States, 15% Canada, 15% EU, 10% UK, and the remaining 10% to customers in other countries,” “以往我的游戏50%销往美国，15%加拿大，15%欧盟，10%英国，其余10%至其他国家”