Is EPR applicable to small sellers?

Amazon is sending emails about EPR (extended product responsibility) compliance in Europe (e.g. Germany, France, Spain etc.)

We are brand owner and manufacturer (private label) but we sell may be a few thousand products a year. We do not make products in restricted categories like Electronics, batteries. So our only obligation is due to packaging.

Is there any kind of threshold that exempts small sellers from the obligation to register and pay for EPR fees? It does not really make sense if they want small businesses to register and pay tax for packaging in 3 countries.