Frequently asked questions

You are likely liable in two regimes at once: textiles and packaging. Clothing sold to consumers falls under the Dutch textile EPR (UPV Textiel), which has no lower threshold, so a single sale can already put you in scope. The scheme currently covers clothing, workwear and certain household textiles; footwear is not in scope yet and is only added with the announced extension, expected to apply by 2028 at the latest.

Shipping to Germany adds packaging obligations there: the boxes and filler you send make you a packaging producer, which means registration in the German LUCID register. The needs analysis works through the packaging side for you, per country and in the order to handle it; textiles is not part of the analysis yet and is covered in the knowledge base.

Without the required registration numbers, a marketplace such as bol.com can block your listings. The practical risk is losing your sales channel, before any official body acts.

The number they ask for depends on the regime (packaging, WEEE, batteries or textiles) and the country. Work out which registrations you actually need first, then register precisely, so you do not sign up for the wrong scheme.

Usually yes. If you import products from outside the EU and place them on the market under your own brand, you are legally treated as the producer, with the full producer obligations, not the factory abroad. This is the most commonly missed case for growing webshops.

Being the producer means you, not your supplier, must register and report across the regimes that apply to your products. The analysis checks your role per product and market so you know where you stand.

Not the Dutch threshold. On 12 August 2026 the PPWR starts to apply with its first obligations: packaging manufacturers must have carried out a conformity assessment and drawn up a conformity statement, and every company must establish which role or roles it holds in the packaging chain. The 50,000 kg per year threshold from the 2014 Dutch Packaging Management Decree stays in force through 2026; it is expected to lapse only with the national producer register in 2027/2028, and no Dutch implementing instrument fixing a date has been published.

If you stay below that threshold, the waste management contribution and the reporting duty to Verpact do not apply to you for now, but you must always be able to show how much your packaging weighs and what it is made of. If you also sell across the border, foreign thresholds count separately: in Germany, for example, LUCID registration applies from the first packaged shipment. PPWR questions fall outside the needs analysis; our specialists answer them personally — through the contact form, by e-mail or by telephone.

Up to four, depending on your target market. In the Netherlands they are packaging, WEEE (electronics), batteries and textiles. You can be liable in several at once, for example if you ship an electronic device with a battery in a cardboard box. Germany has separate registers for packaging, electronics and batteries; for textiles there is no German register yet.

Which regimes apply depends on what you sell, in what role, and in which countries. The needs analysis currently asks about three of them (packaging, WEEE and batteries) and returns a result per regime and per country. Textiles is real Dutch law and is covered in the knowledge base, but it is not part of the analysis yet.

If you sell packaged goods to consumers in Germany, you generally need to register in the German LUCID packaging register before you sell, and marketplaces like Amazon.de check for it. Selling into Germany makes you a packaging producer there, separate from your Dutch obligations.

The LUCID registration stays with you: German packaging law does not allow it to be transferred to a third party, so no service provider can register in your name. A producer without an establishment in Germany may appoint an authorised representative (Bevollmächtigter) who then takes over the resulting packaging obligations. For electronics (ElektroG) and batteries (BattDG) it works the other way round: there, an authorised representative is mandatory for foreign producers. We act as authorised representative where that is allowed or required, and guide you through the LUCID entry that stays in your own name.

Typically three at once: WEEE for the device, batteries for the cells (built in or supplied separately, both count), and packaging for how you ship it. Each regime has its own registration and reporting.

Handling them one by one is where things get missed. The analysis lists all applicable regimes together and recommends the order to register in.

It matters a lot: your role decides who carries the obligation. A manufacturer or importer that first places a product on the market usually registers and reports; a pure reseller of already-compliant goods often does not, but that line is easy to cross, especially with dropshipping or own-brand imports.

The analysis determines your role per product and market, so you register only where you actually have to.

Two things, usually in this order: marketplaces block your listings once they check for registration numbers, and authorities can require back-registration and reporting for the period you were liable. The commercial disruption tends to arrive before any formal step.

There is increased need for action rather than reason to panic. The point is to register where you are liable, in the right order, which is exactly what the analysis maps out.

About five minutes. The analysis asks about your role, products, channels and markets and returns a first assessment per regime and country, with a recommended order to act.

It is a first orientation, not legal advice, and you can hand the result to a specialist if you want the registrations handled for you.