Complexity through the product itself
One electronic product. Multiple EPR obligations. Several countries.
A single electronic product routinely triggers three regimes at the same time: WEEE for the device, batteries for the cells, and packaging for how you ship it. Each has its own registration and its own reporting, and none of them covers the others.
That is why checking registration duties one at a time works badly here. The risk in electronics is not a rule you cannot find, it is the second and third obligation attached to a product you already registered once.
Needs analysis: coming soon
Situations we see
- 01The device is registered, the battery is notA company registers under WEEE and stops there, while the cell inside the product carries its own duty, whether it is built in or supplied loose beside the device.
- 02B2B and B2C in the same catalogueWho you sell to and how it reaches them changes the obligations, so the same product can be handled two different ways within one company.
- 03The accessory nobody classified as electronicsA powered add-on shipped beside a non-electronic product brings the whole WEEE and battery set with it.
- 04The same device in four countriesGermany alone keeps separate registers for packaging, electronics and batteries. Multiply that by your destination markets and the count grows faster than the catalogue.
What makes it hard
- One product, several parallel regimes. The chance of missing one is structurally higher than in a pure packaging case.
- Sales channel and customer type change what applies, so a per-product answer is not automatically a per-order answer.
- Each country can require its own registration, and for electronics and batteries an authorised representative is mandatory for foreign producers rather than optional.
- Registering one regime feels like completing the task, which is precisely why the rest stays open.
What can apply to you
Electronics (WEEE)
The regime the product itself sits in.
Electrical and electronic equipment falls under the WEEE regime, organised in the Netherlands through Stichting OPEN. The duty attaches to the device itself and applies whether you sell to consumers or to businesses, though the route differs.
What counts as electronics is wider than most sellers assume: anything that needs current or a battery to do its job, including the small powered accessory shipped alongside a non-electronic product.
Batteries
The second one, attached to the same product and easy to stop short of.
Batteries are their own regime with their own registration and reporting, separate from the device. Cells built into a product and cells supplied loose beside it both count.
This is where an obligation is most often missed by one step: a company registers the device under WEEE, and the battery inside it stays unregistered.
Packaging
And the third, attached to how it leaves your warehouse.
Packaging is the regime almost everyone falls into, because the box and the filler you ship in are packaging you place on the Dutch market. Above 50,000 kg per calendar year you owe the variable waste management contribution to Verpact. That is a total across all materials together, not a limit per material, and crossing it is not a cliff: the first 50,000 kg is still deducted pro rata to the weight of the materials you declared.
Below the threshold the contribution and the reporting duty to Verpact do not apply to you for now, but the duty to show how much your packaging weighs and what it is made of applies from your first shipment. The threshold comes from the 2014 Dutch Packaging Management Decree and stays in force through 2026; it is expected to lapse only with the national producer register in 2027/2028, and no Dutch instrument fixing a date has been published.
Your role
Which of the three land on you rather than on your supplier depends on this.
Your role decides who carries the obligation. Whoever first places a product on the market normally registers and reports: the manufacturer, or the importer bringing it in from outside the EU. A pure reseller of goods that are already compliant often does not.
That line is easier to cross than it looks. If you import from outside the EU and sell under your own brand, you are legally the producer, with the full producer obligations, and the factory abroad is not. This is the case growing webshops miss most often.
How we help
See all EPR obligations triggered by your electronic products, across products and countries.
- 01The full set of obligations a product triggers, listed together rather than discovered one at a time.
- 02A recommended order to register in, so the device, the cells and the packaging are handled as one job.
- 03A whole-picture needs analysis instead of an isolated check of a single registration duty. In this category that is the difference that decides the outcome.
Questions from this group
- ELECTRONICS · MULTIPLE
I sell electronics with batteries. Which regimes do I fall under?
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.
- EXPORT · NL→DE
I'm starting to sell on Amazon.de. What is LUCID and do I need it?
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.
- ROLES · WHO PAYS
I don't know whether I'm a manufacturer, importer or reseller. Does it matter?
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.
See all EPR obligations triggered by your electronic products, across products and countries.
Needs analysis: coming soon