Complexity through countries and channels
You sell to several European countries. Do you know where EPR obligations arise?
Every country you ship to can create its own obligation, and a registration in your home market does not extend to it. That is the whole difficulty of cross-border retail: the obligations do not grow with your turnover, they multiply with your map.
EPR almost certainly applies to you already. What each new market changes is where it applies, in which regime, and in what order to act. That is what the needs analysis returns.
Needs analysis: coming soon
Situations we see
- 01A new destination countrySales to Germany pick up and the boxes you were already shipping make you a packaging producer there, with a LUCID registration due before the first packaged shipment rather than after a threshold.
- 02One product, several countriesThe same article is compliant at home and unregistered in three destination markets, because each market runs its own register and counts its own volumes.
- 03A second sales channelAdding a marketplace next to your own shop does not change what you sell, but it does add a party that checks your registration numbers and can block the listing.
What makes it hard
- Registrations are per country, so the work grows with each market rather than being done once.
- Thresholds differ: below the Dutch 50,000 kg you owe no contribution, while German LUCID applies from the first packaged shipment.
- The same product can sit in a different regime abroad than it does at home.
- A missed obligation usually surfaces as a blocked listing, before any authority raises it.
What can apply to you
Your role
Start here: in a cross-border chain the same company can be a reseller at home and a producer abroad.
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.
Packaging
The regime you almost certainly fall into, because shipping is packaging.
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.
Registering abroad
The core of the cross-border case: what a second country actually adds.
A registration in your home market does not travel. Selling packaged goods to consumers in Germany makes you a packaging producer there, which means registering in the German LUCID register before you sell. That applies from the first packaged shipment; there is no threshold to grow into first. Germany keeps separate registers for packaging, electronics and batteries, and for textiles there is no German register yet.
Who may act for you differs per regime. German packaging law does not allow the LUCID registration to be transferred, so no service provider can register in your name; a producer without an establishment in Germany may appoint an authorised representative who then takes over the resulting obligations. For ElektroG and BattDG it works the other way round: there an authorised representative is mandatory for foreign producers.
Marketplaces
If you sell through a marketplace as well, this is where a missed registration shows up first.
Marketplaces check registration numbers, and a listing without the number they ask for can be blocked. In practice the commercial disruption arrives before any official body acts.
Which number they ask for depends on the regime and the country. The useful order is to establish which registrations you actually need, then register precisely, rather than signing up to a scheme that turns out to be the wrong one.
How we help
Understand your EPR obligations before cross-border growth becomes a compliance problem.
- 01One assessment that covers every market you sell into, instead of one specialist per country.
- 02A result per regime and per country, with a recommended order to register in, so expansion into the next market is a step you plan rather than repair.
- 03Where an authorised representative is allowed or required, we act as one; where the registration must stay in your own name, we guide you through it.
Questions from this group
- 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.
- MARKETPLACES · BOL.COM
bol.com is asking for my registration number. What happens if I don't have one?
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.
- PACKAGING · PPWR 2026
I only put a few kilos of packaging on the market. What changes on 12 August 2026?
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.
- OVERVIEW · REGIMES
How many EPR regimes are there, and how do I know which ones apply to me?
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.
Understand your EPR obligations before cross-border growth becomes a compliance problem.
Needs analysis: coming soon