Complexity through the claim to act responsibly
Sustainability doesn't stop with the product.
A company that has made sustainability part of its promise is usually further along on materials than on obligations. Recycled packaging, a take-back scheme, a measured footprint. What is missing is the picture of which environmental registrations those same products create across the markets they sell in.
That gap is not a compliance failure yet. It is the difference between meeting your obligations and being able to show that you do. And the proof gets requested in one specific form: registration numbers, per regime and per country. Marketplaces check them, authorities can require back-registration for the period you were liable, and partners ask for them during onboarding.
Needs analysis: coming soon
Situations we see
- 01The claim is ahead of the registerThe sustainability page is specific and well-sourced, while the answer to "which schemes are you registered with, in which countries" would take a week to assemble.
- 02Expansion outpaced the overviewThree new markets were opened in a year, each with its own registers, and nobody owns the consolidated picture.
- 03Someone asks firstA retail partner, a marketplace or an authority requests registration numbers, and the answer is assembled under time pressure instead of being on file.
- 04The obligation moved with the productA change of supplier or a shift to own-brand manufacture quietly turned the company into the producer in law, without anything visible changing.
What makes it hard
- Environmental responsibility is measured and reported, while environmental registrations rarely get the same treatment.
- Blind spots are invisible by construction: you cannot audit a regime you have not identified.
- Every market keeps its own registers, so "are we covered" has no single place to look it up.
- Proof is cheap to keep and expensive to reconstruct. Assembled under a deadline, it arrives late and incomplete.
What can apply to you
Your role
The first blind spot in almost every overview: which obligations are yours at all.
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.
Registering abroad
Why "are we compliant" has no one-country answer. The proof a partner asks for is one row per market, not one for all of them.
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.
How we help
Turn environmental compliance into part of responsible international growth.
- 01An obligations profile per target country, listing registration duties, risks and follow-up duties such as marking. A document you can put in front of whoever asks.
- 02Blind spots identified before someone else finds them, so compliance stays something you organise rather than something that happens to you.
- 03One consolidated view across countries, so the sustainability page and the registers tell the same story.
Questions from this group
- 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.
- RISK · WHAT IF
What do I risk if I don't register?
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.
- 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.
Turn environmental compliance into part of responsible international growth.
Needs analysis: coming soon