Do I need to register if I only supply to resellers?

Supplying to resellers does not change the registration obligation

If you only supply to resellers, you are not automatically exempted from registration in a producer register. The registration obligation applies to the party that first places packaging on the market of a member state, not to the question of who the end buyer is. A brand owner, webshop or importer that supplies packaged products to wholesalers, distributors or retailers thereby places that packaging in circulation for the first time and is in principle subject to the same registration obligation as a party that sells directly to consumers.

What does differ with exclusively B2B supply is the obligation to appoint an authorised representative in a country where you have no establishment. This obligation is linked to distance selling to end-users. A reseller is not an end-user, so this specific route is not affected by B2B supply in itself. This does not change the fact that registration in the producer register of the country where the packaging is first supplied remains in force — even when that supply is to a business and not to a consumer.

What Article 44 and the registers per country say

This result follows from Article 44 of Regulation (EU) 2025/40, which links registration to the first placing of packaging on the market in a member state, regardless of the nature of the purchaser; Article 45 separately governs the authorised representative for distance selling to end-users. How registration works in practice varies by country. In the Netherlands, Verpact applies a threshold of 50,000 kilograms of packaging per year on the Dutch market, below which registration is not yet required — this threshold is expected to be removed once the PPWR producer register becomes operational, at the earliest 12 August 2027. In Germany, LUCID has no threshold: registration is mandatory from the first package, even for exclusive supply to resellers. For Belgium, France and Austria, the national registers have not yet been checked on this point.