who must register the packaging if I do dropshipping

In drop-shipping, the registration obligation typically lies with the party that determines the brand or packaging

In drop-shipping, it is not the party receiving the order that automatically must register, but the party that, according to the definition in Article 3 of Regulation (EU) 2025/40, qualifies as a "manufacturer": that is the party that places the packaged products on the market of a country for the first time, often under its own name or brand. In drop-shipping, the flow of goods goes directly from a supplier — sometimes outside the EU — to the end customer, while the web shop places the order and handles customer contact. Who precisely "places the packaging on the market" in that chain depends on who chooses the packaging, whose name appears on it, and from which country it is delivered.

In practice, this means that a web shop selling under its own name and determining the packaging (in part) is often considered a manufacturer, even if it never physically touches the boxes. If the web shop acts purely as an intermediary for a supplier that ships directly from another country to the customer, then the registration obligation may instead lie with that supplier — especially if that supplier delivers from outside the EU, which raises its own set of questions that are addressed under web shop from abroad delivering to EU customers. Because drop-shipping by definition involves a chain of multiple parties, it is also useful to consider the question whether someone is already a manufacturer of their own shipping box, as that distinction works the same way here.

Basis: Article 3 and the guidelines on the concept of manufacturer

The core lies in the definition of "manufacturer" in Article 3 of Regulation (EU) 2025/40, supplemented by the Commission guidelines (C/2026/3084) that specifically address who in a chain of multiple parties qualifies as a manufacturer. The register in which the manufacturer must then register follows from Article 44 of the regulation — and that register differs by country. A Dutch web shop drop-shipping to German customers may have to deal with LUCID, whereas in the Netherlands itself the 50,000 kg threshold from the Verpact system applies; that threshold is not expected to remain in place and is expected to expire as of August 2027. France and other member states have their own registers, without the Dutch threshold. In case of doubt about who in a drop-shipping chain precisely qualifies as a manufacturer, the Commission guidelines cite the relevant criteria, but the final determination in a borderline case rests with the national authority or court of the country in question.