In which EU countries must I register my packaging?

In every country where you first sell, you register

You register in every EU country where your packaging first enters the market — not only in the country where your business is established. This follows directly from the PPWR: packaging from an unregistered producer may not be placed on the market in that Member State. The registers themselves differ significantly by country. The Netherlands has a threshold of 50,000 kg per year through Verpact; below that you do not (yet) need to register, although recordkeeping remains mandatory. That threshold is, however, a phased-out arrangement, not an exemption: Verpact expects it to expire as soon as the PPWR producer register becomes operational, at the earliest 12 August 2027. Germany has no such threshold: via LUCID you are registered from the first packaging onwards, and marketplaces actively check this in practice.

If you supply from the Netherlands to German consumers, the Dutch threshold does not apply — a single package to Germany already makes you a producer there. For Belgium (Fost Plus and Valipac), France (CITEO) and Austria the registers have not yet been reviewed by us; for those countries refer to the official source until we have done so. If you are a micro-enterprise and your packaging supplier is in the same country as you, that supplier can assume the registration obligation — if that supplier is in a different country, that exemption does not apply.

Why this is mandatory per Member State

Article 44 of Regulation (EU) 2025/40 requires registration in the producer register of every Member State where packaging is first placed on the market, and stipulates that packaging from an unregistered producer may not be placed on the market. Anyone supplying directly to end-users at a distance in another Member State without being established there must appoint an authorised representative in that country via a written mandate, according to Article 45 of the same regulation.