do I need to register separately in each country if I have multiple locations

Yes, registration applies per Member State, not per company

Yes: if you have establishments in multiple EU countries, the registration obligation applies in each of those countries separately. The PPWR regulates obligations as an EU-level regulation, but implementation — the register where the notification arrives — is a national matter. This means that an establishment in the Netherlands submits a notification to the Dutch register, an establishment in Germany to the German register, and so on. There is no central EU portal where a single registration applies to all countries at the same time.

This is not only relevant for establishments, but also for distance selling without establishment: anyone selling from one country to customers in other EU countries will typically also acquire a role as a producer there, even without an office or warehouse on site. For the Netherlands, there is a threshold of 50,000 kg of packaging material per year below which the registration obligation with the responsible organisation ceases — more about that Dutch threshold is described separately. Germany does not have this threshold: anyone delivering there through distance sales, even if it is just one package, is considered a producer and must register in the German LUCID register. How LUCID registration from the Netherlands works is worked out separately. The Dutch threshold is furthermore not a permanent exemption but an arrangement that is expected to expire from August 2027 onwards, after which registration also becomes relevant below that threshold.

What Articles 44 and 45 of the regulation determine

Articles 44 and 45 of Regulation (EU) 2025/40 establish the registration obligation per Member State: anyone placing packaged products on the market notifies themselves in the register of each Member State where this occurs. Article 45 addresses the distance selling situation, where delivery from another country is sufficient to be considered a producer in the customer's country, and additionally describes the possibility of designating an authorised representative to handle registration in that country. For those selling through multiple platforms or fulfilment partners, it is also relevant who exactly qualifies as a producer in the chain; this relates to questions that in the section on fulfilment partners are addressed separately from the establishment question.