do I need to register packaging for free samples as well

Yes, packaging for free samples counts too

Packaging for free samples also counts as a rule for your PPWR obligations. The regulation looks at who places packaging on the market, not whether a selling price is attached to it. A sample that is packaged and sent out the door — shipped separately or as an enclosure with an order — is packaging within the meaning of Article 3 of Regulation (EU) 2025/40, and that definition makes no exception for free products, giveaways or marketing shipments. Anyone who sends samples and uses their own packaging material for it (bags, boxes, cushioning material) places that material on the market in practice just as much as packaging around a paid product.

This means the same question applies as with regular shipments: who is the manufacturer or producer for this, and in which country must it be registered. With samples that are enclosed as an addition in a shipping box that already counts, there is often little extra weight added; with samples that are packaged separately and shipped on their own, that weight in principle counts normally towards the total. How that role distribution works out precisely when your own box is used is described under am I a manufacturer if I pack my own boxes myself.

What differs per country

Within the Netherlands, the 50,000 kg per year threshold applies, and as long as the total packaging weight — samples included — stays below that, there is in practice no obligation to register with Verpact. That threshold is incidentally not a permanent exemption but a scheme that is expected to expire from August 2027 onwards, which means that smaller volumes with samples will then also fall under it. More about that limit is at do I need to register with Verpact as a small webshop.

Germany has no such threshold: whoever supplies there, even with free samples in their own packaging, is a producer from the first gram and must register in the LUCID register, as explained under do I need to register in LUCID as a Dutch webshop supplying to Germany. Other Member States have their own registers and their own thresholds or lack thereof. The obligation from the regulation itself travels everywhere; what differs is purely the national register where the notification goes.

Justification

Article 3 of Regulation (EU) 2025/40 defines packaging based on its function and use, without distinguishing between paid and free products; the Commission guidelines C/2026/3084 on the concept of manufacturer confirm that whoever places packaged products on the market can fall under the manufacturer definition, regardless of whether a sales transaction is involved.