What happens if I don't register for packaging?

Unregistered packagings must not be placed on the market

Packagings from a manufacturer not registered in the correct manufacturer register must not be placed on the market. This is the core of Article 44 of Regulation (EU) 2025/40: registration is not an administrative side matter alongside other PPWR obligations, but a prerequisite for placing packagings on the market at all. Anyone who supplies without registration is operating outside the rules — regardless of whether the packaging itself meets all requirements.

Which register applies depends on the country where packagings are first placed on the market. In the Netherlands, Verpact has a threshold of 50,000 kg per year: below this, registration is currently not mandatory, although keeping records remains necessary. This threshold is expected to be temporary — Verpact assumes it will expire once the PPWR manufacturer register becomes operational, at the earliest from 12 August 2027, with the first reporting year in 2028. In Germany, no such threshold exists: registration in LUCID applies from the first packaging, even if only one package per year, and marketplaces check that number is active and block sellers without registration. Anyone who therefore stays below the Dutch threshold but also supplies to Germany is subject to the registration requirement there from that first package onwards. Belgium, France and Austria each have their own registers and systems that have not yet been reviewed here.

This follows from Article 44 and the manufacturer register per country

Article 44 of Regulation (EU) 2025/40 directly links the placing of packagings on the market to registration of the manufacturer; the regulation itself names no exceptions to this link. Which threshold, which register and which supervisory authority then apply is subsequently determined in the national implementation by each Member State, such as Verpact in the Netherlands and LUCID in Germany.