am I responsible myself or is bol.com if I sell through them

Who registers the packaging: the seller, not bol.com

When selling via bol.com, the seller remains the party considered the manufacturer of the packaging, not the platform. Bol.com facilitates the sale, but the regulation places the obligation on the party that places the packaging on the market — and that is the party that packs and ships the product, even when this occurs through a marketplace. This is comparable to the situation of who is responsible in dropshipping: the platform or intermediary handles the transaction, but the obligation follows the party that packs.

This applies both when selling through your own bol.com account and when shipping via bol.com's fulfilment service (Logistics by bol.com — LDB), although with fulfilment the division of practical tasks may differ. Anyone who packs and ships themselves is in most cases also the party that must register and contribute to national systems. Uncertainty about your own role as a seller on a marketplace is one of the situations where it is advisable to clarify your own position first, for example via the question whether someone is a manufacturer of their own shipping box.

Registration differs by country of delivery

This obligation is not implemented the same way in every country, as the registers vary. When delivering to a German customer via bol.com, the registration obligation applies in the German LUCID register (ZSVR) from the first shipped package — Germany has no minimum threshold. When delivering from the Netherlands, the Dutch threshold of 50,000 kg of packaging material per year applies, but this threshold is a declining deadline and is expected to expire from August 2027 onwards. If you deliver via bol.com in multiple countries, you will be dealing with multiple registers, each with its own registration procedure.

The basis: the manufacturer concept in the regulation

The fact that the seller and not the platform is considered a manufacturer follows from Article 44 of Regulation (EU) 2025/40, which governs the register of manufacturers, and from the Commission guidelines C/2026/3084 of 10 June 2026 on the concept of manufacturer. These guidelines clarify who is considered a manufacturer under which circumstances, and confirm that a sales platform generally does not itself fulfil that role, but that a ruling in a specific borderline case should be sought in the guidelines themselves or with the competent national authority.