do I need to register if I sell from China or the UK to European customers

Yes, registration obligations also apply when selling from China or the UK

Yes, sales from China or the UK to customers in the EU fall under the registration obligation, even if the company itself is established outside the Union. For distance selling — meaning an online shop that supplies directly to a consumer in an EU Member State — what matters is not where the seller is established, but where the packaging is placed on the market. Anyone selling from a non-EU country to European customers becomes the party responsible for that packaging in the same way an EU online shop would be.

The practical difference lies in how it is handled. A company without an establishment in the EU typically arranges this through an authorised representative in the Member State where it supplies: that representative takes on registration and administrative obligations, while responsibility for the packaging remains with the company established outside the EU. This is comparable to how dropshipping and the question of who is responsible is assessed: it is not decisive who sends the package, but who places the packaging on the EU market.

Where this follows from: Articles 44 and 45

Article 45 of Regulation (EU) 2025/40 specifically addresses the situation of distance selling from a country outside the EU, and requires the appointment of an authorised representative in each Member State of supply. Article 44 of the same regulation determines that registration takes place per Member State, meaning that sales to multiple EU countries can also lead to multiple registrations — comparable to the question that arises with multiple EU establishments and the registration obligation per country. For the Netherlands, a threshold of 50,000 kg applies as a separate factor independent of the seller's place of establishment; that threshold is expected to expire from August 2027 onwards, and until then it remains the case that exceeding that quantity — regardless of whether the seller is based in China, the UK or the EU itself — makes registration in the Dutch register mandatory. In other Member States, such as Germany with LUCID, a comparable threshold is typically absent, meaning that supply from a non-EU country there leads more quickly to a registration obligation than the Dutch situation might suggest.