A company that supplies exclusively to other businesses often automatically assumes one thing: packaging rules are for webshops that sell to consumers, and that does not apply to us. This assumption is the most common mistake in B2B resale, and it is persistent because it feels logical at first glance.
The regulation does not look at who the buyer is, but at who places the packaging on the market first in a country. Whether that buyer is a private individual or another business is not the distinguishing factor for that question. A company that purchases products, repackages them or resells them under its own name to other businesses can therefore itself be the party with obligations, even if no consumer is involved in the entire process.
Why this assumption is so persistent
The confusion usually arises because people associate EPR obligations with household waste: the box that arrives at a customer's doorstep. In B2B transactions, this image does not seem to fit, because the packaging goes to a warehouse, a shop or another business, not to a household. Yet in practice there are also registration obligations for packaging that never reaches a consumer; only the way this proceeds can differ by country and by packaging type. Those who do not know this difference too quickly conclude that B2B equals exemption.
What goes wrong in practice
"Our supplier will surely handle this"
The most common variant of the error is assuming that the party you buy from has already handled the registration. That may be true, but it does not have to be. As soon as you fill a package yourself, repack it, relabel it or place it on the market under your own name, the responsibility can fall to you, even if the original supplier has already arranged something elsewhere. Asking your supplier is a good starting point, but not a substitute for checking your own role yourself.
The packaging changes without the registration being updated
A second pitfall arises when a company sells the actual contents unchanged, but does adapt the shipping packaging: your own box, your own sticker, a different volume. This change can shift the distribution of roles, while the company itself still assumes the old situation in which someone else was responsible.
Resale across borders via the same route
When B2B resale takes place to customers in another EU country, more often changes than just the customer. A registration that has been arranged in one country does not automatically cover the obligations in the country where the customer is located. The fact that an earlier link in the chain has already arranged something for its own country says nothing about what is needed once the goods cross a border.
How you prevent this
The core is simple to state, even if the implementation differs from situation to situation: do not rely on the assumption that B2B equals exemption, and do not rely on the assumption that a supplier has already covered everything. Instead, ask concretely who places which packaging on which market first, and document this, even if the answer is "not us". This documentation is precisely what a supervisor may ask for later, and it is better to have an answer ready than to have to reconstruct it afterwards.
Because the distribution of roles can differ by packaging type and country, it is not always clear at a glance where you stand. In the role finder that determines your position by packaging type and country answer a few questions about how your packaging reaches your customers, and you will receive an indication of what applies to that situation, including cases where nothing is required of you. If you prefer to first read how other B2B situations have been assessed, you will find comparable issues worked out in the knowledge base with worked-out situations by topic comparable issues worked out.
If that initial check shows that you do indeed have a role, the next step is to establish that role per country, together with the associated registers and deadlines. How that process is structured and where the information comes from is explained on the page that explains where the information comes from. For the costs of guided registration per country, should that apply to your situation, there is an overview on overview of prices for guided registration.
Are you still unsure whether B2B resale entails obligations in your case, then first run through the free quick-scan or browse through the topics in the knowledge base. Both can be consulted without an account and indicate when something does and when something does not apply to you.