No, B2B sales as such do not constitute an exception. The Packaging Regulation and the national Extended Producer Responsibility registration obligations do not look at who your customer is, but at who places the packaging on the market for the first time within the European Union. If you sell packaged products to another business, you may still be the party responsible for registration, reporting and contribution — even if a consumer never comes into the picture.
What matters is whether you place the packaging on the market first, or whether your business customer does. Whoever purchases a product, repackages it or applies their own label and subsequently resells it, in practice often acts as a manufacturer within the meaning of the Regulation, regardless of whether the next link in the chain is a business or a private individual.
Why B2B is not an exemption
The underlying rationale of the Packaging Regulation is that packaging waste must be collected and processed somewhere, and the costs must be borne by the party that caused the packaging. A cardboard box, a pallet with shrink film or a shipping box does not change status because the recipient is another business instead of a consumer. Businesses also receive packaging that eventually becomes waste, and that chain must start somewhere administratively.
This does not mean that every link in a B2B chain must register. The Regulation and the national registers are designed so that the obligation is in principle with one party per package: the one who places the packaging on the market of a Member State for the first time. If you sell to another business that resells the goods unchanged, the responsibility may shift to that next link, but that is an assessment per situation and per role, not an automatic consequence because it is B2B.
When it is different
There are situations where B2B sales actually bring the registration obligation closer to you rather than further away. If you import goods from outside the EU and then sell them to Dutch or European businesses, you are usually the one who places the packaging on the market in the Union for the first time. If you package products from a third party yourself, under your own name, to resell them to other businesses, the same applies. The role of manufacturer in the Regulation is linked to who actually creates the packaging or trades it first, not to the type of customer that receives the packaging.
Fulfilment arrangements and marketplace sales do not automatically change this picture either: an intermediary that only provides logistics is usually not the manufacturer, but who places the packaging on the market on behalf of which business remains a question that must be examined per chain. For those kinds of borderline cases, we prefer to cite the guidelines rather than make our own judgment about your specific situation.
What this means for your registration
The practical consequence is that you can better answer the question "does this apply to me" per package type and per role than with a general yes or no about B2B. An installation company that purchases components and passes them on unchanged to contractors sits differently in the chain than a distributor that repackages products under its own brand. Both are B2B, but the outcome may differ.
To establish that difference without guesswork, you are best to work through the questions based on your own packaging and countries of supply. in a few questions see which role applies to you provides a concrete answer per package type and per country, including the registers and deadlines that then apply. If you first want to understand how the Regulation precisely defines the concepts of manufacturer, distributor and importer, you will find the explanation in the knowledge base with explanation per subject.
If you discover via the role finder that you must indeed register, the next step is not complicated but it is something for which you can use guidance: which national register, which contribution and which annual report. How that guidance looks per country and what the costs are, are clearly set out on the page with rates and subscriptions.
Are you still uncertain
B2B sales is therefore not an automatic exemption, but neither is it an automatic obligation. The answer depends on your precise role in the supply chain, per packaging type and per country where you supply. If you are still uncertain about your own situation after reading this, you can consult the frequently asked questions on the overview with answers to recurring questions, or complete the free role finder to see in a few minutes where you stand.