Many entrepreneurs bringing packaging to another EU market for the first time assume that the registration they have already arranged for the Netherlands also applies there. That is not the case. Registration with Verpact covers only the placing of packaging on the Dutch market; if you want to sell the same packaging in Germany, France or Belgium, you need a separate registration there, with a different register, its own reporting cycle and its own fees.
The reason lies in how the European obligation has been translated into national legislation. Extended producer responsibility for packaging is an EU-wide principle, but each Member State has implemented it with its own register, its own executing body and its own practical rules. There is no central EU contact point where you register once and it then automatically applies to all Member States.
Why each country has its own register
The underlying directive states that whoever places packaging on a market is responsible for financing the collection and recycling of that packaging. How that responsibility is organized is left to the Member States themselves. Germany registers via LUCID and works with producer responsibility organisations by material type. France has its own recognized organizations. The Netherlands operates through Verpact. The registers differ in structure, in the data they request and in when an annual report is expected.
Because each register is managed nationally, data is also not automatically exchanged between countries anywhere. An entry in one system is invisible to the other system. This is not an oversight, but a direct consequence of the choice to place the implementation with the Member States.
What this concretely means if you sell in multiple countries
For an online shop that ships products to customers in different EU countries, this means that the obligation to register is in principle reassessed for each country. Thresholds, fees and deadlines vary: what falls under an exemption in one country may be subject to reporting requirements in another. The amount of administration also differs; some registers request detailed material data annually, others work with a simpler return.
This does not mean that every sale to a foreign country immediately leads to a full registration obligation. Whether and how the obligation applies depends on the type of packaging, the quantities and the role you play in the supply chain. For a concrete picture of your situation per country, it is useful to first look at role and threshold per country, for example with the role finder that maps your situation per country and packaging type.
The role of a representative
Some countries require companies without a place of establishment in that country to be represented by a local representative. This representative takes on registration and reporting on your behalf. Again, no uniform rule applies here: one country requires a representative above a certain threshold, another country allows foreign companies to register directly under certain conditions. These differences are precisely the reason why an overview per country is needed instead of one general rule.
What is the same everywhere
Despite national differences, every country shares the same starting point: whoever places packaging on the market contributes to the costs of collection and recycling, and the basic obligations regarding packaging design and information on the package stem from the same European regulation. The implementation differs, but the underlying principle does not. This makes it clearer to determine per country what changes and what remains the same; a good starting point for this is the knowledge base with the differences per topic worked out.
For companies operating in multiple countries, it makes sense not to treat registrations separately from each other but to plan them as one coherent whole, including the annual reports that fall at different times per country. How that guidance is structured in detail and where the information comes from is explained on the page that shows how the guidance works per country.
Would you first like to see for yourself in which countries your packaging is subject to registration obligations and which register applies? Do the free quick-scan or browse through the topics in the knowledge base; both can be consulted without an account and provide a first, concrete answer per country.