Last update from 23.10.2023
The German packaging register LUCID is already well known. Since 2019, all companies that place packaged goods on the market must register with LUCID. It is not so well known, however, that many other countries across the EU have their own packaging register as well.
Companies risk high fines and penalties if they do not enroll in the packaging register. This goes for Germany as well as for other countries. The obligation is particularly relevant for e-commerce firms that ship cross-border to end consumers in multiple markets. Not only must foreign companies be registered with LUCID if they ship to Germany; German companies must register abroad in their destination countries, too. In this article, we have ranked the 5 most important packaging register abroad and show what you need to take care of in each country.
The 5 most important packaging register besides Germany
1. The BDO Register in Poland
Just like in Germany, all companies that sell packaged goods to end consumers in Poland must be registered with a central agency. The central agency in Poland is not LUCID, but BDO.
You can find the packaging register in Poland here: https://bdo.mos.gov.pl/
Since the sign-up process is only available in Polish, it is quite difficult for foreign companies. Yet, any foreign e-commerce retailer selling to Polish consumers must be registered.
In order to register a foreign firm, you first need to obtain a PESEL-number. You can then log into the official Polish government website to request entry in the BDO register. Since the whole process is very difficult if you do not speak Polish, we provide contacts of recycling schemes in Poland which can offer support in English as part of our digital consulting service. Any obligated company must also license their packaging with a recycling scheme in Poland anyway (on top of being enrolled in the BDO register). Thus, you will save time and money doing it this way.
After registration in the BDO is completed, your company will receive a unique BDO-number. This number must be printed on any official documents for sales to Poland. Take care to add the BDO-number to your invoice template (e.g. next to the VAT number) for all invoices to Polish customers, since otherwise your company may be sanctioned.
According to the packaging law in Poland, sanctions for not registering in BDO and for not displaying the BDO-number can be up to 220,000 EUR or even imprisonment. In general, Poland is one of the strictest countries of the EU, besides Germany, when it comes to their packaging waste laws.
The BDO register entry costs an annual fee of approximately 20 EUR for small and 70 EUR for larger companies.
2. The national producer register in Lithuania
Not every company needs a packaging license in Lithuania, since there are minimum thresholds and exceptions for small businesses. However, all companies are obligated to enter the packaging register of Lithuania.
This includes foreign e-commerce sellers that ship cross-border to Lithuanian end-consumers. Obligations arise from the first delivery.
The PPWIS producer register is accessible in English under the following link: https://www.gpais.eu/en
Because many of the help-articles and FAQ on PPWIS are not available in English, we provide to our customers a step-by-step manual for the registration and data declaration processes. If you license your packaging with a recycling scheme in Lithuania, you can also get English support there.
3. The register of the environmental agency of Greece
Although all companies selling to Greek consumers are obligated to join the Greek packaging register, the state makes it very hard for foreign businesses to do so. All manuals and the website itself are only available in Greek. And what is more important, a Greek entity or an authorized representative is required for foreign companies to register.
Such representatives can be, for instance, a Greek tax accountant. This is especially convenient for larger e-commerce businesses which must file for VAT in Greece and already work with a local tax accountant. However, for small shops which sell low quantities to Greece, registration in the Greek packaging register is not economical. Their only way is to stop selling to Greece, or to take the risk and ignore their legal obligations. This risk is definitely lower than in Germany or Poland, because Greek authorities do not have a record of sanctioning small businesses for packaging law offences. But this may change with the current fight on plastics, increased pressure from EU recycling rates, and the EU market surveillance regulation.
Registration in the Greek waste register EMPA can be requested here: https://empa.eoan.gr/register.php
Other than the other countries, the packaging register in Greece is not publicly visible for competitors.
4. Waste register of the Slovak Republic
In Slovakia, every company that sells across the border direct to consumers must be registered in the national waste register and provide annual declarations of their packaging waste data.
Registration and declaration processes are only partly digitized. A form must be filled and sent by e-mail or post to the environmental agency. Our services include English manuals on how to do so. Perhaps due to the high complexity and the language barrier, not many foreign companies fulfill their obligations for registration as of now.
You can find the Slovak packaging register here: https://obaly.sazp.sk/index.php
5. Packaging register of the United Kingdom
Finally, some good news: Most (foreign) e-commerce businesses are currently not required to join the national packaging register of the UK. Obligations only arise for companies with an annual sales turnover of 1 million GBP and 25 tons of packaging waste. In addition to this every company needs a branch office in the UK.
The UK packaging register as well as the waste registers for batteries and WEEE is accessible here: https://npwd.environment-agency.gov.uk/
High complexity for international commerce
The different packaging registers and regulations of each country make packaging recycling compliance in Europe so complex. Due to the EU packaging waste directive, all EU member states have enacted packaging and recycling regulations differently in their national law. If you sell cross-border, you need to analyze your compliance obligations for each target destination. With our digital compliance consulting service, you can analyze your individual needs at any time. Contact us if you’d like to know more or read our comprehensive FAQs.