A shop using plain unbranded packaging that only sells in its own country

The situation

A business sends orders in plain boxes with nothing of its own printed on them, and sells only to customers in the country it is based in.

What appears to apply

• When a business counts as a producer, and in which country

  Applies now

  Producer is the word the rules use for whoever first puts packaging onto a country's market. It is worked out country by country, so one business can be a producer in several countries at once. There are five ways to become one, and the first four split by what is being made available rather than only by where. Two cover a business in its own country. One is for packaging on its own: the outer boxes and wrapping goods travel in, the cups and bags filled at a counter, the packaging used in farming and fishing. The other is for goods inside any other packaging. Two more cover the same pair sent to another EU country, but only where the goods go directly to the people who will use them. The fifth catches a business that unpacks goods without being the one who uses them, unless somebody earlier in the chain already counts as the producer.

  Source: Regulation (EU) 2025/40, Art. 3(1), point (15) — read from this source on 13 August 2026

  The two about another country decide whether a representative is needed there, and both turn on selling directly to end users — sending a pallet to a wholesaler abroad is not the same thing. The fifth, about unpacking, is the one most often missed.