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Situation

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. Two cover selling packaged goods at home. Two cover sending packaged goods straight to customers in another EU country. 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

    The two about sending goods to customers in another country decide whether a representative is needed there. The fifth, about unpacking, is the one most often missed.