PPWR ObligationsEU Reg. 2025/40

Who must register for packaging EPR in the Netherlands, and how

Register: Verpact Authorised Rep: Only if you sell direct to end users Load: Low to moderate

Producers report to and register with Verpact (formerly Afvalfonds Verpakkingen) under the Besluit beheer verpakkingen 2014, declaring the packaging they place on the Dutch market and paying the per-material waste-management contribution. The de-minimis is 50,000 kg (50 tonnes) per calendar year, but single-use-plastic and deposit-return packaging have no threshold. No Dutch rule requires an Authorised Representative: you need one only under Art. 45(3) of Regulation (EU) 2025/40, which applies when you supply Dutch end users directly without being established in the Netherlands.

Checked against the Besluit beheer verpakkingen 2014 on 29 September 2026. This is general information about Regulation (EU) 2025/40 and the Dutch national EPR scheme, not legal advice. Thresholds, fees, penalty amounts and go-live dates come from national law and PRO schedules that change: treat every figure as needing a fresh check, and confirm anything you act on with the national authority or qualified counsel.

Packaging EPR in the Netherlands at a glance
Register / authorityVerpact (formerly Afvalfonds Verpakkingen); the ILT supervises
PRO / compliance schemeVerpact
Authorised RepresentativeOnly if you sell direct to end users (Art. 45(3))  No Dutch mandate located; a foreign distance seller to Dutch consumers is itself the producer and deals with Verpact directly
De-minimis threshold50,000 kg (50 tonnes) per calendar year (Arts. 8 and 9); no threshold for single-use-plastic and deposit-return packaging
National instrumentBesluit beheer verpakkingen 2014

The register and what it involves

The rules sit in the Besluit beheer verpakkingen 2014. Producers and importers report to and register with Verpact, the single national producer organisation, formerly Afvalfonds Verpakkingen (the same body under a new name). You declare the weight of packaging placed on the Dutch market, by material, and pay the per-material waste-management contribution. The Human Environment and Transport Inspectorate (ILT) is the supervisory authority.

De-minimis: 50 tonnes, with a critical exception

The de-minimis is 50,000 kg (50 tonnes) per calendar year (Arts. 8 and 9 of the decree). Below it you pay no waste-management contribution and file no annual declaration. The exception: packaging that falls under the single-use plastics rules or the deposit-return system (statiegeld) has no threshold, so one item triggers a declaration and a contribution. A small seller of single-use-plastic or deposit packaging gets no benefit from the 50-tonne relief.

The Authorised Representative rule

Dutch law adds no Authorised Representative requirement of its own. A foreign business that sells packaged products by distance contract straight to Dutch consumers is itself the producer or importer under Art. 1(g) of the decree, so it registers and declares with Verpact directly, for both the product packaging and the shipping materials it sends.

The requirement that does apply is EU law. Since 12 August 2026, Art. 45(3) of Regulation (EU) 2025/40 requires a producer that supplies end users in the Netherlands directly, without being established there, to appoint an Authorised Representative for EPR in the Netherlands. That includes sellers based in other EU countries. If you supply Dutch retailers or distributors who pass your goods on unchanged, you are not the producer in the Netherlands and Art. 45(3) does not reach you. A proposal to suspend the rule until 2035 stalled when the Council ended negotiations on it in April 2026 and left it out of its 24 June 2026 mandate, so it applies now.

Reporting and penalties

Producers above the 50-tonne threshold also submit a report through Verpact before 1 August each year on their measures to prevent and recycle packaging. Enforcement is by the ILT; a compliance consultancy reports penalty payments of around €5,000 a week up to a €100,000 cap, plus possible sales bans (not verified against the enforcement framework). Per-material contribution rates change yearly, so confirm the current rate card with Verpact.

How onerous is it?

Low to moderate for small players. The 50-tonne threshold takes most small importers out of fees and declarations, but single-use-plastic and deposit packaging count from the first item, and a seller shipping straight to Dutch end users from abroad needs an Authorised Representative under Art. 45(3).

Get the Netherlands mapped alongside every other market you sell into

The report takes your packaging profile and returns the obligations that apply to you under Regulation (EU) 2025/40, the EU-wide product duties plus the per-country EPR registration, PRO and Authorised-Representative steps, with the deadline for each.

Get my full PPWR obligations report →

Frequently asked questions

If I place under 50 tonnes on the Dutch market, am I exempt?

From the waste-management contribution and the annual declaration, yes: the de-minimis is 50,000 kg per calendar year. Single-use-plastic and deposit-return (statiegeld) packaging are the exception. They have no threshold, so one item triggers a declaration and a contribution regardless of the 50-tonne relief.

I sell online to Dutch consumers from abroad. Who reports the packaging?

You do. A foreign seller that sells packaged products by distance contract straight to Dutch consumers is itself the producer under Art. 1(g) of the Besluit beheer verpakkingen 2014 and deals with Verpact directly. Because you supply Dutch end users without being established in the Netherlands, Art. 45(3) of Regulation (EU) 2025/40 also requires you to appoint an Authorised Representative there.

When is the Dutch annual packaging report due?

If you are above the 50,000 kg threshold, the report on your measures to prevent and recycle packaging goes through Verpact before 1 August each year. Verpact sets the timetable for the weight declaration and the contribution, so check its current dates.

Sources

Related countries