Netherlands EPR

What is Netherlands EPR Packaging

Extended Producer Responsibility (EPR) in the Netherlands is a regulatory system where producers are held responsible for the management of packaging waste they place on the Dutch market. This framework is governed by the Packaging Management Decree 2014 (Besluit beheer verpakkingen 2014) and is currently transitioning to the EU Packaging and Packaging Waste Regulation (PPWR), which applies directly from August 12, 2026. The goal is to move toward a circular economy by shifting the costs of collection and recycling from municipalities to the businesses responsible for the packaging.

Does this apply to e-commerce & online sales

Yes, EPR obligations apply to all forms of distance selling. Foreign online retailers and marketplaces that ship packaged goods directly to Dutch end-consumers (B2C) are legally considered producers. This includes responsibility for both the product packaging and any shipping materials (boxes, mailers, tape) used to deliver the goods. Under the PPWR 2026 rules, fulfillment service providers and marketplaces are now "gatekeepers" and must verify that their sellers are registered and compliant.

Who is the “producer” under Netherlands EPR?

A "producer" or "importer" is any entity that first places packaged products on the Dutch market. This includes:

1. Manufacturers based in the Netherlands.

2. Importers who bring packaged goods into the Netherlands.

3. Foreign online suppliers selling directly to end-users in the Netherlands without a local importer.

4. Brand owners who have goods packaged under their own name.

Who must register for EPR packaging in Netherlands

Producers must register with the national monitoring body and join a collective scheme to fulfill their recycling targets. In the Netherlands, this is managed through Verpact (formerly Afvalfonds Verpakkingen). Verpact acts as the central Producer Responsibility Organization (PRO). Companies must also submit data to the Human Environment and Transport Inspectorate (ILT) if they exceed certain volume limits.

Netherlands EPR Packaging Registration Threshold

The Netherlands has a split threshold system. For standard packaging, there is a reporting and payment threshold of 50,000 kg per year. If you place less than 50,000 kg on the market, you are exempt from paying the waste management fee and submitting an annual declaration to Verpact. However, there is no threshold (0 kg) for packaging subject to the Single-Use Plastics (SUP) directive or for items in the Deposit Return System (Statiegeld). Starting August 12, 2026, under the PPWR, all foreign sellers must be registered regardless of volume.

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Packaging Covered (and Excluded)

The EPR system covers:

• Sales packaging (primary).

• Grouped packaging (secondary).

• Transport packaging (tertiary).

Materials include plastic, paper/cardboard, glass, metal, and wood. From August 12, 2026, new rules strictly limit "empty space" in shipping boxes to a maximum of 50%, and certain substances like PFAS in food-contact packaging are banned.

Producer Responsibility Organization (PRO)

Verpact is the primary PRO in the Netherlands. It coordinates the collection and recycling system on behalf of all registered producers. Producers pay a "Packaging Waste Management Fee" (Afvalbeheersbijdrage) to Verpact, which is used to fund the national waste infrastructure.

EPR Registration in Netherlands

The registration process involves:

1. Creating an account on the Verpact portal.

2. Determining if your packaging falls under the 50,000 kg threshold or the SUP/Deposit rules.

3. Providing company information and VAT details.

4. Appointing an Authorized Representative if you are a foreign seller (mandatory from August 2026).

Authorized Representative

For foreign companies (non-residents) selling into the Netherlands, the PPWR makes it mandatory to appoint a local Authorized Representative (AR) by August 12, 2026. The AR must be based in the Netherlands and is legally responsible for the producer's registration, reporting, and payment of eco-fees.

What Data Must Be Reported

Producers exceeding the threshold or selling SUP items must report:

• Total weight in kilograms by material type.

• Number of units (specifically for SUP and Deposit items).

• Recyclability classification (used for eco-modulation).

• PPWR 2026 requires highly granular data, including the percentage of recycled content in plastic packaging.

First Reporting Period & EPR Reporting Deadlines

• Annual Declaration (Verpact): Must be submitted by April 1st for the previous calendar year.

• ILT Report: Large producers (over 50,000 kg) must also submit a report to the Human Environment and Transport Inspectorate (ILT) by July 31st.

• SUP Reporting: Quarterly or annual deadlines apply depending on the specific product category.

Labels & Marketing Claims

The Netherlands uses a well-established Deposit Return System (Statiegeld) for PET bottles and cans, which require a specific deposit logo. From August 12, 2026, all packaging must comply with EU-harmonized sorting labels. Use of the "Green Dot" is not mandatory but is common for companies operating across multiple EU markets.

EPR Eco Fees & Eco-Modulation

Fees are based on the weight and type of material. The Netherlands uses a "Bonus/Penalty" system (Eco-modulation). Packaging that is "highly recyclable" (e.g., rigid mono-material plastics) receives a discount, while packaging that is difficult to recycle (e.g., multi-layer laminates) faces significant surcharges.

Risks, Penalties & Common Mistakes

• Fines: The ILT can impose penalty payments of €5,000 per week, up to a maximum of €100,000.

• Sales Bans: Non-compliant businesses can face immediate sales bans.

• Common Mistakes: Forgetting that the 50,000 kg threshold does not apply to SUP items and failing to account for shipping boxes used in e-commerce.

What E-Commerce Sellers Should Do Now

1. Check if your total packaging weight in the Netherlands exceeds 50,000 kg.

2. Register with Verpact immediately if you sell SUP items (e.g., plastic-lined coffee cups or food containers).

3. Appoint an Authorized Representative in the Netherlands to prepare for the August 2026 deadline.

4. Audit your shipping boxes to ensure they meet the 50% maximum empty space rule.

Detailed EPR Guidance for each Jurisdiction

We support 36 jurisdictions

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FAQ

• Currently, you only need to register and report if you exceed 50,000 kg OR sell SUP/deposit items. However, from August 2026, registration will be mandatory for all.

• Single-Use Plastics (e.g., certain food containers, packets, and wraps). These have zero thresholds.

• No, VAT registration is separate from EPR. You must register with Verpact and the ILT separately.

• Fees are invoiced by Verpact based on your submitted annual declaration.

• It is the Dutch deposit system for cans and bottles; sellers must ensure these carry the correct logo and pay the deposit.