Yes - B2B webshops must register their packaging too

Yes. If you operate a B2B webshop in the Netherlands and supply packaged goods to business customers, your packaging falls under Dutch Extended Producer Responsibility (EPR) rules. As a manufacturer or importer of packaging or packed products you are responsible for managing that packaging until the waste phase, and the official list of packaging types explicitly includes company packaging (bedrijfsverpakkingen), the packaging used by companies and disposed of in company waste[1]. Verpact likewise makes no distinction between packaging that ends up with a consumer and packaging removed by a waste collector at a business.

Dutch packaging duties follow from the 2014 Packaging Management Decree (Besluit beheer verpakkingen 2014)[1]. Producers and importers that bring more than 50,000 kilograms of packaging onto the Dutch market in a calendar year, or remove that quantity after importing goods, must register with producer organisation Verpact, report the weight and quantity of that packaging every year, and pay the packaging waste management fee[2]. Even if your annual volume remains below the 50,000 kg threshold, you remain legally responsible for your packaging and must be able to show the weight and the materials it is made of[1].

Two details decide what that threshold means for a B2B seller. It is a total limit across all packaging materials together, not a limit per material, and crossing it is not a cliff: Verpact reduces the invoice basis by 50,000 kg pro rata to the weight of the materials you declared[3]. Deposit-bearing packaging and packaging under the single-use plastics rules sit outside that arithmetic entirely, because Verpact applies no declaration threshold to them at all[4].

What if your business situation is slightly different, or you combine webshop sales with imports and direct shipments? To determine your exact compliance scope across products and sales channels, you can start the digital needs analysis to clarify which requirements apply to your setup.

  • B2B and B2C transactions carry the same fundamental legal responsibility under Dutch packaging decree rules.
  • The 50,000 kg per calendar year threshold determines the packaging waste management fee owed to Verpact[2], while the duty to show the weight and materials of the packaging you bring onto the Dutch market applies from the start[1].
  • All packaging types used in commercial fulfillment, from primary item wrappers to shipping cartons and pallet wrap, count toward your total volume.

Why B2B is in scope

A widespread misunderstanding among commercial suppliers is that packaging EPR applies exclusively to consumer goods. In the Netherlands, statutory packaging responsibility follows from the 2014 Packaging Management Decree and rests on the manufacturer or importer of packaging or packed products, who must manage that packaging until the waste phase[1]. Packaging used by companies and disposed of in company waste is named as a packaging type in its own right, so commercial deliveries to industrial facilities, offices, or trade workshops are covered alongside retail packaging delivered to households[1].

In B2B commerce, packaging generally appears in three distinct layers, all of which fall within the legal definition of packaging:

  • Sales packaging (primary packaging): The individual container, bottle, bag, or box encasing the product at the unit level.
  • Grouped packaging (secondary packaging): Collated bundling such as shrink film, outer cartons, or trays that group multiple sales units together for wholesale ordering.
  • Transport packaging (tertiary packaging): The shipping packaging, corrugated boxes, strapping, edge protectors, and stretch foil used to protect goods during dispatch and freight transport.

When a Dutch B2B webshop packs an order and dispatches it to a corporate client in the Netherlands, the business acts as the producer of that added transport packaging and must account for every material component in its annual reporting.

One caveat before you conclude that the outer boxes are always yours. Verpact pressed the pause button on 22 July 2026 for exactly this question, for shipping, service and primary production packaging: whether the producer of those is the manufacturer or the party that adds them has not been settled, and the outcome may apply retroactively from 12 August 2026[7]. The pause covers who reports the Dutch kilograms for those three packaging types. It suspends neither the product rules for the packaging itself nor anything outside those three types, and Verpact asks companies to keep working on the basis of the situation as it stood before 12 August 2026 in the meantime[7].

Edge cases in B2B: pallets, reusable crates and exporting customers

Commercial shipping relies heavily on logistics aids, returnable assets, and complex delivery chains. Verpact publishes separate declaration rules for reusable packaging and applies a different, lower plastic rate to indirect exports, so these flows are not reported like ordinary single-use material. Single-use logistics resources such as pallets and glass trolleys are a packaging type in their own right and must be registered with Verpact precisely because they are meant for single use[1]. Note the asymmetry that catches most B2B sellers out: logistics resources do not count towards the threshold weight, and they carry a declaration obligation with no levy attached to them[4]. The corrugated outer box and the stretch film around the same pallet are ordinary transport packaging: they do count, and they are charged at the rate for their material.

Reusable packaging, such as heavy-duty plastic return crates or pooling containers, is packaging that is returned after being brought on the market, inspected, possibly cleaned, and refilled, and it must be designed to last more than one cycle within a demonstrable return system. Verpact asks for two figures: the weight of the packaging used for the first time, broken down by material, and the total weight of all reusable packaging in circulation during the year[4]. Only the first of those is charged, at a system fee that Verpact lists at EUR 0.015 per kilogram for 2024, 2025 and 2026; reusable drinking cups are the exception, at EUR 0.280 per kilogram[5].

Packaging CategoryOperational ExampleDeclaration StatusVerpact Fee Status
Single-use transport packagingCardboard outer boxes, stretch film, strapping, edge protectorsMandatory annual weight declaration; counts towards the 50,000 kg thresholdCharged at the standard rate for each material type
Single-use logistics resourcesOne-way wooden pallets, glass trolleysDeclaration obligation, but does not count towards the threshold weight[4]No levy is attached to them[4]
Reusable packaging (first use)Standardised returnable plastic containers, reusable bins added to poolDeclare the kilograms used for the first time in a year, per materialSystem fee only, EUR 0.015 per kg[5]
Reusable packaging (total circulation)Subsequent refill cycles within a closed loopDeclare the total weight in circulation each yearNo rate is linked to this declaration
Indirect exportPackaged goods sold to Dutch B2B buyers who export them onwardClaimed by the party that exports, until 1 June for the previous declaration year[6]Refund of the contribution paid earlier in the chain; a lower plastic rate of EUR 0.87 per kg applies[5]

Another frequent B2B scenario involves indirect exports. If you sell packaged products to a Dutch business customer who subsequently exports those goods abroad without unpacking them, the packaging does not end up in the Dutch waste stream. Where the waste management contribution was already paid earlier in the chain, a refund for indirect export can be requested[2]. Read carefully who claims it: the refund belongs to the party that actually exports the goods, so in this scenario it is your customer who files it with Verpact, not you[6].

Your role is to make your customer's claim possible. Verpact requires the exporting party to record the supplier's name, address details and Chamber of Commerce number, with the weights per material type per supplier, and the supplier must be registered with Verpact; requests run annually until 1 June for the previous calendar year[6]. Verpact also applies a separate, lower plastic rate of EUR 0.87 per kilogram to indirect export volumes, while the other material rates stay the same[5], so keeping verifiable export documentation with your customer is what makes the correction defensible.

What to do next as a B2B seller

Ensuring compliance for a B2B webshop requires a structured review of your packaging inventory and reporting workflows. Taking concrete inventory now prevents reporting bottlenecks during annual declarations.

  • Map your packaging inventory: Record the precise tare weight and material composition (cardboard, flexible plastic, rigid plastic, wood, metal) for every shipping carton, filler material, and pallet type used in your warehouse.
  • Classify materials via official guidance: Check borderline items in Verpact's packaging catalogue, which tells you whether your product counts as packaging and whether a packaging waste management fee is due[1].
  • Track annual volume thresholds: Calculate your total aggregate packaging weight across all sales channels for the calendar year to determine whether your business crosses the 50,000 kg contribution threshold.
  • Complete your producer registration: If your volumes require mandatory reporting, carry out your Verpact registration and submit the required annual data through the portal before the statutory deadlines.

Maintaining structured records of supplier invoices, technical specifications, and shipping logs ensures that your packaging data remains verifiable in case of inspections by the Human Environment and Transport Inspectorate (ILT).

Outlook: how the rules develop from here

Packaging regulations across Europe are undergoing substantial revision. At the European level, the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force on 11 February 2025 and has applied since 12 August 2026[8]. The regulation introduces harmonised packaging design criteria, stricter packaging minimisation rules, and mandatory technical documentation.

One PPWR duty already binds a B2B seller that ships outside the Netherlands. Article 45(3) requires a written mandate appointing an authorised representative for extended producer responsibility in every member state where you make packaging or packaged products available for the first time and are not established[8]. Do not plan around the relief that was proposed: on 10 December 2025 the European Commission proposed suspending Article 45(3) until 1 January 2035 for producers already established in the EU, and the Council discontinued negotiations on that file on 24 June 2026[9]. Until something replaces it, the obligation stands.

At the national level, the exact operational transposition of future EU requirements into Dutch legal instruments, including the necessary amendments to the Besluit beheer verpakkingen, remains an evolving process. Verpact expects the national producer register from 12 August 2027 at the earliest, with 2028 as the first reporting year, to be declared before 1 June 2029; it also expects the declaration threshold to disappear at that point, with a simplified declaration for companies placing less than 10,000 kg on the Dutch market[10]. That is Verpact's operational expectation, not a published Dutch instrument, and the practical implementation details for specific B2B transport systems and registration mechanisms are not settled in any administrative decree. Because regulatory details continue to evolve, establishing transparency over your current packaging flows is the most effective way to prepare.

Which EPR obligations apply to your webshop depends on your exact role in the packaging chain. A business purchasing standard unbranded cartons from an EU distributor operates under different legal conditions than a company importing packaged components or having custom boxes manufactured under its own brand. These distinctions cannot reliably be resolved through a general checklist alone. To understand your compliance position today and be on the safe side, start the EPR needs analysis now. Afterwards, our experts support you in implementing the requirements and keep you covered as the rules develop.

Frequently asked questions

Do B2B webshops need to register packaging in the Netherlands?
Yes. The 2014 Packaging Management Decree does not distinguish between packaging sent to consumers and packaging sent to businesses. If you place packaging on the Dutch market, it falls under the Extended Producer Responsibility (EPR) rules and must be managed accordingly.
Do I still have to register if I stay under the 50,000 kg limit?
If you bring less than 50,000 kg of packaging onto the market, you generally do not pay the variable waste management contribution to Verpact. However, you are still considered a producer and must comply with basic EPR obligations. Two categories are exempt from the threshold altogether: deposit-bearing packaging and packaging covered by the single-use plastics rules, for which Verpact applies no declaration threshold at all, so the duty starts at unit one.
What if my B2B customer exports the goods outside the Netherlands?
If your Dutch B2B customer demonstrably exports the packaged goods, that packaging does not end up in the Dutch waste stream. The refund for indirect export is claimed by the party that exports, so your customer files it, not you. Your part is to be registered with Verpact and to supply the data the claim needs: your name, address and Chamber of Commerce number, and the weights per material type.
How do I report reusable transport packaging like pallets?
Reusable transport packaging, such as durable crates or pallets, remains in a closed loop. You report two figures: the weight used for the first time that year, per material, and the total weight in circulation. Only the first carries a charge, at a system fee of 0.015 EUR per kg for 2024 through 2026.
Can I invoice the Verpact packaging fee to my business customers?
What the rules fix is who is liable, not how you price. The producer established in the Netherlands remains the party that must declare and pay to Verpact, and that responsibility cannot be contracted away. How you reflect the cost in a B2B price or on an invoice is a commercial matter between you and your customer.
Who is responsible for packaging in B2B drop shipments to end users?
In a drop shipment model, the party that legally places the packaging on the Dutch market first is responsible. If you instruct a manufacturer to ship directly to your end user under your name, you often assume the producer role for the shipping packaging. You must verify your exact role in the chain.

Sources

  1. [1]business.gov.nl
  2. [2]business.gov.nl
  3. [3]verpact.nl
  4. [4]verpact.nl
  5. [5]verpact.nl
  6. [6]verpact.nl
  7. [7]verpact.nl
  8. [8]eur-lex.europa.eu
  9. [9]eur-lex.europa.eu
  10. [10]verpact.nl