Dutch packaging EPR: Verpact, fees and your annual cycle

The Dutch packaging EPR system and the legal basis

Extended Producer Responsibility (EPR) in the Netherlands establishes that businesses putting packaged products on the Dutch market must finance the collection, sorting, and recycling of that packaging waste. The statutory framework rests on the 2014 Packaging Management Decree (Besluit beheer verpakkingen 2014)^[1]. Per the Human Environment and Transport Inspectorate (ILT), producers usually work together as one organisation to meet EPR requirements, referred to in the Netherlands as a producentenorganisatie (Producer Responsibility Organisation, PRO), and if almost all producers of that product are voluntary members, the Minister for Infrastructure and Water Management can decide that each producer must have their EPR duties carried out by that organisation, which is then laid down in an Algemeen Verbindend Verklaring (Generally Binding Agreement)^[2]. For packaging, that organisation is Verpact, which according to business.gov.nl plays a central role in the collection and recycling of packaging in the Netherlands^[3]. Producers or importers who place EPR-covered products on the Dutch market must inform Rijkswaterstaat every year about the quantity of products they have sold and how much waste they have collected, and ILT oversees compliance with the EPR regulations^[2].

Who qualifies as a producer under Dutch law

Under the Dutch packaging decree, a producer or importer is defined by specific commercial actions within the supply chain rather than company size alone. If your business introduces packaged physical goods to Dutch end users, you carry regulatory responsibility for those materials.

• Manufacturers and brand owners who produce goods in the Netherlands and package them under their own label.
• Importers who purchase packaged goods from abroad and introduce them onto the Dutch domestic market.
• Traders and webshops that add primary, secondary, or shipping packaging to products destined for Dutch consumers or end users.
• Entities that provide single-use takeaway food or beverage packaging at the point of sale.

Because the Dutch Ministry of Infrastructure and Water Management declared the packaging waste management contribution agreement generally binding (algemeenverbindendverklaring) for the period 2023 to 2027, joining the collective scheme managed by Verpact is the standard route to meet statutory EPR requirements^[4].

The fee system: material rates and tariff differentiation

Verpact funds collective collection and recycling operations through the Packaging Waste Management Contribution (Afvalbeheersbijdrage Verpakkingen). Every affiliated business paying into the system is charged according to the net weight and specific material composition of the packaging placed on the market. Rates reflect the actual net costs of collection, sorting, and reprocessing for each material fraction, and Verpact publishes them per material for each year^[5].

Plastic fee differentiation and recyclability incentives

Since 2024, Verpact has distinguished between rigid and flexible plastic packaging in both reporting and fees. To incentivise sustainable design, Verpact applies the Plastic Fee Differentiation scheme, which rewards easily recyclable plastic packaging and the use of recyclate. For 2026, Verpact keeps the discount levels of 2025 and states that the total discount can amount to as much as EUR 0.60 per kilogram^[5].

Businesses that structure their packaging choices around monomaterials, light colours, and easily separable labels lower their net annual obligations. To forecast material-specific costs accurately, you can calculate your packaging fee based on published Verpact schedules.

Your annual cycle: register, record, declare and pay

Complying with Dutch packaging EPR follows an annual administrative schedule. The compliance workflow requires continuous record-keeping alongside structured declaration milestones.

• Continuous packaging recording: Maintain an ongoing audit trail of all packaging weights, item counts, and material fractions introduced onto the Dutch market during the calendar year.
• Provisional statement (opgaaf): Once you have your login credentials, you submit an estimate of the kilograms for the current declaration year, which is what Verpact invoices you on during the year^[11].
• Definitive declaration (aangifte): In the year following your notification, you file the definitive declaration for the previous calendar year by 1 April, broken down by material, replacing the estimate with the actual kilograms placed on the market^[11].
• Invoice settlement and reconciliation: Verpact reconciles the advance payments against the declared volumes and issues a final bill after the summer, then a new notification for the current calendar year^[11]. Requests for an indirect export refund over the previous declaration year run until 1 June^[11].

The standard 50,000 kg exemption and cross-border boundaries

Under the Dutch Packaging Management Decree, a baseline threshold of 50,000 kg of packaging material per calendar year applies. Companies putting less than 50,000 kg of standard packaging onto the Dutch market in a calendar year are currently exempt from paying the variable waste management contribution to Verpact^[6]. However, businesses must maintain verifiable administrative records to prove that their annual volumes remain below this threshold if requested by authorities.

Two mechanics behind that number decide what it costs you. The threshold is a total limit across all packaging materials together, not a limit per material, and crossing it does not make the whole tonnage payable: Verpact reduces the invoice basis by 50,000 kg pro rata to the weight of the materials you declared, so the threshold behaves as an allowance rather than a cliff^[10].

This threshold applies strictly to domestic distribution in the Netherlands. If your webshop also sells cross-border into Germany, the Dutch 50,000 kg exemption does not apply there: German packaging law (since 12 August 2026 the PPWR together with the VerpackDG, which replaced the Verpackungsgesetz) requires registration in the LUCID register and system participation from the very first sales package sent to German private consumers. Since 12 August 2026 a second duty applies on top of the German one: Article 45(3) of the PPWR requires a written mandate appointing an authorised representative for extended producer responsibility in every member state where you make packaging available for the first time and are not established^[13]. The Commission proposed suspending that obligation until 1 January 2035 for producers already established in the EU on 10 December 2025, but the Council discontinued negotiations on the file on 24 June 2026^[14], so it stands. Other regimes such as electrical equipment or batteries follow separate, independent compliance tracks.

What this means for your webshop today

For an e-commerce business operating in the Netherlands, packaging compliance involves more than the retail boxes holding individual products. All outbound shipping packaging, including corrugated outer cartons, paper tape, bubble envelopes, plastic strapping, and void fill, constitutes packaging under statutory definitions and must be tracked.

Exceptions where duties apply from the first unit

The standard 50,000 kg threshold does not grant blanket exemption to every product category. Dutch law enforces immediate registration and declaration duties from the very first unit placed on the market for specific packaging types.

• Single-Use Plastics (SUP): Verpact states there is no threshold for SUP packaging and deposit packaging when filing declarations^[7], and that unlike other packaging, even producers and importers introducing just a single unit of SUP packaging to the market are subject to the legislation, including the charge covering litter clean-up costs that started in 2023^[8].
• Deposit-bearing packaging (Statiegeld): since 1 April 2023 returnable cans, just like returnable plastic bottles, must be registered separately, with the quantities as well as the kilograms of each type of material recorded^[8], and because Verpact applies no declaration threshold to deposit packaging, the duties start from unit one^[7].
• Standard packaging above 50,000 kg: Verpact applies a threshold of 50,000 kg to other taxable packaging and notes that logistics resources do not count towards determining the threshold weight^[7], so a business exceeding it across all combined materials must register, file the definitive annual declaration by 1 April, and pay the corresponding material tariffs.

Even when standard packaging volumes remain under 50,000 kg, webshops must track material weights to verify that they do not inadvertently cross reporting thresholds as sales expand.

Outlook: how the rules develop from here

European packaging law is undergoing structural harmonisation. The Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) entered into force on 11 February 2025 and applies generally from 12 August 2026^[9]. Per business.gov.nl, the first PPWR obligations took effect in the Netherlands on 12 August 2026 and include, among others: packaging manufacturers must have completed a conformity assessment and draft a conformity statement; manufacturers must draw up and keep a packaging dossier with information on material, weight and environmental impact; manufacturers must comply with the maximum levels for PFAS in packaging; and businesses must determine their role or roles in the packaging chain, since which obligations apply depends on that role and the type of packaging. Not all rules have been finalised yet: business.gov.nl notes that the European Union will continue to work out the PPWR over the coming years, so further rules will be introduced up to and including 2029^[3].

Expected timeline for the national producer register

Under the PPWR, all EU member states must maintain a formal producer register. Per Verpact, the transition to the national producer register in the Netherlands is expected from 12 August 2027 at the earliest, with 2028 as the first reporting year, to be declared before 1 June 2029^[12]. These milestone dates reflect Verpact operational guidance and remain subject to the formal enactment of Dutch statutory instruments and EU secondary implementing legislation.

Verpact expects the declaration threshold to disappear when that register takes effect, with a simplified declaration for companies placing less than 10,000 kg of packaging on the Dutch market per year, who would report only the weight of the materials used^[12]. Read that as the scheme operator's expectation, not as settled law: no Dutch implementing instrument has fixed the date, the contribution amounts, or the calculation methodology for small-volume producers.

In the meantime one allocation question is openly unresolved. Verpact pressed the pause button on 22 July 2026 for shipping, service and primary production packaging, because it is not settled whether the producer of those is the manufacturer or the party that adds them, and the outcome may apply retroactively from 12 August 2026. Verpact asks companies to keep working on the basis of the situation as it stood before 12 August 2026 while the definitions and the allocation of duties are clarified at EU level^[15].

Evaluating your compliance obligations

Which exact packaging obligations apply to your company depends on your specific role in the supply chain, whether you source generic packaging within the EU, import finished goods, or design custom branded containers. These operational distinctions cannot reliably be resolved through a general checklist alone.

To establish your current regulatory standing and ensure dependable compliance as European rules evolve, you can carry out a Digital needs analysis. Our team evaluates your commercial setup, maps your obligations across target markets, and supports your ongoing reporting requirements.

Frequently asked questions

Which scheme applies to what I sell?

In the Netherlands, if you place packaged products on the market, you must comply with packaging EPR through Verpact. If your products include electronics or batteries, you also face separate obligations under the WEEE and battery regimes.

Who counts as the producer in my setup?

Under the 2014 Packaging Management Decree, the producer is the entity established in the Netherlands that first places the packaged product on the market. This includes manufacturing, importing, or adding takeaway packaging like carrier bags.

Where do I start if none of this has been arranged yet?

Begin by determining your total annual packaging weight and materials. If you exceed 50,000 kg or sell single-use plastic or deposit packaging, you must register with Verpact, keep weight records, and file the definitive annual declaration by 1 April.

How do the 2026 Verpact rates differ by material?

Materials that are harder to recycle cost more. For example, the 2026 rate for paper and cardboard is EUR 0.017 per kg, while rigid plastic rates are higher. Using highly recyclable plastic can earn a discount of up to EUR 0.60 per kg.

Does the 50,000 kg threshold disappear under the new PPWR?

The 50,000 kg threshold remains in force today. Per Verpact, it is expected to lapse only when the PPWR producer register takes effect, which is anticipated from 12 August 2027 at the earliest.

What happens if I sell to German consumers from my Dutch webshop?

Dutch Verpact registration does not cover your German sales. For cross-border sales into Germany, you are subject to German packaging law, since 12 August 2026 the PPWR together with the VerpackDG, requiring a separate LUCID registration and dual-system licensing from the first gram of packaging.