Does a micro-volume webshop need to register with Verpact in 2026?

No, if you bring less than 50,000 kilograms of packaging onto the Dutch market in a calendar year, the exemption in the Besluit beheer verpakkingen still applies today. Registration for smaller volumes is expected to begin when the PPWR producer register launches, which Verpact says must be established from 12 August 2027.

Are marketplace-only sellers exempt from the new packaging rules?

No, the PPWR applies to anyone who places packaged products on the market, including those selling exclusively via marketplaces. The 50,000 kg threshold still exempts small sellers from reporting volumes today, but the size-independent PPWR obligations apply from 12 August 2026.

What happens on 12 August 2026 for small webshops?

Regulation (EU) 2025/40 officially applies from this date. While volume registration for small webshops waits for the producer register, you must comply with size-independent duties like proving conformity and the PFAS restrictions for food-contact packaging immediately.

What are the expected costs when the producer register launches?

Future contribution duties are set to reach below today's 50,000 kg threshold once the PPWR register and reporting apply, but the exact amounts and calculation methods are not yet determined. Current tariffs cannot be projected onto future duties.

What happens if I do nothing before the PPWR application date?

If you fail to meet the immediate size-independent requirements on 12 August 2026, such as keeping basic packaging records and ensuring conformity, you will be non-compliant. To be on the safe side, evaluate your exact role in the supply chain now.

Do small webshops need to register their packaging in 2026?

Not yet: the 50,000 kg exemption stands

Small webshops operating in the Netherlands do not face immediate packaging registration duties on 12 August 2026 if their annual packaging volume remains below the national threshold. Regulation (EU) 2025/40 applies across member states from 12 August 2026^[1], but national registration exemptions remain governed by Dutch law.

Under the Dutch Besluit beheer verpakkingen 2014, companies placing less than 50,000 kg of packaging on the market per calendar year remain exempt from packaging waste management contributions and mandatory annual weight declarations^[2]. This national threshold continues in force today.

Universal registration for small-volume webshops will only become mandatory when a national producer register is formally established under the new European framework. Per producer organisation Verpact, a producer register must be established from 12 August 2027, with the first reporting year expected to be 2028, to be reported before 1 June 2029^[3]. Crucially, this timeline reflects Verpact's operational expectation rather than a statutory deadline, as no corresponding Dutch national instrument has been published to date.

Regulatory Milestone	Effective Date	Status for Small Webshops (< 50,000 kg)
PPWR Entry into Force	11 February 2025	EU framework adopted; national thresholds remain in force
PPWR Application Date	12 August 2026	Size-independent duties apply; volume exemption holds
National Producer Register	12 August 2027 (per Verpact)	Pending Dutch statutory implementation; registration expected

Businesses can rely on the 50,000 kg exemption today while preparing internally for the transition once national implementing instruments are enacted.

Are you affected? A test for small webshops

To determine whether your webshop is currently subject to volume reporting in the Netherlands, you can apply three practical criteria based on your operational setup today.

Target market: You sell physical packaged products directly to consumers or business customers in the Netherlands.
Packaging role: You place products into primary, secondary, or shipping packaging (such as cardboard boxes, mailers, or protective tape) prior to dispatch.
Annual volume: Your total weight of packaging placed on the Dutch market is strictly under 50,000 kg in the current calendar year^[2].

If all three conditions apply, you fall outside the group that business.gov.nl describes as owing the packaging waste management contribution and the annual reporting duty, namely companies bringing more than 50,000 kilograms of packaging onto the Dutch market in a calendar year^[2]. You are not required to submit weight declarations or pay packaging waste management contributions to Verpact for the 2026 reporting cycle.

To understand your compliance position today and be on the safe side, start the EPR needs assessment now. A structured evaluation helps verify your current status and ensures your packaging documentation is ready before new reporting phases arrive.

What already applies from 12 August 2026

Although volume reporting exemptions hold for small webshops, Regulation (EU) 2025/40 introduces duties that do not depend on packaging volume and that catch anyone who packages, sells, imports or ships products from 12 August 2026^[1]. These requirements apply regardless of annual packaging weight.

Proof of compliance: if you have packaging manufactured or you import it, you must be able to show that it meets the European requirements, and suppliers must hand over the information needed for that^[1].
EU declaration of conformity: the manufacturer must draw up an EU declaration of conformity stating that the packaging complies with the European rules, and resellers should check that it exists^[1].
Substance restrictions: packaging in direct contact with food must not contain harmful PFAS above the set limit, which covers items such as trays, cups and pizza boxes^[1].
Documentation readiness: Webshops must maintain precise records of packaging types, material compositions, and tare weights to substantiate compliance upon request.

Setting up basic packaging records today ensures that your business can satisfy technical verification requirements and seamlessly transition into formal producer registration when required.

What has not changed for small webshops

Alongside new technical obligations, several core operational structures remain untouched for small Dutch webshops until the new producer register is established.

Fee structure: Verpact's existing contribution rates and material categories continue to apply to affiliated participants, and no replacement schedule for small volumes has been published.
Reporting schedule: companies bringing more than 50,000 kilograms of packaging onto the Dutch market in a calendar year pay the packaging waste management contribution to Verpact, report the quantity they place on the market, and submit their prevention and recycling report every year before 1 August^[2].
Threshold validity: The duty to pay and report starts above 50,000 kilograms of packaging brought onto the Dutch market in a calendar year, and that threshold remains in the Besluit beheer verpakkingen 2014 until a new statutory instrument replaces it^[2].

Reporting duties are set to reach below today's 50,000 kg threshold once the PPWR producer register applies: Verpact states that declaring becomes mandatory for everyone meeting the definition of producer, with a lighter regime for companies placing less than 10,000 kg of packaging on the market per year, who report only the weight of the materials used^[3]. However, the exact calculation methodologies and future fee levels have not yet been determined by authorities.

Businesses should separate the certainty that registration will eventually apply from assumptions about cost levels. Webshops should not project current Verpact tariffs onto future small-volume obligations until formal rate schedules are officially published.

Outlook: how the rules develop from here

The regulatory landscape for packaging compliance continues to evolve at both European and national levels. Regulation (EU) 2025/40 fixes the overarching European framework, but its requirements are phased in gradually over the following years and what they mean in practice is not yet entirely clear, as it depends on your activities and your role in the supply chain^[1]. Specific implementation details in the Netherlands also remain subject to pending statutory decrees.

Which obligations apply to your webshop depends on your exact role in the packaging chain. A webshop using standard packaging sourced from an EU supplier faces different legal duties from a business importing packed goods or having packaging manufactured under its own specifications. 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 assessment now. At ClearoSystems, our Digital needs analysis evaluates your specific setup across products, sales channels, and target markets. Afterwards, our experts support you in implementing the requirements and keep you covered as the rules evolve.

Frequently asked questions

Does a micro-volume webshop need to register with Verpact in 2026?: No, if you bring less than 50,000 kilograms of packaging onto the Dutch market in a calendar year, the exemption in the Besluit beheer verpakkingen still applies today. Registration for smaller volumes is expected to begin when the PPWR producer register launches, which Verpact says must be established from 12 August 2027.
Are marketplace-only sellers exempt from the new packaging rules?: No, the PPWR applies to anyone who places packaged products on the market, including those selling exclusively via marketplaces. The 50,000 kg threshold still exempts small sellers from reporting volumes today, but the size-independent PPWR obligations apply from 12 August 2026.
What happens on 12 August 2026 for small webshops?: Regulation (EU) 2025/40 officially applies from this date. While volume registration for small webshops waits for the producer register, you must comply with size-independent duties like proving conformity and the PFAS restrictions for food-contact packaging immediately.
What are the expected costs when the producer register launches?: Future contribution duties are set to reach below today's 50,000 kg threshold once the PPWR register and reporting apply, but the exact amounts and calculation methods are not yet determined. Current tariffs cannot be projected onto future duties.
What happens if I do nothing before the PPWR application date?: If you fail to meet the immediate size-independent requirements on 12 August 2026, such as keeping basic packaging records and ensuring conformity, you will be non-compliant. To be on the safe side, evaluate your exact role in the supply chain now.