What the PPWR changes for Dutch webshops and when
Regulation (EU) 2025/40 entered into force on 11 February 2025 and applies generally across all EU member states from 12 August 2026[1]. The regulation introduces uniform EU-wide rules for packaging design, conformity assessments, and waste management.
Starting 12 August 2026, companies placing packaged goods on the market must conduct formal conformity assessments and hold declarations of conformity for each packaging type[2]. Restrictions on substances of concern, including specific limits on PFAS in food-contact packaging such as 25 ppb for any individual PFAS measured by targeted analysis, also take effect on that date[3]. Further requirements follow in stages. They include a limit of at most 50% empty space in shipping boxes and recyclability performance grades, both from 2030[4].
For Dutch webshops, the 2026 reporting threshold of 50,000 kg under the Besluit beheer verpakkingen 2014 remains in force today[5]. This threshold is not abolished on 12 August 2026. Per Verpact, a PPWR producer register must be established from 12 August 2027, and you can register from the moment it is set up. The first reporting year is expected to be 2028, to be declared before 1 June 2029[6]. Verpact also states that the threshold for filing a declaration disappears, with a simplified declaration for companies placing less than 10,000 kg of packaging on the Dutch market[7]. That timing is Verpact's operational expectation and is not yet fixed in a published Dutch instrument.
Is your webshop affected? A quick self-test
If you package, sell, import, or ship products, you fall under Regulation (EU) 2025/40[4]. The regulation sets requirements for all packaging placed on the EU market, so the whole European Union counts as the market area rather than the Netherlands alone[1][7]. Business size does not create a general exemption from packaging compliance, although businesses with fewer than 10 employees and turnover under EUR 2 million get more flexibility on some rules[4].
The PPWR covers everyone in the EU who makes packaging, is first to place it on the market, or otherwise trades in or uses it. Virtually every business that makes, supplies, sells or discards packaging therefore faces one or more obligations[7]. Which administrative duties apply depends on your role in the packaging chain, and a company can hold more than one role[8]. Operating as a manufacturer, an importer, or a distributor sourcing standard packaging from an EU supplier creates different documentation requirements.
Cross-border sales require separate attention to destination market rules. For example, Germany enforces its own packaging register under the PPWR and the VerpackDG, while electronic devices and batteries fall under separate legal regimes.
To review how the new EU regulation applies to your packaging portfolio, contact ClearoSystems for PPWR consulting.
Selling to other EU countries: the Article 45 representative
One PPWR duty hits cross-border webshops hardest, and it starts on 12 August 2026. Article 45(3) of Regulation (EU) 2025/40 requires a written mandate appointing an authorised representative for extended producer responsibility. You need one in every member state where you make packaging available for the first time and are not established[9]. A Dutch webshop that ships parcels to consumers in Germany, Belgium and France therefore needs a representative in each of those three countries, not one for the EU.
The mandate transfers the operational duties: registration, reporting the quantities placed on the market, paying the financial contributions and answering the competent authority. Your own responsibility for compliance does not transfer with it[9].
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[10]. The Council discontinued negotiations on that file on 24 June 2026. The obligation therefore applies from 12 August 2026 as written, with no small-business carve-out.
Paused or binding? How to tell the two apart
Verpact has pressed a pause button, and it is narrower than the headlines suggest. The pause covers three packaging types only: shipping packaging, service packaging and primary production packaging. For those three, Verpact asks producers and packers to keep working from the situation as it stood before 12 August 2026[2].
The reason is a single unresolved definition. It is not settled whether the producer of shipping, service or primary production packaging is the manufacturer or importer of the empty packaging, or the retailer who fills it[2]. That question decides who declares the kilograms, so Verpact would rather freeze it than have the market guess.
Two things follow for a webshop. Your shipping boxes sit inside the paused group, so your Dutch declaration practice for them does not change yet. But if clarity arrives later, it may apply retroactively to 12 August 2026, so keep the records that would let you refile[2].
Everything outside those three packaging types is binding on schedule. The pause is about who reports Dutch kilograms. It does not postpone the product rules that apply to the packaging itself.
| What it covers | Status on 12 August 2026 | What you do now |
|---|---|---|
| Who counts as producer of shipping, service and primary production packaging | Paused by Verpact, possibly with retroactive effect | Keep your current Dutch declaration practice and keep the underlying records |
| Declaration of conformity and technical documentation per packaging type | Binding | Hold a declaration for every packaging type you have made or import |
| PFAS limits in food-contact packaging | Binding | Get written confirmation from your supplier |
| Authorised representative for EPR in other member states (Article 45) | Binding | Appoint one per destination country you ship to |
| Dutch 50,000 kg contribution threshold | Unchanged national rule | Declare to Verpact if you reach it |
What to do before the key PPWR dates
Preparation for upcoming compliance milestones involves three practical steps for Dutch online retailers.
First, continue your 2026 compliance under current Dutch rules. Companies putting more than 50,000 kg of packaging onto the Dutch market declare to Verpact and pay the waste management contribution[4][5]. That national duty is unchanged by the PPWR. You can review packaging registration guidance to confirm your present obligations.
Second, review your packaging inventory against the coming minimisation and recyclability requirements. Packaging must be no larger or heavier than needed. From 1 January 2030 the empty space in a shipping box may not exceed 50%, and packing material counts as empty space[4]. Check outer shipping boxes to reduce filled volume and avoid unnecessary secondary packaging.
Third, work through Verpact's preparation steps. Identify which role or roles you hold in the chain and which packaging types you carry. Then map what you already know about your packaging and what your supplier can share with you[7]. If you buy or resell packaged goods, check three things: the packaging carries the correct label, it names the manufacturer with an address, and a declaration of conformity exists. Where you have packaging manufactured or import it yourself, you must be able to prove compliance with an EU declaration of conformity from 12 August 2026. Suppliers must give you the information needed for it[4].
- Check whether you must register where you use packaging; in the Netherlands you declare to Verpact, and a waste contribution applies above 50,000 kg of packaging material per year[4].
- Audit packaging sizes and weights: packaging must be no larger or heavier than needed, and from 2030 the empty space in a shipping box must not exceed 50%, with packing material counting as empty space[4].
- Obtain supplier declarations of conformity ahead of 12 August 2026[4].
What has NOT changed: the Dutch EPR system stays
The arrival of Regulation (EU) 2025/40 does not replace the existing Dutch Extended Producer Responsibility framework[5]. For a complete overview of national rules, consult our guide on Dutch EPR schemes.
Producer organisation Verpact continues to manage national packaging collection, recycling systems, and waste management declarations in the Netherlands[5]. Material-based waste management contributions remain active under national regulations[5].
Enforcement authority remains with national agencies, including Rijkswaterstaat and the Human Environment and Transport Inspectorate (ILT)[5]. The PPWR introduces harmonised European requirements on top of this established national structure rather than discarding it.
| Framework Component | Current Status | PPWR Interaction |
|---|---|---|
| National Producer Scheme | Verpact manages collection and reporting | System continues as national execution body |
| Enforcement Authority | Rijkswaterstaat and ILT enforce rules | Authorities enforce both national and EU rules |
| Reporting Base | Material-based volume reports to Verpact | Expanded reporting criteria added in stages |
Outlook: how the rules develop from here
European and national packaging rules remain in development. The European Commission and national authorities will issue further delegated acts and implementation guidance through 2029[2].
Once the EU PPWR producer register is active, waste management contributions will apply to volumes below the present 2026 threshold of 50,000 kg. However, future contribution rates and specific calculation methods are not yet fixed in any published instrument[2].
Which PPWR obligations apply to your webshop depends on your exact role in the packaging chain. A business using standard shipping boxes sourced from an EU supplier faces different administrative steps than an importer or private-label merchant having packaging manufactured to custom specifications. These distinctions cannot reliably be resolved through a general checklist alone.
To understand your PPWR position today and be on the safe side, contact ClearoSystems for PPWR consulting now. Our experts then support you in implementing the requirements and keep you covered as the rules evolve.
Frequently asked questions
- Am I affected by this change?
- Yes, selling packaged goods to Dutch or other EU customers brings your webshop into scope. Business size, specific sector, and B2B/B2C distinctions make little difference under the PPWR.
- What do I have to do before the date?
- You must audit your packaging portfolio against recyclability rules, plan supplier changes, and ensure every packaging type has a declaration of conformity by 12 August 2026.
- What happens if I do nothing?
- Without a valid declaration of conformity from 12 August 2026, your packaging cannot be legally placed on the EU market, which blocks your ability to sell goods.
- Does the PPWR abolish the Dutch 50,000 kg threshold in 2026?
- No, the Dutch 50,000 kg exemption remains in force today and is not abolished on 12 August 2026. Verpact expects it to lapse only when the PPWR producer register takes effect, from 12 August 2027 at the earliest.
- Do I need a representative in every country I ship to?
- Yes, if you make packaging available for the first time in a member state where you are not established. Article 45(3) requires an authorised representative for extended producer responsibility in each such country from 12 August 2026. The suspension proposed for EU-established sellers was dropped in Council on 24 June 2026.
- Has Verpact postponed the PPWR?
- No. Verpact paused one question for three packaging types: who counts as the producer of shipping, service and primary production packaging. Product rules such as the declaration of conformity and the PFAS limits apply from 12 August 2026 regardless, and the pause may later be resolved with retroactive effect to that date.
- How does the PPWR affect imported packaging?
- If you import packaging into the EU, you are considered the first to place it on the market. You hold full responsibility for ensuring a declaration of conformity is drawn up and available.
- Are there new rules for e-commerce empty space?
- Yes, the PPWR introduces strict design rules to minimize packaging volume. The 50% cap on empty space in e-commerce, transport and grouped packaging applies from 1 January 2030.
