Selling supplements: jars, sachets and packaging rules

Supplement sellers are packaging producers: what the EPR rules require

Selling dietary supplements in the Netherlands triggers Extended Producer Responsibility (EPR) from the moment your webshop delivers its first order. Under the Dutch 2014 Packaging Management Decree (Besluit beheer verpakkingen 2014), any company that places packaged consumer goods on the Dutch market is legally responsible for the waste management and recycling of that packaging^[1]. Whether you sell vitamin gummy jars, blister-packed mineral capsules, whey protein pouches, or liquid herbal drops, the containers and transit materials you use fall squarely within the scope of Dutch packaging EPR.

The legal definition of packaging covers every layer necessary to protect, transport, and present your supplements to the consumer. For online supplement retailers, compliance encompasses three distinct layers:

• Primary packaging: The direct container holding the supplement, such as high-density polyethylene (HDPE) pill jars, glass dropper bottles, aluminium blister packs, or multi-layer powder sachets.
• Secondary packaging: Folding carton outer boxes, presentation sleeves, and bundle wraps that group multiple items together on the shelf or in the parcel.
• Tertiary and shipping packaging: Corrugated cardboard boxes, paper padded mailers, sealing tape, void fill, shipping labels, and pallet wrap used to deliver orders to the end customer.

Verpact is the producer responsibility organisation (PRO) for collective packaging waste management in the Netherlands: it uses the packaging waste management fee to pay for the collection and recycling of packaging and reports the recycling results achieved to the government every year^[2]. As the manufacturer or importer of packaging or packed products, you are responsible for managing that packaging until the waste phase, and you must be able to show the weight of the packaging and the materials it is made from^[1]. Furthermore, if you expand your sales cross-border, separate national EPR regimes apply, such as registering with the German LUCID register (since 12 August 2026 under the PPWR and the VerpackDG) for deliveries into Germany.

Scope test: does your supplement webshop have the obligation?

Not every business in the supplement supply chain carries the legal status of a packaging producer. Under the Dutch 2014 Packaging Management Decree (Besluit beheer verpakkingen 2014), the duty falls on the manufacturer or importer that brings packaging or packed products onto the Dutch market^[1][3], and with effect from 1 January 2023 Verpact applies the contribution to the brand proprietor involved in the manufacture of a product whose trade mark does not belong to the manufacturer, for example a store brand or own private label^[2]. Determining whether your shop acts as a producer under EPR depends directly on your sourcing, manufacturing, and fulfillment structure.

To identify where your business stands, evaluate your commercial model against the four primary operational setups:

An explicit no-case occurs when you purchase pre-packaged, branded supplements from an established Dutch wholesaler or manufacturer who has already placed those units on the domestic market under their own name. In that scenario, the packaging fee and reporting duties have already been fulfilled upstream. However, if you repackage those goods, bundle them into customized gift sets, or pack them into your own e-commerce mailing boxes, your business becomes the producer for those added packaging layers.

If your commercial setup sits on the boundary between contract manufacturing, cross-border sourcing, or marketplace fulfillment, our Digital needs analysis evaluates your specific product and supply configurations to define your exact producer status and legal duties.

Jars, blisters, sachets and pouches: classifying each packaging type correctly

For each pack you register the materials consumed and the weight of each of those materials; multiplied by the quantity of packaging placed on the market in a calendar year, that forms the basis for your declaration to Verpact^[4]. Dietary supplements present specific classification challenges because products often combine rigid plastics, composite barrier foils, and internal protective elements across different packaging types.

Each component of a supplement container must be weighed and classified according to its predominant material by weight:

• Plastic pill jars and tubs: Typically molded from rigid polyethylene terephthalate (PET) or high-density polyethylene (HDPE). The screw cap (often polypropylene, PP), liner, and induction seal must be accounted for alongside the bottle body.
• Glass bottles and droppers: Amber or clear glass bottles are classified as glass packaging. The rubber bulb, plastic screw collar, and glass pipette insert are reported as their respective plastic and glass weights.
• Blister packs (push-through strips): Usually made of thermoformed polyvinyl chloride (PVC) or PVDC sealed to aluminium foil. Because the layers cannot be separated manually by the consumer, blister strips are classified as composite packaging.
• Powder sachets and stand-up pouches: Multi-layer flexible barriers containing aluminium, polyethylene (PE), and polyester (PET) foils. These are classified as flexible plastic or composite packaging depending on the dominant material layer.
• Desiccant packets and cotton inserts: Silica gel pouches, clay packets, and oxygen absorbers placed inside the jar to preserve tablet stability are functional packaging accessories and must be reported as part of the overall packaging unit.

For composite packaging (a laminate of materials that cannot be separated), you pay the packaging waste management fee for each of the material categories that make up the item and you state those categories separately on your declaration^[2]. Separable components such as a paper leaflet in an outer carton are simply reported under their own streams, paper and cardboard for the box and leaflet, rigid plastic for the bottle inside. Components and corresponding elements with a packaging function, such as measuring caps, pouring spouts and adhesive labels, are regarded as part of the packaging they are incorporated into, and you pay the fee for them too^[2].

Thresholds, deadlines and typical volumes for a supplement shop

Meeting Dutch packaging obligations requires establishing a reliable system for weight tracking and annual reporting. If you bring more than 50,000 kilograms of packaging material onto the Dutch market in a calendar year^[5], you must pay the packaging waste management contribution to Verpact, report the quantity you placed on the market, and submit your prevention and recycling report through Verpact every year before 1 August^[1]. Verpact applies the same 50,000 kg figure as its invoicing threshold across taxable packaging, with no threshold at all for single-use plastic and deposit packaging^[2]. Above the threshold the first 50,000 kg is deducted pro rata to each material's share of the weight, so only the remainder is charged; see our worked example of the packaging fee calculation.

For small and medium-sized supplement webshops, total annual packaging weight often remains well below this 50,000 kg threshold. Staying below it does not remove your administrative duties, though: if you bring packaging onto the Dutch market you must be able to show the weight of that packaging and the materials from which it is made, and the packaging dossier must be available at any time the Human Environment and Transport Inspectorate (Inspectie Leefomgeving en Transport, ILT) requests it^[1].

Step by step: from product list to your first packaging declaration

To build a compliant packaging administration, follow these four operational steps:

• Compile a complete packaging bill of materials (BOM) per SKU: Measure the tare weight of every empty jar, lid, label, sachet, and blister pack across your entire product catalogue. Verpact states that this information comes from your packaging designer or supplier, or, in the case of imports, from your foreign supplier's bill of materials^[4].
• Factor in shipping packaging: Calculate the average weight of shipping cartons, parcel tape, packing paper, and shipping labels used per order, and allocate these weights across your total domestic sales volume.
• Maintain annual weight logs: Multiply the unit packaging weights by the total number of units sold to Dutch consumers between 1 January and 31 December of the reporting year.
• Register with Verpact and submit the declaration if applicable: registration with Verpact comes first, and once your aggregate volume exceeds 50,000 kg you file the declaration broken down by material category and submit the annual prevention and recycling report before 1 August^[1].

Outlook: how the rules develop from here

The regulatory framework governing packaging in the Netherlands and across the European Union is undergoing structural reform. Regulation (EU) 2025/40, which entered into force on 11 February 2025 and has applied since 12 August 2026, establishes unified European standards for packaging recyclability, minimisation, and labelling. However, national registration and reporting mechanisms transition through specific phases.

In the Netherlands, the current 50,000 kg threshold remains fully in force today under national legislation^[1]. Per Verpact, the national volume threshold is expected to lapse only when the formal PPWR producer register is introduced, which is expected from 12 August 2027 at the earliest, with the first full universal reporting expected over the 2028 operational year for small webshops. These dates represent administrative planning timelines that remain subject to formal national implementing decrees.

Future waste management contributions will eventually extend to smaller volume producers once universal reporting applies, but the exact contribution rates and calculation methods for lower volume tiers remain undetermined. The statutory rules continue to evolve, making ongoing tracking essential for growing e-commerce brands.

Which packaging obligations apply to your supplement webshop depends on your exact role in the packaging chain. A business that imports finished supplements from third countries carries different legal duties from a brand that formulates custom powders filled by an EU contractor, or a reseller sourcing standard Dutch wholesale lines. These operational distinctions cannot reliably be resolved through a general checklist alone.

To understand your compliance position today and be on the safe side, start the Digital needs analysis now. After that, our experts support you in implementing the requirements and keep you covered as the rules evolve.

Frequently asked questions

Does the packaging obligation apply to my supplement webshop?

If you import packaged supplements into the Netherlands or fill own-brand jars and sachets locally, you are the producer who first places the packaging on the market. This means you must comply with Verpact rules and verify your volumes.

What exactly do I have to register and report to Verpact?

You must document the material categories and weights of all primary packaging, like jars and blisters, as well as secondary shipping boxes. If you exceed the 50,000 kg threshold, you must submit an annual declaration and pay the waste management fee.

Do free samples and refill pouches count as packaging?

Yes, both samples and refill pouches are classified as packaging because they contain and protect the product for distribution. You must weigh them and allocate them to their respective material categories, such as flexible plastic.

How do I report mixed vitamin bundles?

For combined products, you must break down the packaging of every individual component in the bundle. You report the total weight of the materials used across the entire set, including any additional grouping packaging.

Who is responsible for packaging when selling supplements via marketplaces?

If you hold the inventory and sell directly to consumers via a marketplace, you usually retain the producer obligation for the product packaging. Marketplaces are increasingly acting as gatekeepers and will require proof of your compliance.