Which packaging falls under packaging EPR, and which does not?

The short answer: almost everything you use to ship is packaging EPR

If your Dutch business places packaged goods or shipping packaging onto the Dutch market for the first time, it falls under Extended Producer Responsibility (EPR) for packaging. Under the Besluit beheer verpakkingen 2014, as a 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]. The core rule is simple: Verpact applies the legal definition, which in principle covers all products used for enclosing, protecting, shipping, delivering or supplying other products.

Whether you run a D2C webshop, supply retail channels, or import finished goods into the Netherlands, packaging duties attach to the entity that first introduces the packaging into the Dutch commercial chain. Components and elements of packaging, such as adhesive labels, caps, and pouring spouts, count as part of the packaging they are attached to, so they belong in your declaration too. Shopkeepers that provide takeaway packaging with their name or logo on it are subject to the same obligations that apply to producers and importers^[1]. If you ship products directly to Dutch end consumers or business customers, you hold the reporting obligation. If your commercial growth extends across the border into Germany, a separate registration under Germany's VerpackDG via LUCID applies, as national EPR systems remain separate prior to full EU alignment.

When your product range or sales channels expand, determining where your packaging responsibilities begin and end becomes critical. If your company sits on the edge of these definitions, you can start the EPR needs analysis to clarify your obligations across sales channels and destination countries.

• Sales packaging and its parts: boxes, bottles, cans, drink cartons, and the caps, spouts, and adhesive labels that belong to them.
• Composite packaging made of several materials that cannot be separated, declared per material category.
• E-commerce transport packaging: envelopes larger than the standard C5 envelope used to send goods rather than addressed correspondence^[1].
• Takeaway and point-of-sale packaging: carrier bags, paper bags, chip trays, gift wrap, and pizza boxes handed to customers^[1].
• Single-use logistics resources such as pallets and glass trolleys, which you declare to Verpact only when they are used once and carry a declaration duty rather than a levy^[2].

The scope test: three questions to classify any item

To determine whether a specific item falls under packaging EPR in the Netherlands, you can apply a three-question test built on the legal definition Verpact uses: in principle, any product used for enclosing, protecting, shipping, delivering or supplying another product is packaging, and it only counts as packaging once it is actually used as such. If you are in doubt about a specific item, Verpact's packaging catalogue lets you check whether something counts as packaging and whether the Packaging Waste Management Contribution is due for it^[3].

• Is the item used for enclosing, protecting, shipping, delivering or supplying a product? Empty boxes you produce or import are end products until something is placed inside them, at which point they become packaging.
• Did your business manufacture the packed product, import it, or have it made under your own name, logo, or private label? That role makes you the producer or importer for the Packaging Waste Management Contribution^[4].
• Is the packaging brought onto the Dutch market by you? Manufacturers and importers are responsible for the waste from packaging and packed products they bring onto the Dutch market from abroad, including showroom packaging carrying their name and logo^[1].

Applying these three questions eliminates guesswork for standard inventory and logistics items. For example, a custom printed cardboard box added by your warehouse to ship an order meets all three criteria. The edges are narrower than they look: an envelope smaller than C5 is not packaging at all, and envelopes used for individually addressed correspondence such as letters, invoices, and bank statements are excluded even when they are larger. Adjacent regimes, such as Dutch EPR schemes for electronics or batteries, operate under entirely separate rules and do not affect this packaging classification.

Examples: what falls under packaging EPR and what does not

Clear boundaries exist between items subject to your EPR reporting and items that fall outside your responsibility. The decisive criterion is whether you are the party that brings the packaging onto the Dutch market as packaging: an item only counts as packaging once it is used as such, so boxes you produce or import while they are still empty are end products rather than packaging. Understanding this distinction prevents double-reporting while ensuring full compliance for all webshop packaging materials.

Consider a Dutch webshop that sources standard shipping boxes from a local Dutch packaging distributor. Because the boxes were already brought onto the Dutch market and declared upstream, the webshop does not report those boxes again. If the webshop instead imports the same shipping boxes directly from a manufacturer outside the Netherlands, it is the importer bringing that packaging onto the Dutch market from abroad and carries the responsibility for it, including packaging that arrives under its own name and logo^[1]. Reusable logistics resources that stay in a loop, such as pool or euro pallets, sit outside single-use declaration, while one-off pallets and glass trolleys do have to be declared to Verpact if they were not already declared earlier in the chain^[2].

Step by step: classify and report your packaging to Verpact

Once you classify your packaging items, you must map them to Verpact declaration categories to fulfill your annual reporting obligations. Under the Besluit beheer verpakkingen 2014, a statutory threshold of 50,000 kg of packaging material per calendar year applies for fee payment, counted across all your materials together rather than per material^[1]. If your Dutch business brings more than 50,000 kg onto the Dutch market in a calendar year, you pay the packaging waste management contribution to Verpact, report the quantity you place on the market each year, and submit a prevention and recycling report every year before 1 August^[1]. Below that threshold the contribution and the annual prevention report are not triggered, but you must still be able to show the weight of your packaging and the materials it is made from^[1].

• Build a material inventory: record every packaging component (paper, cardboard, plastics, glass, metals, wood) and its weight, because if you bring packaging onto the Dutch market you must be able to show the weight of the packaging and the materials it is made from^[1].
• Separate deposit-return items: deduct deposit-bearing beverage containers managed under Statiegeld Nederland, where the 2026 deposit is 15 cent per small plastic bottle (up to 1 litre), 25 cent per large bottle (1 litre or more) and 15 cent per can, because these follow separate deposit collection rules^[5].
• Check each item against Verpact's catalogue: the packaging catalogue tells you whether your product counts as packaging and whether a packaging waste management fee is due^[1].
• Calculate total annual weight: multiply unit weights by annual units distributed in the Netherlands to see whether you exceed the 50,000 kg per calendar year threshold that triggers the contribution and reporting duty^[1].
• Register and declare: report the quantity of packaging you bring onto the Dutch market to Verpact each year, using the Dutch-language PackTool to register packaging and single-use handling aids^[1].

For growing Dutch e-commerce businesses, tracking cross-border sales is equally vital. Packaging placed on products exported out of the Netherlands is exempt from Dutch Verpact fees because the waste is generated abroad. You must retain export documentation and delivery receipts to substantiate any export deductions on your Dutch volume report. For businesses navigating these rules alongside cross-border rules, establishing a structured packaging registration routine ensures data accuracy across both home and target markets.

Outlook: how the rules develop from here

EU and Dutch packaging regulations continue to evolve, with key transitions scheduled under the EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40. The PPWR entered into force on 11 February 2025 and becomes generally applicable across EU member states from 12 August 2026, which business.gov.nl flags as the effective date from which stricter packaging requirements change the current Dutch guidance^[1]. The 50,000 kg Dutch contribution and reporting threshold under the Besluit beheer verpakkingen 2014 remains in place today^[1]. How the Netherlands will implement the PPWR in national instruments is not settled, so specific requirements for 2027 and beyond only become real once they appear in the official publications.

• Regulation (EU) 2025/40 entry into force: 11 February 2025, establishing uniform EU framework rules.
• PPWR general application date: 12 August 2026, introducing stricter packaging design and eco-modulation rules across all Member States^[1].
• National Dutch implementation: Pending amendments to the Besluit beheer verpakkingen to align domestic reporting categories with EU wide registry standards.

Which packaging rules apply to your business depends on your exact role in the supply chain. A Dutch webshop using standard packaging sourced from an EU supplier faces different obligations from a business importing packaging or having it 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. After that, our experts support you in implementing the requirements and keep you covered as the rules evolve.

Frequently asked questions

Does this apply to my business?

If your Dutch business is the first to place a packaged product on the market in the Netherlands, you are subject to the EPR obligations and must report to Verpact. This rule fully applies to webshops that add shipping boxes and filler materials.

Are gift wraps and e-commerce inserts considered packaging?

Yes. Gift wrap added by a retailer at the point of sale, along with e-commerce inserts that protect or present the product during shipping, fall under the official packaging definition and must be classified and reported.

Do hangers count as packaging under EPR rules?

Hangers sold with an item of clothing, where the clothing is displayed on the hanger, are generally classified as packaging. Conversely, hangers sold separately as an independent product do not fall under packaging EPR.

How do I classify multi-material packaging?

Multi-material packaging should be separated into its individual material components, such as plastic, paper, and metal, for accurate reporting if they can be separated by hand. Otherwise, you report the predominant material by weight.

What exactly do I have to register or report?

You must register and report the total weight of packaging materials you place on the market, categorised by material type like paper, plastic, or glass. The precise declaration categories and tariffs are defined by Verpact.

What happens if I am late?

Failing to register or report your packaging on time puts you out of compliance with the Besluit beheer verpakkingen 2014. This can trigger enforcement actions by the ILT, increased regulatory scrutiny, and potential financial penalties.